Non-Geographic Numbers Legislation Guide

Transcription

1 Non-Geographic Numbers Legislation Guide

2 What is the new legislation? Called the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 03 : this sets out the information which a trader must provide to a consumer before and after making a sale. Specifically for companies providing telephone helplines, this governs the type of numbers which can be used for post contract queries and the cost to call them. New regulation will come into force in the UK on the 3th June 04 that enshrines the principles of the EU Consumer Rights Directive. It is being introduced in all EU member states. In the UK this will supersede the existing Distance Selling Regulations 000 and the Off-premises (doorstep regulations) 008 which will be revoked from that date.

3 Who is affected? If you are a trader selling goods and services or digital content to a consumer - these regulations will apply to you. There are however some exemptions generally where existing sector specific regulations are in force which would overlap. Contracts exempt from the provisions Gambling as covered by the Gambling Act 005 Construction & Sale of immovable property Residential letting contracts Package travel contracts Timeshare contracts Vending machines and other goods intended for current consumptions Single telecom connections for use by telephone, fax or internet Financial services are generally exempt although warranties, credit agreements and insurance products which are offered in conjunction with the sale of non- financial goods will still need to meet the regulations. Note: The Government has asked the Financial Services Conduct Authority to consider equivalent regulation Contracts only partly covered by regulation (Telephone helplines may still be affected in some sectors) Passenger transport is exempt from cancellation rights and most of the information requirements. Low value off-premise contracts < 4 Items dispensed on prescription How will I be affected? If you are not in one of the sectors which are exempt, then from 3th June 04: All telephone numbers which you provide for Post Contract queries (customer services, payments etc.) must cost no more than Basic Rate Basic Rate means not more than a geographic or mobile rate The following number types would comply: - Geographic numbers starting 0, 0 or 03 - Mobile numbers starting 07XX - Free to call numbers such as 0800 or 0808 Note: 0800/0808 is not generally free to caller from a mobile but this will change in mid-05 when OFCOM introduces changes to mobile charges. Sole use of Premium rate (09xx) and other revenue sharing ranges (e.g. 0844, 087) for post contract lines will no longer be legal 0870 may be acceptable but is often charged at more than geographic rates and will become a revenue sharing range in 05 so best avoided. Reduction (or complete loss) in revenue share when using 0844/087 - call & Service charges for using 0, 0 or 03 What options do I have? It is not a regulation requirement to provide a Telephone helpline at all so for some organisations it may be appropriate to consider moving all post sales calls to on-line only. However for the rest here are some of the possible options: Issue new Basic rate numbers for use on Post-Contract calls. These could be 0, 0 or 03 but must be advertised as prominently as the normal ones. For many consumers these numbers are included call bundles and mobile packages so may in effect be free. Companies using numbers starting 08XXX, can apply for an equivalent 03XXX number from their service provider. There s no need to remember new numbers just substitute the 8 for a Numbers are widely used by charities/public bodies. 03 is used by the BBC for all listener/viewer contact and is increasingly being adopted by government and pseudo government organisations e.g. DVLA, Blood transfusion etc. New Basic Rate numbers can be run in parallel with existing 08XXX ones. Where calls are answered using Automated Attendant or IVR type systems, messages can be played to the caller telling them of the alternative number to ring for postcontract queries.

4 The 6 point action plan Clearly what action your company will need to take will depend on a number of factors e.g. the type of business you are, what number(s) you use etc. However here is a simple checklist of things all businesses need to consider in order to start planning for the changes. Confirm if your business is in scope Refer to the useful links section for further information. As with any new regulation there are grey areas so some companies may not be clear as to whether the regulation applies or not. Unfortunately such cases will probably need to be tested in a court of law in order to resolve this. Our recommendation is to assume you are in scope and plan for it accordingly. Reviewyour current inbound numbers Confirm what numbers are in use, who supplied them and any network services which they may be attached to. 3 Review your options 4 Speak to your service provider about obtaining new numbers and what solutions and assistance they can offer. If you think you need to change numbers can they provide a changed number announcement, are there any limitations on which numbers can be used with specific services etc. When looking at solutions, possible options may include: Running new basic numbers in parallel with existing ones (but you will need to tell customers who ring the old number that there is a cheaper number available) Timelines and processes for changing numbers Changing numbers can take time and new numbers have to published and communicated in plenty of time ahead of the changes required for 3th June 04. Clearly where numbers are advertised online these can probably be changed with relative ease but others will need to be planned. For example, having agreed what numbers to use, you will need to confirm if any changes are required which affect: Operational systems If there are network services (e.g. auto-attendant, IVR s) - are these being paid from revenue share? Confirming what numbers are used is often more complex than you would think, especially when more than one service provider is involved. Separate post sales calls and allocate and advertise new numbers Using 03 numbers may ease the changes as there may only be a single digit change e.g becomes etc. Consider using network services to separate traffic where messages can be applied at network level about any new numbers (however you can t change the rates for a call once it is in progress so customer would need to re-dial). Choosing 0800 numbers for post contract calls may result in mobile customers being charged and then demanding a refund of the additional costs. This will change next year when OFCOM change the mobile rates for 0800 and calls to such numbers from mobiles become free to caller. Business processes Network services Stationary/Printed Materials Advertising Shop and van signage Changes to operational and network services ( including testing, reconfiguration and training of new processes) do not normally happen overnight and may need to be carefully managed. Changing details on stationary/brochures including van signage can take a long time and might have to be staggered over a significant period.

5 The 6 point action plan Clearly what action your company will need to take will depend on a number of factors e.g. the type of business you are, what number(s) you use etc. However here is a simple checklist of things all businesses need to consider in order to start planning for the changes. 5 Financial impact of changing numbers 6 Changing numbers can impact many different aspects of a company s business including the financial cost so it s important to have a clear view of the options available. For example: a. Do you receive revenue share from any numbers? If so how much traffic (calls etc.) would potentially need to move to meet the new regulation and therefore what will be the financial impact to your business. b. Will you be able to continue providing the same service (and same service levels) without that revenue? For some companies, the call centre staff that answers the calls may be directly funded from revenue share. Many customers may find they are moving from having a net positive cost to a charge. This may be an opportunity to review your inbound contact approach. Keeping customers informed You need to give customers as much notice as possible of any changes in telephone numbers and support them with additional guidance on the cost to call (typically from a BT line). All available mechanisms should be used to ensure the message is heard. Where practical, this should include putting notices on footers, web site Contact us sections and even audio messages on on-hold and queuing systems. Don t forget to update directories (BT Directory/Yellow Pages etc. ) and trade and consumer listing services. c. There s no obligation in the regulation to subsidize services, so for some companies the only option may be to reduce customer service levels (number of staff to handle queries, hours of operation etc.). Clearly this would be an undesirable consequence of the regulation which is designed to improve customer confidence but one which will need careful consideration

6 Number change check list Number change checklist Changing your number may have a bigger impact than you think. Here s a brief checklist of areas you may need to review when updating your post contract numbers. Area/Function Requires change Level of difficulty (-3), Yes/No 3 being hardest External Signage Directories e.g. yell Comparisons sites Companies house Footers/ signatures Your website Vehicle liveries Business cards Advertising including digital activity IVR Systems (either internal or external) Call Recording (new numbers) Agent Scripting Network Services Voic s Call handling Systems (PBX/ACD) Customer communications Brochures Letterheads and compliment slips Merchandise and display stands Product Packaging and instructions Bills Fax Lines & Fax Headers 3 3 3

7 Useful links Department for Business, Innovation & Skills UK consumer contract regulation Guidance on the regulations