MTN Double Opt-in

Business Rules

 

Introduction 

MTN is serious about the protection of its customers against unauthorized billing for WASP services.

We have therefore embarked on deploying a Token Based Billing (TBB) technical solution that will

prevent WASPs from billing customers for WASP services without their express consent. A token is

generated for a customer purchasing or subscribing to WASP services and a WASP will not be able to

bill a customer unless the customer has approved the token and it becomes valid. MTN customers

will now be in full control of purchasing WASP Services, whether once-off or subscription services

and can opt out of any and/or all WASP subscription service(s) at any time via MTN’s self-service

USSD menu.

 

Background


MTN currently provides WASPS with access to its Event Based Billing (EBB) System, enabling WASPS

to directly bill a MTN customer for WASP services. This billing mechanism allows for flexible billing

and WASP’s can bill customers once-off for ad-hoc purchases and/or multiple times for subscription

services. MTN is currently reliant on the Wireless Application Service Provider Association (WASPA)

Code of Conduct to govern the billing of WASP services, and are further reliant on WASPS to comply

with the WASPA Code of Conduct to ensure that MTN customers are only billed for those WASP

services for which they have authorized the billing via a double opt-in process as prescribed in the

Code. Unfortunately, due to the EBB System’s inability to enforce the double opt-in process, there

have been heightened claims from MTN customers of unauthorized billing for WASP services. These

claims have resulted in major reputational damage to the MTN brand, high call centre costs and

numerous disgruntled customers. Consequently, MTN has had to seek measures to eliminate these

claims and to minimize all associated risks.

 

Objective


The key objectives are to ensure that:

 

a) Complaints related to WASP services are significantly minimized;

b) Customer engagement with WASP Services is restored and trusted;

c) Customer experience is improved and customer satisfaction is heightened;

d) Onerous accountability is instilled in all WASPS and MTN to provide sustainable WASP services and revenues;


 

4. Token Based Billing Business Rules

 

4.1 Subscribing to WASP Services

 

4.1.1 When a customer authorizes the WASP to bill them, the customer must be made aware of the

         following information: 


a) The service or product that the customer is purchasing;

b) The frequency of the service/product being purchase i.e. once-off or monthly subscription;

c) The amount the customer is agreeing to be charged per frequency; and

d) Disclaimer or Terms and Conditions the customer agrees to in terms of this purchase and

    authorization.

 

When a customer opts in via any channel/bearer type other than WAP/Web or USSD, the customer

will be provided with a USSD string by the WASP (eg *141*5*3digitpin - also provided by WASP#.)

Once the USSD string is entered, the customer will be taken directly to opt in for the subscription

instead of having to navigate the USSD menu.

 

4.1.3 Tokens are created in a pending state until authorized by the customer.

 

If a customer authorizes a pending token within 7 days, the token status will change to active.

Otherwise the pending token will expire.

 

4.1.5 When a token is created successfully, the WASP will be notified.

 

4.1.6 When a token’s status changes, the WASP will be notified.

 

4.1.7 Tokens can run indefinitely or have an expiry date, depending on the services the customers

        subscribed for and information provided by the WASP.

 

4.1.8 Authorization of a token by a customer must be free of charge and under no circumstances will

        a WASP be allowed to bill a customer for same.

 

4.1.9 Authorization by a customer for WASP services must, as far as possible, not break away from

        the channel it is accessed on/in.

 

4.1.10 The WASP should not attempt to bill the customer for an amount higher than the value of the

          token approved by the customer. Any such attempts will be billed to the WASP by MTN at an

          amount still to be defined.

 

4.1.11 appropriate error messages will be returned to the WASP informing them of successful or

          unsuccessful token generation.

 

4.1.12 Real time notifications must be sent to WASP in the event of a token status change.

 

4.1.13 The WASP must redirect the subscriber to the MTN approval page hosted at

           http://ebb.mtn.co.za for the subscriber to approve or reject the service request. This page may not

           be replicated by the WASP and hosted on its servers.

 

4.2 Unsubscribing from WASP Services


4.2.1 If a customer unsubscribes from content purchased from a WASP, the token status will be

        changed and no further billing attempts can be made on that token. If the WASP attempts to bill, a

        levy, to be determined by MTN, will be charged to the WASP. 

4.2.2 Real time notifications will be sent to the WASP when a token’s status changes.

 

4.2.3 Customers must be able to unsubscribe via the USDD self-service channel. Customers can opt

        out of any subscription service(s) at any time using MTN's self-service USSD menu on *141*5#, as

        well as MTN’s or the WASP's call centre.

 

4.2.4 When details of an active token is displayed once selected from the active subscriptions list,

        the customer will have the option to unsubscribe from the service.

 

 

Retrieval of Lost Tokens by WASP


4.3.1 All tokens, regardless of the status in the TBB database for a specific WASP, will be made

        available in a secure location for the WASP to retrieve.


4.3.2 All used and rejected tokens will be periodically removed from the TBB database by MTN and

        will not be included in the daily token dump thereafter.


4.4 TBB token removal for Recycled Numbers


4.4.1 Once a MSISDN is put in suspension before recycling, MTN will ensure that all tokens for that

        MSISDN will be made inactive.

        If a MSISDN is made available (recycled) again all tokens will be invalid and only new Token Based

        Billing transactions will be enacted (i.e via approval of a token by a customer).


4.4.3 Real time notifications will be sent to the WASP.


4.5 Validate WASP Token


4.5.1 The WASP can only use a token in an active state in order to bill a customer for services.

4.5.2 If the WASP attempts to bill a customer using a token in any status other than active, penalties

        as per the error codes list will be levied.

4.5.3 If the WASP has already billed the customer for the period, a penalty will be incurred by the

        WASP if the WASP attempts to do so again within the same period.

4.5.4 The WASP cannot bill a customer for an amount exceeding that agreed to on authorization of

        the token by the customer.

4.5.5 Each time the WASP attempts to bill a customer using an active token, MTN will check if there

        are sufficient funds.

4.5.6 If there are sufficient funds and the token is active, the customer will be billed by the WASP

        (not exceeding the maximum amount of the token for the period).

4.5.7 Should a customer not have sufficient funds when a WASP attempts to bill them, the WASP will

        be informed accordingly, but no penalties will be levied on the WASP for such attempts. However, if

        billing success of the same attempts is less than 30% of the total billing attempts, MTN will levy a

        charge to the WASP for these attempts at a rate to be determined by MTN.

        The WASP will be able to bill customers an amount lower than that agreed to upon authorization of

        the token.

 

4.6 Recovery Billing


4.6.1 A Recovery bucket will be created for each token that was partially or never billed, within a

        particular service interval.


4.6.2 The recovery bucket will hold the amount that the WASP can recover. (For example, if the

        subscription is R7 per week and the WASP can only successfully bill the customer R6 for this week,

        then the recovery bucket will be updated with R1.)


4.6.3 The recovery bucket balance will never be made available to the WASP. 

4.6.4 If the WASP wishes to recover costs, the WASP must indicate the request as a WASP recovery

        request, as per the Technical Specification provided by MTN.


4.6.5 MTN may later wish to charge WASPs a transaction fee when attempting to collect from a

        recovery bucket that is empty = R0 or on an amount exceeding the recovery bucket balance.


4.6.6 The WASP must clearly communicate these billing methods to customers.

 

The dynamic arrears period must be set as follows per frequency, but MTN reserve the right to

change this as and when required:


a) Hourly services: Billing request end period + 12 hours.

b) Daily services: Billing request end period + 5 days.

c) Weekly services: Billing request end period + 14 days.

d) Monthly Services: Billing request end period + 30 days.


 

Should a recovery amount within the bucket reach the end of its arrears period, the amount will be

removed from the recovery bucket. Thus the oldest recovery amount will be removed first, as it will

reach the end of the arrears period first.


4.6.9 The recovery bucket will thus hold the sum total of all the amounts that the WASP can recover

        on, but each amount will have an expiry date, which will be the arrears period. The arrears period

        allows a WASP to collect a specific amount only for a certain period, thereafter the amount falls

        away (removed from recovery bucket total and recovery bucket total updated) and the WASP

        cannot recover that amount anymore.

 

4.7 Call Centre Customer Support for Unsubscription of WASP Services

 

4.7.1 MTN Call centre agents will be able to view customer subscriptions based on token billing. 

4.7.2 Call centre agents will not have access to unsubscribe customers from services, however they

        can provide the customer with instructions on how to unsubscribe via MTN’s self-service USSD

        channel.


4.7.3 Existing access and processes for call centre agents will remain in place. Access to WASPA and

        e-mail to the WASP to fulfil requests from a customer, remains as per the current process

 

WASP Transaction Fees


All WASPs will pay a transaction fee of R0.05 (excl. VAT)

 

Migrations


4.9.1 All customers that have a content billing barring option loaded on their MSISDN at time of

        migration from EBB to TBB, will be excluded from the migration and their subscriptions invalidated.

        Tokens for these MSISDN will not be generated by MTN.


4.9.2 Penalties imposed on the WASP if any unauthorised subscriptions are included in the

        subscriber database to be migrated to TBB, as provided by the WASP, are contained in paragraph 5.6

        of these Business Rules.

 

5. General Business Rules

 

5.1 The Token Based Billing Services Annexure supersedes the EBB Services Annexure to the MTN

      WASP Agreement.

 

5.2 The Token Based Billing Rules will apply to all Token Based Billing transactions using all bearer

      types.

 

5.3 Where the WASPA Code of Conduct differs from MTN’s Token Based Billing Rules, MTN Business

      Rules will take precedence.

 

5.4 All requests from customers to opt-out of services they are subscribed to via a WASP must be

     free to the customer.

 

5.5 Any opt-out requests from customers to marketing messages from the WASP must be free to the

     customer. In the event that MTN finds, through validated channels, what it deems excessive opt-out

     requests from customers, this will be considered SPAM and MTN will reverse-bill the cost of that

     opt-out to the WASP at the MTN standard rate. 

MTN may, at its sole discretion and without prejudice to any right which it might have to terminate

the service, elect to immediately suspend the provision of the service if:

 

5.6.1. MTN has reasonable grounds to consider it is entitled to terminate the service; 

5.6.2  MTN is obliged to comply with an order, instruction or request of a court, government agency,

         emergency service organisation or other administrative or regulatory authority; 

5.6.3  MTN has reasonable grounds to consider that the service is being used fraudulently or illegally;

 

5.6.4  MTN has reasonable grounds to consider that the WASP will not or is unable to make any

         payment which is due or is to fall due to MTN hereunder;  


5.6.5  MTN has reasonable grounds to consider that the WASP is or has been involved or connected

         with criminal activity or other activity, which is or may be detrimental to MTN; or MTN TBB


5.6.6  MTN has reasonable grounds to believe that the WASP has billed any of its customers without

         the customer’s consent/authorization.


If MTN exercises its right to suspend the service it shall, whenever reasonably practicable, give prior  

notice of such suspension to the WASP, such notice to state the grounds of such suspension and its

expected duration. MTN shall in such circumstances use all reasonable endeavors to resume the

Service as soon as is practicable.


5.8  If the service is suspended as a consequence of the breach, fault, act or omission of the WASP,

       the WASP shall pay to MTN all reasonable costs and expenses incurred by the implementation of

       such suspension and/or recommencement of the provision of the service.


5.9  MTN reserves the right to withhold any revenue that may accrue to the WASP during the

      suspension period. All WASP revenue will only accrue to the WASP once the breach, fault, act or

      omission of the WASP has been remedied in on or before the agreed upon time period.

 

5.10 MTN shall not be liable for any loss, damage or inconvenience suffered by the WASP as a result

       of any suspension, except to the extent that such suspension is directly attributable to the

       negligence of MTN.