The new normal: The case for a permanent work from home provision for OSPs

A recent circular by Department of Telecommunications (DoT) has relaxed restrictions for BPOs, KPOs and medical transcript service providers up to April 30, enabling lakhs of employees to Work from Home The relaxation is for a category that describes as Other Service Providers (OSPS which includes services likes BPO, billing service center, e-publishing center, financials service, KPOs  medical transcript, network operating center, telemedicine, and tele education.

As per DoT rules, OSPs are required to make a mandatory security deposit of Rs 1 crore per office location to enable Work from Home (WFH) for its employees. In its order, the government has temporarily waived this requirement.

The government has also exempted the requirement of going through an authorized PPVPN for providing WFH facility, which means employees can now connect to the client-server. Enterprise server through any secure VPN connection. These requirements were previously imposed to ensure there would be no misuse of customers data and if there was they could be easily traced    

Can you set the context to why the current regulations were fixed for OSPs and under what circumstances were they framed and enacted in the first place?
In the early nineties, the government introduced registration for IT service providers like International call centres who serviced customers outside India. With the international calling rates being extremely high then, the Other Service Providers (OSP) centres were allowed to operate using their own international leased lines, which were operational 24×7. As an increased source of foreign revenue OSPs also gave boost to employment in cities like Gurugram, Bengaluru, Chennai and Mumbai. 

How has the situation changed, making the said regulations either archaic or irrelevant?
Today India enjoys outsourcing of IT enabled services in sectors like banking, Insurance, medical research, publishing, tech support, analytics, legal services, finance, accounting and digital marketing. India is well suited for  service delivery centres for multinationals. The country also has numerous common outsourced operations which are either captive or third party, they being Contact Centres, Network Operations Centres, BPOs, KPOs, LPOs and IT helpdesk.

In the last decade there has been a huge drop in international calling rates, this combined with available technology and manpower allows businesses to make cheap/free calls anywhere in the world. Technologies such as Multiprotocol Label Switching (MPLS) and  Software Defined  (SD) WAN have made the expensive leased lines redundant and made the the overall cost of operations inexpensive. Also, the revenue loss is not a concern for the government anymore.

The DOT regulations for such outsourced operations are cumbersome and it is                associated with heavy fines in case of non-compliance. 

As to what I understand the reason behind the current regulatory regime for OSPs, is that the Government wants to keep the path open for generating a trail in case a security breach happens. With dynamic IP addresses / cloud computing, it’s not possible. However with a fixed location / Static IP, it’s possible. Second point, is this also about having a zero-trust approach ?

The traceability of all the calls and internet communication is important from the internal security point of view as well. Government is more concerned about the security aspect than the toll bypass. OSP’s in the larger frame of the Internet industry are only 4.3 million agents that use internet communication for data and voice. It is not understood why the OSP agents / ITeS industry are viewed as a threat to security to the nation which has over 500 million Internet users. Security in OSP/(ITeS) and the rest of the internet community must not be differentiated when it comes to remote working. 

Remote working for OSP agents is strictly regulated with not a single WFH registration issued by DoT prior to COVID-19. Currently DoT has issued a relaxation for allowing OSP agents to work from home but with the condition the agents need to use VPN, which is a redundant technology. The relaxation also calls for INR 5,00,000 of fine per agent in case of violation. This move is  draconian for the OSP/ ITES industry.

I am assuming there is a valid reason behind the Government’s restrictions. There might also be a possibility where the policy makers understand that the current OSP-VPN work from home norm is redundant but they would need special legislation to change the said policy. Can the Govt change the regulations for OSPs, the ones you have mentioned ?
The regulations have not been amended since the last 12 years. TRAI recently issued a consultation paper on “Review of Terms and Conditions for registration of Other Service Provider(OSP)” on the request of the industry. The recommendations were made to DoT in October 2019. These recommendations are made keeping the latest technologies in consideration as well as recommending ways to regulate the OSP centres but the initiative is not enough to accommodate many important aspects.

Why do you think it’s a concern, because the OSP employees will resume working from office, once things settle down? It’s just a matter of a few days and as it is the Govt has relaxed the 1 cr deposit regulation?
First let’s get the elephant out of the room and accept COVID is not going away soon.  The new norm  is  remote working or WFM which is here to stay for times to come.

TRAI  recommendation is to replace PPVPN network to a home broadband connection over a secure VPN over the internet to connect to the respective OSP centre. 

The recommendation to use VPN is not feasible because there are several and  simpler ways to connect remotely over a secure connection. Zero Trust Architecture and Cloud are some of the other secure ways of remote working. The ask for static IP address is also unnecessary. 

It is important that WFH must not be restricted to a single place of remote working, it must be flexible about the place from where you want to work remotely. 

While TRAI has shared these recommendations with DoT, who in the interim has given temporary relaxation to the OSPs allowing their teams  to work from home using a secure VPN over a home broadband internet. 

Having said this, there has to be a  quick, simple and permanent solution for WFH for all OSP agents to allow the future of remote working. This temporary relaxation from DoT is granted due to COVID-19 pandemic situation and will be revoked in due course of time.

When you talk to KPOs, BPOs and other OSPs, what is their viewpoint?
OSPs need for the hour and the future is remote working or working from home to ensure business continuity.

Today most of the enterprises enjoy the luxury of their teams working remotely, keeping this in mind, OSPs should also be allowed to use the work from home privilege.

Allowing “work from home” will not only allow business continuity but also open up employment for stay at home individuals, be it women, elderly and those with special needs.