How to respond to the Ofcom consultation
Included in the consultation is a draft revised policy, which would replace the current one. It is, hovwever, important to also look at the other documents, including the annexes.
This is because one major change with this revision is that Ofcom has spent a lot of time and effort trying to obtain information about the overall calling environment and the commercial and consumer effects of any changes. These have come from the 2014 call for inputs, and the subsequent surveys along with economic calculations.
As a result Ofcom are quoting specific facts and figures rather than just pulling numbers out of the air. Any responses to the consultation will need to address the underlying evidence as well as the policies themselves.
A quick summary of changes that I think will be of interest:
– There are more explicit statements of what constitutes misuse although, as before, the door is left open for things that aren’t specifically mentioned to be defined as misuse if necessary
– One specific statement is “Calling parties should not make silent of abandoned calls”
– Things that may be considered misuse:
– For IVM:
——- Long waits while being passed to an agent
——- Not providing information on who is calling while the person is waiting for an agent
– Rotating CLIs
– It is explicitly stated that 3 silent or abandoned calls may be considered to be misuse
– When considering what action to take the Abandoned Call Rate (ACR) on non-infringing days will be taken into account
– Currently only days over 3% are considered. The implication is that in future all abandoned calls will be taken into account. I take this to mean that if you’re caught over 3% then if you’ve been running at 2.95% most of the time you’re likely to incur a larger fine than if you’d been running at 1%
– Management practices and processes will be taken into account
– Has testing been done?
– Are staff competent?
– Are you actively monitoring third parties that call on your behalf?
Overall the aim appears to be to push down the number of silent and abandoned calls while making it easier for Ofcom to take action.
I would encourage everyone to read and respond. As I said at last year’s user group meeting these reviews don’t happen very often and the only way the industry has a voice is to make their feeling known during the consultation period. I am sure consumers and consumer groups will be responding, without industry input there will be no balance.
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