The Ghana Chamber of Telecommunications wishes, on behalf of its members, to respond to a publication on your website dated Monday, March 18th, 2018 under the above headline.

The story said, “Mobile network providers and their agents are in an ongoing practice of violating the Subscriber Identification Module (SIM) Registration Regulation (L.I. 2006).”

The above story further said, “Telecommunication network providers did not send representation for the interface and stakeholders at the meeting requested journalists present to demand answers from the industry”

These conclusions were drawn from video evidence presented by the Consumer Advocacy Center (CAC) and summary analysis deduced from the evidence during the World Consumer Rights Day 2019 (WCRD).

We wish to state categorically that the mobile industry does not sell or condone the selling of pre-registered SIM cards by street vendors or traders.

As responsible corporate entities, we have binding contracts with our distributors and terminate same when they are flouted in that regard. We will continue to work with our Regulators in finding medium to long-term solutions to manage the problem of SIM cards registered with fictitious credentials.

Our position is bulleted below in response to the ongoing dialogue;

1. Prior to the commencement of the SIM Registration exercise; the Industry Regulator directed the use of only the following ID documents; National Passport, Drivers’ License, Voter’s ID, National Identification Card, and NHIS Card.

2. The problem here is none of these five documents is compulsory to have, as well as evidence shows huge flaws in the creation of most of these five (5) ID documents, an example is the DVLA, which states that close to 40% of the drivers’ licenses in Ghana are fake.

3. What does such evidence mean for the authenticity and validity of the major registration ID documents which millions of subscribers had and till date use to register their SIM numbers?

4. Mobile Operators and their channel partners and agents continue to comply with the SIM Registration law but there appears to be a problem of verification, i.e. the absence of a national register, which should carry the unique record of each citizen and foreigner resident in this country and provide the additional level of security gap the industry requires.

5. Without the Ghana Card, the mobile operator or its agents or merchants cannot single-handedly verify the multiple approved IDs shown them on a daily basis to deny the customers their right to communicate using a SIM card.

6. Also, identity checks can be relatively easily circumvented due to the difficulties in validating identity documents in a retail environment. This is because verification and authentication are critical elements in limiting identity fraud.

7. The availability of a national identification database and whether the identity documentation being used can be validated against a government registry, either at the point of sale or at the point of activation, has a significant bearing on the registration solution and enhances the sanctity of the SIM being registered.

8. Fortunately, the mobile industry employs short-term methods of educating customers regularly through numerous awareness programs engineered by the industry to secure their use of the many services that mobile offers including mobile money.

9. The mobile industry also employs the fraud management system to track the abnormal activities of such fraudsters to delete them off their network. Customers are usually requested to send fraudulent mobile numbers to the toll-free shortcode “419” to allow for quick investigation of sim cards found to be engaged in fraud.

10. We are committed to resolving this problem in the long term, working directly with the National Identification Authority to upon completion of the Ghana Card exercise, verify all mobile SIM cards to validate all existing mobile SIM cards to the government unique identification database. Therefore, avoiding the sale of SIM cards in the streets does not resolve an ID validation and authentication problem.

In conclusion, we will urge the CAC led by Prof. Goski Alabi to submit the said evidence for scrutiny and redress by the mobile industry. We also wish to recommend to the CAC to avoid short-serving the industry to such important events like engaging with our customers.

We encourage customers to desist from purchasing pre-registered SIM cards and report such practices to the police and/or mobile network operators for resolution.

Signed,

Derek Laryea

Head, Research

Ghana Chamber of Telecommunications