Emergency Call Routing – Requirements and Limitations of Use
This document supplements the Master Service Agreement, or any other separate written agreement entered into between the Parties in which Customer is expressly authorized to use the Services solely for its own internal business purposes, as applicable (the “Customer Contract”). Capitalized terms not elsewhere defined herein will have the meaning ascribed to them in the Customer Contract or any applicable Order Form.
This document describes the service limitations and conditions that apply to any party using any Emergency Services (911, E911, 999, 112 etc as applicable by country), products and services as part of the session initiation protocol (“SIP”) based voice over the internet (“VoIP”) services (collectively in this document called “Services”) provided by Sip Communications Group Limited and its affiliates and subsidiaries (“Sipcom”) and any user of any software application or service made available by the Customer that interfaces with the Services (“User(s)”).
In the event of a conflict between the terms of this document and the Customer Contract between Sipcom and Customer, the terms set herein shall prevail.
This document may be modified by Sipcom from time to time, upon reasonable notice, which may be provided via Customer’s account, e-mail, or by posting an updated version of this at www.Sipcom.com. The Customer continued use of the Services on or after the date the modified version of this document is effective, and binding constitutes the Customer acceptance of such updated document. If the Customer do not agree to the modified version of this document, the Customer must stop using the Services immediately. Sipcom encourages Users to review this document regularly.
Terms capitalized when used within this document have the following meanings:
“911 Services” means functionality that allows Users to contact Emergency Services by dialling the digits 911. This is the US and Canadian emergency number which works across North America and many US and Canadian territories.
“999 Services” means functionality that allows Users to contact Emergency Services by dialling the digits 999. This is the emergency number which works in the UK and a number of other countries.
“112 Services” means functionality that allows Users to contact Emergency Services by dialling the digits 112. This is the EU emergency number which also works in UK and all EU countries and many but not all other countries (alongside any pre-existing country-specific emergency numbers).
“Basic 911 Services” means the ability to route an emergency call to the designated entity authorized to receive such calls serving the Customer’s ERL. With basic 911, the emergency operator/despatcher answering the phone will not have access to the caller’s telephone number or address information unless the caller provides such information verbally during the emergency call.
“Emergency Response Location” or “ERL” means that address provided by the Customer that is associated with a telephone number provided by Sipcom, that identifies the location to be registered with and used in the event a call is made to the Emergency Services.
“Emergency Service(s)” means those services (fire, police, ambulance etc) available by calling 911, 999, 112 or other country specific Emergency Service number.
“Emergency Location Identification Number” or “ELIN” is a ten-digit number which is associated with an ERL that is presented to the PSAP so they can match the caller phone number to the ERL and provide a call back number to the PSAP in case a call is disconnected. This is only used with 911 Services.
“Enhanced 911 Service” or “E911” means the ability to route an emergency call to the designated entity authorized to receive such calls, which in many cases is a Public Safety Answering Point (“PSAP”), serving the Customer’s ERL and to deliver the User’s telephone number and ERL automatically to the emergency operator/despatcher answering the call.
“Interconnected VoIP Service(s)” are those services provided by Sipcom where the application utilises VoIP to deliver the calls. This includes but is not limited to: Teams/Cisco/Zoom Direct Routing, SIP Trunking, SIP Origination/Termination, and Hosted IP-PBX.
“Reseller” means that third party who is contracted with Sipcom to buy and resell the Sipcom Interconnected VoIP Services to its own customers.
Basic 911 Services: When Customers make a 911 Services call, the Interconnected VoIP Service will attempt to automatically route the 911 call through a third-party service provider to the PSAP corresponding to the Customers ERL. However, due to the limitations of the VoIP telephone services, the 911 Services call may be routed to a different location than that which would be used for traditional 911 dialling. For example, the Customers call may be forwarded to a third-party specialized call centre that handles emergency calls. This call centre is different from the PSAP that would answer a traditional 911 call which has automatically generated ERL information, and consequently, the Customer may be required to provide name, address, and telephone number to the call centre.
How Customer information is provided: Interconnected VoIP Service will attempt to automatically provide the PSAP responder/dispatcher or emergency service operator with the name, address and telephone number associated with the Customer’s account. However, for technical reasons, the emergency responder/dispatcher receiving the call may not be able to capture or retain the Customer name, phone number or physical location. Therefore, when making a 911 emergency call, the Customer must immediately inform the emergency responder/dispatcher of the caller’s location (or the location of the emergency, if different). If the Customer is unable to speak, the emergency responder/dispatcher may not be able to locate the Customer location if the information is not up to date.
With Enhanced 911 Services, when a caller from a registered location dials the digits 911 from any Sipcom offered Interconnected VoIP Service that is associated with a phone number and ERL, the phone number and ERL are automatically presented to the local emergency centre serving the location. Emergency operators/despatcher will have access to this information regardless of whether the caller is able to verbally provide such information.
999 Services and 112 Services
With 999 Services or 112 Services, in general when a caller dials 999 or 112, the call will be routed to the correct local emergency centre serving the location (where appliable) based on the ERL and the operator answering the call will see the phone number and customer ERL. The operator answering will ask the caller to verbally confirm their current location and which they can check if it’s different that the ERL in Emergency Services database. If they receive silent call or don’t receive verbal confirmation of different address, they will fall back and use the ERL in the Emergency Services database.
However, the emergency call processing depends on the national regulation applicable in each country. In each country legal and/or regulatory requirements stipulate the manner in which a telephone call from a given User to Emergency Services number(s) should be routed. The 999 and 112 emergency call processing are split into three different groups.
- Centralised – meaning all calls are routed to the same emergency service. Examples are UK and Ireland.
- Location based – meaning calls will be routed to the emergency service based on the caller’s emergency location address. Examples are France, Germany, and Spain.
- Location Area Code (“LAC”) based – meaning calls will be routed to the emergency service based on the LAC element of the telephone number. Examples are Italy, Netherlands, and Portugal.
To assist the Customer with maintaining accurate ERL details for their Users Sipcom have created a platform accessed via a portal to provide the ability to update User ERL details in a timely manner as and when the information needs updating (“Voiceplatform”). To ensure the Customers remain aware of this obligation Sipcom will send out automated half year reminders to help keep these details up to date. On the portal, a link to which will be provided to Customers during the implementation phase of their project, there are two short training videos to show how to update the different fields for the User ERL details. To remain compliant with the applicable laws and regulations, Customers must access the Voiceplatform portal to validate the User ERL details for each of their allocated telephone numbers.
Interconnected VoIP Services – Limitations
Interconnected VoIP Services allow the Customer to make or receive telephone calls over the Internet to or from the public switched telephone network. The nature of VoIP telephone calls, while appearing similar to traditional telephone calling services, create unique limitations and circumstances, and the Customer acknowledges and agrees that differences exist between traditional telephone service and VoIP telephone services, including the lack of traditional 911 emergency services.
Because of the unique nature of VoIP telephone calls, emergency calls to 911 via a VoIP service will be handled differently than traditional phone service. The following provisions describe the differences and limitations of 911 emergency calls, and the Customer hereby acknowledges and understands the differences between traditional 911 service and VoIP calls with respect to 911 calls placed to Emergency Services as described below.
- Interconnected VoIP Services; acknowledges and agrees that all of Sipcom’s Interconnected VoIP Services are Internet based and that the 911/999/112 calling capabilities Interconnected VoIP Services are different from those offered by traditional providers of local telephone services using the public switched telephone network (PSTN). Sipcom’s Interconnected VoIP Services are not meant to be relied upon in the case of an emergency for the reasons set out in this document. CUSTOMERS SHOULD AT ALL TIMES MAINTAIN AN ALTERNATIVE MEANS OF CALLING EMERGENCY SERVICES. For technical reasons, including network congestion, it is possible that a 911/999/112 Services call will produce a busy signal or will take longer to connect when compared with traditional 911/999/112 calls.
- Network and Power; problems with the Customer Internet connection, including network congestion, as well as loss of power will disrupt or prevent any Sipcom Interconnected VoIP Services from functioning. If this occurs, the Customer will not be able to call the Emergency Services.
- Service Disconnected or Outage: If the Customer has a service outage due to an issue within the network or application or due to a suspension of the Customer account due to billing issues, the Sipcom Interconnected VoIP Services will not function, and the Customer will be unable to make a call to the Emergency Services. The Customer must not disconnect the 911/999/112 Services call until told to do so by the emergency operator/dispatcher, as the emergency operator/dispatcher may not have the Customer number or contact information. If the Customer is inadvertently disconnected, they must call back immediately.
- Geographic Location Details: VoIP services are technically capable of being used in locations that are not associated with the traditional geographic area of a telephone number. However, these capabilities can cause problems connecting to and using the Emergency Services. All emergency calling capabilities will only be available in the location that the Customer has associated with the particular Sipcom assigned Customer telephone number. For Basic 911 Services or E911 and 999 and 112 Services to be accurately routed to the appropriate emergency call centre, the Customer must provide accurate telephone number details as the call-back telephone number for all emergency calls and accurate ERL information. Additionally, if the Customer is using the service in a location that uses a different area code than the area code in the number the Customer is using with the Sipcom Interconnected VoIP Services, when the Customer dials the Emergency Services the Customer may not be able to reach any emergency personnel. Even if the Customer does reach emergency personnel, the call may not reach the emergency personnel near the Customer’s actual physical location and the emergency personnel may not be able to transfer the call or respond to the emergency. In this situation the Customer must use an alternative method to call the Emergency Services, e.g., a mobile phone.
- Correct Emergency Service Centre: Failure to provide a correct ERL in the correct format may cause all Basic 911 Service or E911 or 999 Service or 112 Service calls to be routed to the incorrect local emergency service provider. Furthermore, use of any Sipcom Interconnected VoIP Services from a location other than the location to which such service was ordered, may result in emergency calls being routed to the incorrect local emergency service provider.
- Changed Equipment Location: It is important that the Customer registers accurate ERL every time the Customer moves the equipment associated with the Sipcom Interconnected VoIP Services. If the Customer moves the equipment to another location without reregistering, when the Customer dials the Emergency Services, the Customer may not be able to reach any emergency personnel. Even if the Customer does reach emergency personnel, if the Customer has not provided valid ERL the Customer will not be calling the emergency personnel near the Customers actual location and the emergency personnel may not be able to transfer the Customers call or respond to the Customers emergency.
- Location Accuracy and Changes to Location: It is important that the Customer registers an accurate ERL when the Customer initiates the Sipcom Interconnected VoIP Services and every time the Customer moves the equipment associated with the Interconnected VoIP Services. When the Customer changes the Customer location, it may take up to 48 hours for the Customer location change to be reflected in Sipcom’s records. During that time, the Customer may not be able to reach the correct Emergency Services centre or any emergency service provider by dialling the Emergency Services.
- Nomadic VoIP: Certain Sipcom Interconnected VoIP Services are designed to be used anywhere and are not fixed to a specific service location. Sipcom does not recommend this service is used to call the Emergency Services nor does it guarantee calls made to Emergency Services with nomadic VoIP services will work and Customer acknowledges and agrees to this limitation.
- Inform other Users: The Customer is responsible for notifying, and the Customer agrees to notify, any User or potential Users of the Sipcom Interconnected VoIP Services of the nature and limitations of 911/999/112 Services calls with regards to the Sipcom Interconnected VoIP Services.
- Liability: Customers are advised to review this section with respect to Sipcom’s limitations of liability.
With some exceptions, mostly in Europe, Emergency Services access is supported only on geographic numbers. It’s also only supported on numbers that Sipcom provides that accommodates Emergency Services, or those which are ported over via Sipcom that accommodates Emergency Services; Sipcom cannot enable it for other telecoms operators.
Because of regulatory requirements around the world, all Customers of Sipcom have to provide the required ERL details before they can use the associated services. Sipcom Customers (including Resellers) must ensure the limitations of this document are understood by the Users of the Interconnected VoIP Services.
For Resellers it is the Reseller responsibility to ensure the Customer ERL details are correct and processed at the time the applicable number is provisioned with Sipcom. Additionally, it is the Resellers responsibility to ensure their customer is fully aware of this document and understands the limitations associated.
If the Customer have questions about whether the phone service the Customer are receiving is an Interconnected VoIP Service, contact the Sipcom support team at firstname.lastname@example.org for further information.
SIPCOM UNDERSTANDS THAT THE CUSTOMER, OR RESELLER, OR USER, HAVE READ AND UNDERSTAND THE REQUIREMENTS AND LIMITATIONS ASSOCIATED WITH 911, 999, 112, OTHER EMERGENCY SERVICES AND E-911 EMERGENCY SERVICES AVAILABLE THROUGH THE SIPCOM INTERCONNECTED VOIP SERVICES. SIPCOM CANNOT ACCEPT ANY LIABILITY WHATSOEVER FOR ANY ERRORS OR OMMISSIONS ON BEHALF OF THE CUSTOMER OR RESELLER OR USER THAT RESULTS IN THE FAILURE OF THE EMERGENCY SERVICES TO MEET THEIR OBLIGATIONS.
Any obligations that may be imposed by national regulatory body or law, or federal and state law on operators of private branch exchange or multiline telephone systems are obligations imposed on the Customer, and not on Sipcom.
Sipcom’s Interconnected VoIP Services will only be used for business, non-residential purposes. in an environment that requires either multiple lines or extensions and if this situation ever changes the Customer will discontinue the use of Sipcom’s Interconnected VoIP Services.