CAMIX is the official authorized operator of Yaounde and Douala IXP by MINPOSTEL Decision No 386/MPT/CAB 26 OCT 2020
Management and operation of Cameroon’s IXPs is not exclusive to CAMIX. MINPOSTEL is reserving the right to authorize another organization to manage and operate future IXPs.
Integration of other stakeholders like academia, research institutions and think tanks into CAMIX board will improve consumer-centricity, neutrality and innovation.
There are insufficient data protection and privacy provisions as regards to the processing and collection of personal identifiable information and users telecommunications by CAMIX.
Strategic importance of IXP
Internet eXchange points (IXP) are physical locations through which Internet infrastructure companies such as Internet Service Providers (ISPs) connect to shorten their paths to each other’s networks, thereby improving performance by reducing latency and providing a faster round-trip time. By optimizing path for local (Inside of Cameroon) internet traffic and by choosing the best path to route outbound (outside of Cameroon ), a well operated IXP provides optimized Internet performance (speed) to customers and passive revenue (cost savings) to ISP operators.
Beside the improved Internet speed to end users and the passive revenue generation to ISPs, an IXP is also of national security importance. They process and sometimes collect customers telecommunication and personal identifiable information since all Internet traffic in that city or region transits through the IXP.
CAMIX, a consumer advocate but a business mindset
CAMIX is a non-profit association created in January 2014 at MINPOSTEL with the intent of administrating the IXPs of Yaounde and Douala. According to CAMIX website (as of November 8th 2020), CAMIX board consists of RINGO, MTN, MATRIX, CREOLINK, INFOGENIE and Internet Society (ISOC) Cameroon. You would notice that the board consist of 5 ISPs and only one Consumer advocate and civil society organisation.
Consumer-centricity is not obvious from CAMIX own mission which is to “provide Internet Service Providers with a physical infrastructure enabling data exchanges and transfers to be carried out securely nationally and internationally”. Though it could be implied that reduced latency and faster routing will implicitly benefit consumers, it is not clear that the notion of neutrality will pertain, especially when decisions could be influenced by passive revenue gains (cost savings) for ISPs. Given the current structure of CAMIX board, the balance of power ( ISP financial interest dominating CAMIX board) is unlikely to guarantee consumers’ interest and protect consumer data.
Though, CAMIX statute opens membership to “all entities having an interest in Information and Communication Technologies communication (ICT), Internet development issues”, increasing awareness on the strategic importance of IXPs for Cameroon and its implications to consumers and inviting other stakeholders like research institutions, academia and civil society organisations into CAMIX membership and board could provide better consumer-centricity for CAMIX, improve technical innovation and efficiency.
The October 26 2020 decision No. 386/MPT/CAB/26 OCT 2020 authorizes CAMIX “to manage and operate the Yaounde and Douala Internet Exchange Points”. In simple terms, this means that if there were new IXPs to be deployed by the government of Cameroon in other cities, CAMIX will not be necessarily be the automatic manager and operator of those. A different organization maybe be selected to manage the new IXPs.This is an important consideration by the government because it encourages competition.
While CAMIX is an association of Internet Service Providers in Cameroon, it operates the IXP using an independent model, where members have to pay a fee to be part of the IXP and all operational expenses are met by the IXP. According to the Internet Society and the International Telecommunication Union Development sector (ITU-D), the pros of such a model are neutrality, sustained revenue and ease of scale and growth. However, the cons of such a model are medium to high cost of peering. It is therefore possible to see other business models of IXP operation in the future that might have cheaper peering fees. Other IXP business models include a free IXP where location and operation costs are donated by a sponsor; a subsidized business model where certain aspects and operational costs of the IXP are sponsored for a sustained period of time; and a collaborative committee model where community, business, government and technical experts provide oversight. Each of these has its pros and cons. It is worth also noting that it seems CAMIX used a subsidized business model before this decision of authority granted to CAMIX by MINPOSTEL, since the cost of most of the equipment and infrastructure were owned by the state as noted in chapter 1, Article 6 of the decision.
Besides the operating model, competition in any market drives down cost, so having multiple players operating IXPs in the country is a good thing for broadband price and is in fact one of the most important factors impacting Internet affordability in Africa, according to research carried out by Alliance for Affordable Internet (A4AI). And this decision is rightly mindful of that.
Peering Request Refusal Appeal Process
The CAMIX statute drawn on December 06, 2016 does not address the issue of interconnection requests explicitly. Chapter 3, Article 7 addresses the issue of membership to the CAMIX association and the power to admit a new member is entrusted to the executive committee of CAMIX, who also happens to be the body to manage and determine all disputes of CAMIX. Assuming a request for membership also means a request to interconnect to the IXP, it means if such a request were to be refused, the requestor has nowhere which is independent of the decision making to appeal the request denial.
While this MINPOSTEL decision No. 386/MPT/CAB/26 OCT 2020 includes a provision to overturn any decision to refuse requests to connect to the IXP by CAMIX if deemed unsatisfactory by the National Agency for Information and Communications Technology (ANTIC) or the Telecommunications Regulatory Board (ART) in Chapter 2, Article 8 (5), it unfortunately fails to provide provisions for appealing a refused peering request to either ANTIC or ART.
Hopefully, CAMIX membership considers reviewing its statute to address disputes related to peering requests.
Security and Privacy Concerns
Chapter 4, Article 18 (2) & (3) raises very concerning questions with regards to mass surveillance and privacy violations without any legal or executive oversight. Article 18 (2) reads: The Telecommunications regulatory Board and the National Agency for Information and Communication Technologies have free access to the facilities of the Internet Exchange Points and may collect data deemed necessary. And Article 18 (3) reads: The National Agency for Information and Communication Technologies reserves the right to deploy within the Internet Exchange Points any technical device it deems necessary for security reasons.
While Cameroon doesn’t currently have any data privacy and protection law, one would expect that this policy document would be mindful of the constitution, especially the preamble that states that “the privacy of all correspondence is inviolate. No interference may be allowed except by virtue of decisions emanating from the Judicial Power” and Law n° 98/014 of July 14, 1998 governing telecommunications. It therefore should have provided adequate judicial oversight similar to that contemplated in those two legal documents.
Internet users in Cameroon need confidence that proportionality, judicial oversight and due process would be adhered to in the event that access to data at the IXP is made by ANTIC due to a genuine security reason. Omitting judicial oversight in the access of data at the IXP doesn’t build this confidence. It does the opposite of promoting Internet use for development as it erodes trust of the Internet in general. Yet, trust is the lifeblood of the Internet and central to e-commerce. And we know that all too well in Africa, because the fear of fraud is one of the major factors holding back uptake of e-commerce on the continent.
Rather than contribute to the erosion of trust and confidence of the Internet, the government of Cameroon should be intentional about its efforts to encourage and promote the use of ICTs and the Internet. Such an effort would align with its ambitions and progress towards digital transformation and efforts to lead the Central African sub-region’s telecommunications industry. An ambition which has been asserted by many government officials.
The vision to lead the Central African sub-region’s telecommunications industry and to be an ICT hub in the sub-region seems a bit far reach still. And though Cameroon lost one such opportunity to lead in ICT in the sub-region to Gabon’s Internet Xchange (Gab-IX) in 2015, to be the African Union appointed Internet Exchange Point of the central African sub-region (Cameroon had no IXP at the time), the recent decision to grant CAMIX the authority to manage and operate only the Douala and Yaounde IXPs is a step in the right direction. That direction being a broadband policy and ICT policy in general of Cameroon that takes into consideration factors like competition which affect broadband pricing.
However, the decision and document unfortunately misses the mark with regards to information on how peering requests refusal can be appealed. It also makes a significant omission with regards to data security and privacy concerns at the IXP that could jeopardise the users’ trust of the internet in Cameroon. We hope the government takes these into consideration in the near future.
Finally, we hope that in addition to inviting content providers like Netflix and Cloudflare to peer at the IXP, CAMIX should consider deploying an instance of a DNS root server at the IXP. This is so that Internet in Cameroon can be even more resilient and deliver faster response times during DNS queries.