0871 Pre-consultation

in Phones & TV
13 replies 797 views
bbb_ukbbb_uk Forumite
2.1K Posts
As posted on Sayno here, ICSTIS have now published a pre-consultation on 0871 numbers and what regulation, etc to apply to them compared with 09x numbers.

See ICSTIS' site here. The pre-consultation can be found here.
Pricing clarity at the heart of new 0871 regulation proposed by ICSTIS
The phone regulator ICSTIS has today launched a pre-consultation which sets out clearly the need for enhanced consumer understanding about the cost of calling 0871 numbers.

Following the decision by Ofcom in April 2006 for ICSTIS to regulate 0871 numbers from early 2008, ICSTIS is today launching a pre-consultation outlining the issues that will need to be addressed to ensure that consumers continue to have trust and confidence in using 0871 numbers.

ICSTIS’ pre-consultation emphasises the importance of ensuring consumers understand that 0871 numbers can cost up to 10p per minute and may cost more from some mobile phones and other networks. Paul Whiteing, Deputy Director of ICSTIS said: “Consumer trust in 0871 numbers is crucial. If you are calling a company and they may be charging you up to 10p a minute then you need to know this before you call. We will also want to be clear that any delays in handling that call are not deliberate or designed to make money out of the consumer. Our aim is to create a set of regulations that put the consumer at the heart of the regulatory requirements and to do this we will be insisting on absolute clarity and transparency when it comes to telling consumers what calls cost. This will be backed by tough enforcement powers.”

The pre-consultation document has been launched by ICSTIS today. The closing date for comments is Friday 29th September 2006. ICSTIS encourages all companies and consumer bodies with an interest to respond with their views.

NOTES
• 0871 numbers are special numbers on which telephone companies and third party service providers can share the revenue costs of the call (up to 10p per minute).
• Ofcom announced (NTS: A Way Forward – 19 April 2006) that as from early 2008, ICSTIS would take over the regulation of 0871 numbers.
• 0871 numbers are used for a variety of purposes including operating call centres, helplines and booking services.
• ICSTIS is the regulator of premium rate services. Ofcom is extending its powers to regulate 0871 numbers with effect from early 2008. ICSTIS has wide ranging powers for managing breaches of its Code of Practice. This includes fine powers of up to £250,000.
«1

Replies

  • bbb_ukbbb_uk Forumite
    2.1K Posts
    The pre-consultation questions are:-

    Q1. We would welcome feedback about the distinctive characteristics of the market for 0871 numbers, including information about the market size, the main types of use for 0871 numbers and views on how this is changing, and is likely to change, as we move towards 2008 and beyond.

    Q2. We recognise that a considerable amount of use of 0871 numbers relates to business call centres for customer service and information. Again, we would be interested to hear from those companies and other affected organisations about how the decision by Ofcom to extend regulation of PRS to 0871 may impact on their operations and how any ensuing burden should be minimised without losing sight of the need to ensure an appropriate level of consumer protection.

    Q3. We would welcome feedback about the likely consequences of the possible migration to or from 0871 numbers flowing from the changes announced by Ofcom to 0870 revenue share and as a consequence of extending PRS regulation to all 0871 numbers.

    Q4. We would welcome feedback about consumer concerns that arise, particularly with the promotion and content of 0871 services, and we would welcome feedback about safeguards that stakeholders believe would be necessary and proportionate for the development of an effective consumer protection regime for 0871 numbers.

    Q5. We would welcome thoughts on what approach we should take to formulating a Code of Practice and how far this should be separate from the current ICSTIS Code and, if so, why. Are there additional issues relating to 0871 numbers, not covered in the current Code and distinctive to 0871, that would to also be addressed?

    Q6. We would welcome feedback on how we should regulate call centre waiting time issues, recognising that being in a queue for a long time leads to consumer expense as well as generally leading to a perception of poor service. We would particularly welcome the views of trade bodies whose members are active in call centre provision about how best practice could link to our regulatory requirements once agreed.

    Q7. We would welcome views on the potential incentives that we could create in order to develop improved performance and consumer service in this area without the need immediately to resort to regulatory sanctions.

    Q8. In respect of pricing transparency, we would welcome views on how we move to a situation of compliance in time for early 2008 when we take control of the regulation of 0871 numbers. Many companies reported to Ofcom that they face long lead times to amend their promotional copy in respect of advertising for 0871 numbers. What action can we take and with whom to ensure that service providers and others in the value chain promoting these numbers fully
    understand the need for providing transparency in good time for any regulatory changes which may take place early in 2008?

    Q9. Pricing transparency for 0871 numbers will be affected by the fact that many such numbers, especially when used for customer services, are listed in white pages telephone directories where space for the listing is restricted to a company name and number. There is no provision to provide information relating to the likely cost of the call. How should we consider dealing with issues relating to pricing transparency in this context or in other contexts such as advertising such numbers or radio or television?

    Q10. Do stakeholders have any views about our preliminary conclusions on governance arrangements for regulating 0871 numbers?

    Q11. We would welcome any thoughts on how far the current funding model, which appears to have operated well for many years, could be adapted to incorporate 0871 number or whether specific alternatives should be considered. If the latter, with what justification?

    Q12. We would welcome stakeholder comments on branding issues and how far, in the context of a re-brand of the core ICSTIS business, stakeholders consider there is a need for public perception reasons, for a separate brand for 0871 numbers.

    Q13. We would welcome any comments on this proposed timetable.
  • JohalaReewiJohalaReewi Forumite
    2.6K Posts
    If this is a pre-consulation excercise, does that mean there will be a full consulation afterwards, or is this the actual consulation? :confused:
  • bbb_ukbbb_uk Forumite
    2.1K Posts
    If this is a pre-consulation excercise, does that mean there will be a full consulation afterwards
    Annoyingly, this does seem the case for some unknown reason.

    I think we need to mention in this pre-consultation (and probably again in the final consultation) that at the very least:-
    1. Call queuing is prohibited just like 09x numbers.
    2. 0871 numbers to be advertised same as 09x numbers (clear and transparent and not put 'national rate' that some companies have been putting)
    3. When call answered we are informed that the call costs 10p/min

    I'm not sure what other safeguards, etc exist for 09x numbers but without these three things then we are not protected from the abuse of these numbers.

    Companies currently using these numbers are only using them as premium rate numbers but without the safeguards, rules, guidelines that having an 09x have.

    Plain & simple, they are used to maximise their profits by ultimately bypassing ICSTIS regulation and safeguards, etc.

    The main safeguard, as mentioned above, is being prohibited from being kept in a queue and being charged for the privilege of doing so.

    At the very least when replying to this consultation, we do a paragraph or something that mentions that 0871 should have, at the very least, those three safeguards mentioned above.
  • It might also be worth mentioning that companies who offer premium rate call blocking should include 0871 in the block (at the moment they only block 09 numbers so 0871 gets through).
  • bbb_ukbbb_uk Forumite
    2.1K Posts
    The closing date for this pre-consultation is [highlight]THIS[/highlight] Friday 29 September 2006.

    That means only 5 days left.

    As mentioned in an earlier post, at the very least 0871 numbers should have:-
    • Call queuing is prohibited just like 09x numbers.
    • 0871 numbers to be advertised same as 09x numbers (clear and transparent and not put 'national rate' that some companies have been putting)
    • When call answered we are informed that the call costs 10p/min

    For more info see ICSTIS page here.
  • bbb_ukbbb_uk Forumite
    2.1K Posts
    I've only scanned the consultation but below are my draft responses:-

    - - - - - - - - - - - - - - - - - - - - - - -
    Q1. We would welcome feedback about the distinctive characteristics of the market for 0871 numbers, including information about the market size, the main types of use for 0871 numbers and views on how this is changing, and is likely to change, as we move towards 2008 and beyond.

    n/a

    Q2. We recognise that a considerable amount of use of 0871 numbers relates to business call centres for customer service and information. Again, we would be interested to hear from those companies and other affected organisations about how the decision by Ofcom to extend regulation of PRS to 0871 may impact on their operations and how any ensuing burden should be minimised without losing sight of the need to ensure an appropriate level of consumer protection.

    n/a

    Q3. We would welcome feedback about the likely consequences of the possible migration to or from 0871 numbers flowing from the changes announced by Ofcom to 0870 revenue share and as a consequence of extending PRS regulation to all 0871 numbers.

    n/a

    Q4. We would welcome feedback about consumer concerns that arise, particularly with the promotion and content of 0871 services, and we would welcome feedback about safeguards that stakeholders believe would be necessary and proportionate for the development of an effective consumer protection regime for 0871 numbers.

    The primary use of 0871 numbers is the revenue sharing and the reasons why many companies are using 0871 numbers instead of 09x PRS numbers which were specifically designated for revenue share is to avoid being regulated by yourselves and avoid the safeguards that are incorporated into 09x numbers. Therefore, a company using 0871 can earn revenue without having to clearly indicate the cost of the call and can keep us in queues longer to earn more revenue knowing that there is nothing us consumers can do.

    Q5. We would welcome thoughts on what approach we should take to formulating a Code of Practice and how far this should be separate from the current ICSTIS Code and, if so, why. Are there additional issues relating to 0871 numbers, not covered in the current Code and distinctive to 0871, that would to also be addressed?

    n/a

    Q6. We would welcome feedback on how we should regulate call centre waiting time issues, recognising that being in a queue for a long time leads to consumer expense as well as generally leading to a perception of poor service. We would particularly welcome the views of trade bodies whose members are active in call centre provision about how best practice could link to our regulatory requirements once agreed.

    As mentioned in my response to Q4, 0871 numbers are used specifically to avoid the safeguards offered to end consumers via existing 09x numbers. The main one is waiting times where it can be known to spend over 30minutes in a queue on 0871 numbers whereas on an existing 09x number us consumers wouldn't get charged until we speak to an operator therefore queuing for 30minutes is at the expense of the company concerned and not us consumers. This is why introducing a requirement to prevent us consumers being charged for the call until answered (like existing 09x numbers) is the safest and best way to ensure protection for us consumers.

    Q7. We would welcome views on the potential incentives that we could create in order to develop improved performance and consumer service in this area without the need immediately to resort to regulatory sanctions.

    n/a

    Q8. In respect of pricing transparency, we would welcome views on how we move to a situation of compliance in time for early 2008 when we take control of the regulation of 0871 numbers. Many companies reported to Ofcom that they face long lead times to amend their promotional copy in respect of advertising for 0871 numbers. What action can we take and with whom to ensure that service providers and others in the value chain promoting these numbers fully understand the need for providing transparency in good time for any regulatory changes which may take place early in 2008?

    0871 numbers should be advertised in similar formats as existing 09x numbers - along the lines, "Calls cost 10p/min from BT landline. Calls from other networks and mobiles may vary."

    This is specifically important because 0871 (like 0870) are known to many consumers as 'national rate' and even some TV adverts recently advertised an 0871 number as a 'national rate'. This is obviously misleading but the problem gets worse because mobile network that currently charge upto 40p/min for these calls all because in most cases the consumer would not be aware of the cost of this number and assume its just 'national rate' so therefore around the same price as a geographical call.

    The obvious difference between 0871 and 09x numbers when it comes to making calls from mobiles is that most (if not all) consumers are aware that premium rate numbers begin with 09x and will cost more from a mobile. This is not true for 0871 where many consumers would think that it costs the same as a national rate call.

    Due to this, I believe it may be necessary (and it would improve price transparency) to have the operator when they answer the call state something along the lines of, "This call costs 10p/min from a BT landline. Calls from mobiles cost more."

    Q9. Pricing transparency for 0871 numbers will be affected by the fact that many such numbers, especially when used for customer services, are listed in white pages telephone directories where space for the listing is restricted to a company name and number. There is no provision to provide information relating to the likely cost of the call. How should we consider dealing with issues relating to pricing transparency in this context or in other contexts such as advertising such numbers or radio or television?

    What difference is there between following the same guidelines/regulations for price transparancy on 0871 numbers like there is on 09x numbers? For example, if a company using a premium rate number advertises in the yellow pages then they would have to state the cost of the call. Similar thing for radio, where quizes/phone-ins, etc that use 09x numbers all state the cost of the call from a BT landline. So therefore it is possible for companies to do the same and follow the code of practice on call transparency for their 0871 like they would have to for 09x numbers.

    I can't see the logic behind saying that just because a company chooses to use a revenue generating 0871 doesn't have to mention the cost of the call but they do if they were to choose an 09x number. What's the difference apart from the cost of the call?

    Q10. Do stakeholders have any views about our preliminary conclusions on governance arrangements for regulating 0871 numbers?

    n/a

    Q11. We would welcome any thoughts on how far the current funding model, which appears to have operated well for many years, could be adapted to incorporate 0871 number or whether specific alternatives should be considered. If the latter, with what justification?

    Maybe an annual or quarterly fee should be charged instead of the current method of taking a cut of the call per minute.

    Q12. We would welcome stakeholder comments on branding issues and how far, in the context of a re-brand of the core ICSTIS business, stakeholders consider there is a need for public perception reasons, for a separate brand for 0871 numbers.

    n/a

    Q13. We would welcome any comments on this proposed timetable.

    n/a

    IN SUMMARY

    You already state in your pre-consultation that you received over 23,000 number checks on 0871 alone in the period of Oct '05 to May '06 (8 months) and over 800 phone calls. Therefore you should already be aware of lack of consumer awareness of these numbers and the detriment they are causing by basically being a premium rate number without ANY safeguards whatsoever.

    Personally, given a choice of ringing a company on a premium rate 09x number costing 10p/min and ringing them on a 0871 number costing the same then I'd ring the 09x number. Simply because I know that I wouldn't be charged for being kept in their queue thus saving me what initially can be fortune.

    I believe in most cases the amount of time spent on the telephone to companies using 0871 (and 0870) is being held in a queue. In my experience most phone calls, once answered, are over in a few minutes. Emailing companies these days either results in no reply whatsoever or them not reading my emails correctly and replying back with something that isn't related to or answer what my original query was. This just isn't true for me and many people I know agree.

    At the very least 0871 numbers should have:-
    • Call queuing is prohibited just like 09x numbers.
    • 0871 numbers to be advertised same as 09x numbers (clear and transparent and not put 'national rate' that some companies have been putting)
    • When call answered we are informed that the call costs 10p/min

    Anything less then they will be no different than how they work now where companies call queuing is allowed and the cost of the call isn't published (in most cases).
    - - - - - - - - - - - - - - - - - - - - - - -
  • derrickderrick Forumite
    7.4K Posts
    Part of the Furniture 1,000 Posts Name Dropper
    ✭✭✭✭
    Correct me if I am wrong, but I thought that the 0871 numbers where to come under ICSTIS regulation, which would automatically address your 3 main points?
    Don`t steal - the Government doesn`t like the competition


  • bbb_ukbbb_uk Forumite
    2.1K Posts
    derrick wrote:
    Correct me if I am wrong, but I thought that the 0871 numbers where to come under ICSTIS regulation, which would automatically address your 3 main points?
    No not really because 0871 will be subject to lighter regulation than current 09x numbers. How light is the question but the consultation seems to favour companies and how it is going to cost them and affect them rather than consumer detriment.
  • bbb_ukbbb_uk Forumite
    2.1K Posts
    Ok, I've read more of the pre-consultation now and something I noticed is a worrying:-
    Paragraphs 4.167 to 4.185 of the NTS Statement outline Ofcom’s responses to consultees’ comments about extending PRS regulation to 0871 numbers. Arising from these responses were issues relating to the suitability of the current Code of Practice for the regulation of the types of services being provided on 0871 numbers. This was particularly with regard to issues about the suitability of the Code to cover customer service functions which operate on 0871 numbers. Related to this was a concern from some respondents about disproportionate regulation of call centre waiting times should the “undue delay” provisions in the current ICSTIS Code of Practice be adopted in a rigid way with no proper regard to call queuing issues that arise in call centre environments. [highlight]We, like Ofcom[/highlight], observe that any provisions by us in this area will be the subject of consultation and a [highlight]balance[/highlight] may need to be struck between ensuring consumers do not suffer unreasonable financial detriment resulting from call queuing with the need to provide a call centre operation where it needs to be recognised that consumer calling patterns are not always even and accurately predicted.

    Separately we need to address the issue of how far services which contain a live voice element, which may be the great majority, would require separate permission from ICSTIS to operate, as we currently require for live voice services in the 09 area today as well as a requirement, linked to this, to give pricing information on connection to consumers. Our initial thoughts are that prior permission for all services should be targeted on those services which are considered to have the characteristics which could generate consumer harm or vulnerability. In this context our initial thinking is that most 0871 live services will not fall within that category unless they are providing some form of entertainment or service which may make users particularly vulnerable or place them at risk, such as live chat services or counselling/ medical advice lines.
    This reads to me like ICSTIS don't really want to prohibit call queuing at the expense of us consumers because of the cost involved to companies that want to use revenue-generating 0871 numbers.

    This as well:
    Our initial thoughts are that prior permission for all services should be targeted on those services which are considered to have the characteristics which could generate consumer harm or vulnerability. In this context our initial thinking is that most 0871 live services will not fall within that category unless they are providing some form of entertainment or service which may make users particularly vulnerable or place them at risk, such as live chat services or counselling/ medical advice lines.
    ICSTIS are basically saying here that the most consumer detriment will be 0871 numbers used by live chat service (I assume adult stuff) or counselling/medical advice lines.

    This, I believe, is wrong because these services are very few and far between especially operating on 0871 numbers. Ofcom announced that 'adult' services have to use 09x numbers which means that maybe adult customer services call centres may still use 0871 so therefore 0871 isn't being used for any 'adult' chat services like ICSTIS would have us believe but they may use 0871 for customer services enquiries (where appropriate) which this would fall under call centre usage of 0871 numbers like the vast majority of 0871 numbers.

    It sounds to me like ICSTIS want to try and say that the worse use of these numbers is chat services, etc and not general customer service call centres so they will apply stricter regulation on these, practically non-existent usage, rather than the main use of this number range which is obviously call centre related.

    Basically, those using 0871 for live chat services (????) will be subject to tighter regulation like possible call queuing but general usage of 0871 for call centres like customer services, technical support, etc isn't considered detrimental so call centres wont be subject to these tighter regulations that exist for all 09x numbers like prohibiting call queuing at the expense of us consumers.
  • bbb_ukbbb_uk Forumite
    2.1K Posts
    I suggest those that want to ensure that being charged for call queuing is prohibited on 0871 reply to this consultation and let ICSTIS know.

    I'd just remind ICSTIS that despite what ICSTIS say, call queuing can be a big problem as mentioned in the press like here and from it I quote:-
    Then I went back to the website and found, in the small print, a number that was only 10p a minute. I rang this eight times and was always held in a queue. The longest I waited was about 20 minutes
    and
    Mariane Cavalli, who lives in London, contacted us after trying to get proof from the airline that she cancelled a flight. She wasn't even seeking a refund, just a letter of confirmation, but she, too, ran into a wall of silence - and hours waiting on an expensive 0871 phone line
This discussion has been closed.
Latest MSE News and Guides

Bacon flavoured toothpaste

Can you help this Forumite track some down?

Join the Forum discussion

£10 Christmas bonus

For benefits recipients

MSE News