DPOs against notifying changes in addressable system to broadcasters

TV broadcasters and distribution platform operators (DPOs) have offered differing views on the mandatory reporting of every change made in the addressable system which includes CAS, SMS and other related systems.

It is consultation paper ‘The Telecommunication (Broadcasting and Cable) Services Digital Addressable Systems Audit Manual’, the Telecom Regulatory Authority of India (TRAI) has sought comments “whether it should be mandatory for every DPO to notify the broadcasters for every change made in the addressable system.

The response of the broadcasters and DPOs are on predictable lines with the former supporting such a move while the latter has argued that the condition is too onerous on them.

In its submission, the Indian Broadcasting Foundation (IBF) has stated that it should be mandatory for every DPO to notify the broadcasters for every change made in the addressable system (CAS, SMS and other related systems).

The IBF’s argument is that since CAS, SMS and other related systems are important components of the addressable systems and also they directly impact the revenues of all the stakeholders in the chain, the DPOs should mandatorily inform the broadcasters of the changes that would have been made in the addressable systems within 7 days in writing.

This, it added, would further tighten the provision already provided under the regulations.

“Further, it is critical that not only the hardware changes but also the software changes made if any, is notified to the broadcasters. Care should be taken while replacing the existing data servers (CAS/ SMS) to protect the historical data of the old addressable system. Replacement cannot be excused for the data loss. As per the Regulations, last 24 months’ data along with all logs to be preserved,” IBF said in its submission.

The All India Digital Cable Federation (AIDCF) is of the opinion that the said clause will only add to the burden on the DPOs. In its submission, it said that CAS /SMS are an integral part of the addressable system and depending upon the market requirement, there are updates happening to both on a routine basis.

These changes, it said, have no business/commercial impact on the Broadcasters and are of technical nature to ensure smooth functioning of the systems. Informing the Broadcasters about all and every little change in these would entail extra burden on the DPO’s.

At the same time any wholesome change like installing new SMS/CAS deployed by the DPO’s should necessarily be informed to the broadcasters, whose channel are being run by the DPO’s within 15 days of such change, it added.

Direct to home (DTH) operators Tata Sky, Bharti Airtel, and Dish TV are also of the view that the DPOs should not be burdened with sharing each and every change in the addressable system.

Dish TV noted that the broadcaster while granting the signals of its channels, seek a certificate from the DPO regarding the CAS and SMS. It further stated that till such time the CAS and SMS of the DPO are compliant with the specification laid down by the TRAI, there should not be any need to intimate any broadcaster regarding any changes made in the same.

“It is important to note that in any case, the broadcaster shall have the right to Audit the Technical Systems of the DPO,” it noted.

Tata Sky stated that the audit manual needs to clearly identify the major changes, which require intimation to the broadcasters any. These include changes in the version number of the Conditional Access System, change in the ownership/Name of CAS, and changes in the simulcrypt status of conditional access.

The IBF stated that the audit agency should be given free hand in the deployment of processes/analysis and should have the ability to use their own Laptop with all the software for the purpose. Audit firms have developed tools to recalculate the correct subscriber base which will not only improve the accuracy of Audit analysis but also reduce the time for completion of Audit.

After completion of the audit, the DPO in any case, can check and retain the personal data (specific to DPO) and allow the auditor to have the data which is required for analysis, it stated.