01-06-2016 09:17 AM - edited 03-17-2019 05:25 AM
Hello, I am planning to install my Cisco CUCM and CUC cluster in Singapore. I will setup a site in India (with PRI for PSTN access and WAN for VoIP), and I will configure Logical Partitioning and Geolocation Policies to comply with the regulation in India (no TEHO allowed or Toll bypass allowed). My question is: Will I have to restrict or not local PSTN calls not answered or busy on an India phone to voicemail if Cisco Unity Connection is hosted in Singapore? (across the WAN)
I wish to have the feedback of the guys who have a similar setup in place, thanks...
01-06-2016 10:16 AM
My understanding is No, as voicemail is your system. The main thing with india telco laws is to prohibit calls from reaching external destinations via VoiP where local PSTN connectivity should can be used (basically let the telco companies collect the revenue). Voicemail solution is internal hence does not need to be prevented.
01-06-2016 01:49 PM
Thank you for your response, it is useful. I gave 5 stars to both of you. The regulation cannot be as explicit, I guess.
01-06-2016 10:40 AM
Simply NO. PSTN to VoIP call over WAN should never be connected in any case. Voicemail must reside within local site only.
-Vivek
01-06-2016 12:15 PM
Vivek, can you point to documentation/law where it's stated that voicemail system needs to be local to India? I have seen many implementation supporting voice in India with voicemail/cluster in another country, and would like to confirm that this is illegal for future references.
01-06-2016 09:07 PM
Hi Chris,
There is no specific guideline with respect to this case explicitly in my information except mentioned by Martin as below;
Regulations of the Telecom Regulatory Authority of India (TRAI) require that voice traffic over the enterprise data network and the Public Switched Telephone Network (PSTN) must be strictly separated and no mixing of calls between the two networks can occur for the purpose of toll bypass.
Here, 'For the purpose of toll bypass' is a big statement. Laws and regulations can never consider use cases in mind, they are made for specific purpose. Here, one purpose is clearly mentioned in guidelines viz 'Toll Bypass', there is one more purpose which is not mentioned anywhere and that is 'Security'. Let's leave security aside for a time being.
Each and every person can have different opinion when seeing and defining the definition of 'Toll Bypass'.
I won't completely disagree with you when you consider voicemail server as internal and hence can be located anywhere. But if I was in place of regulating officer, this is a serious toll bypass for me as in this case we are taking VoIP call from India to another country without paying any toll to local operator, no matter call is being connected to machine or human. No matter where the location of voicemail server is, it could be in Singapore or USA, local operator would expect this call to take through PSTN from India and then connect to voicemail irrespective of the location of voicemail server then.
When dealing with regulations, it's always good to either get confirmation from respective authority in case of any doubt or play safe game.
https://supportforums.cisco.com/blog/12539601/trai-india-regulations-voipip-telephony
- Vivek
01-06-2016 01:41 PM
I would need a Unity Connection cluster in each India location if I wanted to prevent connecting a PSTN call to connect to the WAN, to be answered by a Call Handler, or a voice mail box?
Here is what I found:
Regulations of the Telecom Regulatory Authority of India (TRAI) require that voice traffic over the enterprise data network and the Public Switched Telephone Network (PSTN) must be strictly separated and no mixing of calls between the two networks can occur for the purpose of toll bypass.
"For the purpose of toll bypass" I don't think handling the call from a internal service is explicitly doing toll bypass, if the calls go back to the same location in the end and is controlled to do that. Or if the call is answered by a answering service, once again hosted on my corporate network. Thanks for any additional input. All the answers and opinions on the understanding of the regulation is useful.
01-06-2016 01:55 PM
Exactly, there is no toll bypass with voicemail. So, the way I read it and always understood it voicemail system can be anywhere.
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