URGENT RESPONSE SUGGESTED: Ofcom Consultation - 070 Rip-Off, including Patientline scandal

Another Ofcom consultation:

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Ofcom has today published proposals to amend its guidelines on the acceptable use of 070 numbers.  The closing date for responses to the consultation is 8 November 2005.
Personal Numbering - Proposed amendment to guidance on acceptable use of 070 numbers

http://www.ofcom.org.uk/consult/condocs/personal_numbering/
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Modified Nov 2, 2005 - contributors should consider responding to this consultation, particularly wrt the Patientline scandal and the continued abuse of 070 numbers. Note the closing date of November 8. See posts below (NGM) for further details.

~ Thread title edited by Dave ~

according to the annexe 2

We will normally allow ten weeks for responses to consultations on issues of general interest.

Hmm seems the 070 problems isnt of general interest.

Hi all.

In the Ofcom consultation on 070 numbers and "acceptable use" at http://www.ofcom.org.uk/consult/condocs/personal_numbering/pn.pdf it may be worth looking in page 12, para 9:

3  
Please bear in mind that Ofcom counts the cover as page 0 and so the pdf page numbering still does not match the printed page number. But would any of you expect anything else involving Ofcom's use of numbers?

Tks NGM

Colour (and color!) changed.

And thank you for the valuable input.

Here is my email and will I think prompt some shall we say interesting reactions.

I am still left utterly stunned that Ofcom thought they could pull off this stunt of legalising Patientline via a devious 14 page consultation where the fact that hospital 070 services are even part of the plans is only mentioned on Page 12 of 14.  Ofcom just get worse and worse in their quite deliberate deviousness and cynicism.  But who is going to be able to force them to start acting in the interests of uk citizens and consumers?

-----Original Message-----
Sent: 01 November 2005 23:58
To: vicki.nash@ofcom.org.uk
Cc:stephen.carter@ofcom.org.uk;david.currie@ofcom.org.uk
Subject: Ofcom to Allow 50p per Minute Patientline Scam to be Legalised via Rushed & Secretive 13 Day Consultation

Dear Ms Nash,

I feel I must write to you in your role as Ofcom Consultation Champion to protest in the strongest possible terms about a Consultation published by Ofcom only 6 days ago on 26th October and which closes in just another week's time.  This means that instead of lasting a standard 10 weeks for Ofcom Consultations this Consultation is being railroaded through by Ofcom in an unlucky for some 13 days.  Furthermore this is a Consultation for which there has been no press release and for which there is no Plain English Summary available on your website.  Yet this 13 day consultation is related to another variant of Non Geographic Numbers (NGNs) for which Ofcom is currently in the midst of a 10 week consultation for NGN numbers which begin 084 and 087.

What is this mysterious rushed 13 day Ofcom consultation that is so urgent? www.ofcom.org.uk/consult/condocs/personal_numbering/pn.pdf ).  Well if you read Pages 1, 2, 3, 4, 5, 6, 7, 8, 9 and 10 out of 14 pages you wouldn't think it was really about anything very interesting at all as it makes reference to some rather obscure matters known as General Conditions of Entitlement, Range Holders, Resellers and End Users.  Gosh this does seem like one of those really dull and turgid Ofcom Consultation documents that one could consign quite happily to the nearest waste paper bin.  Surely there is nothing meaty here such as for instance the proposal to keep charging 0845 callers premium non standard call prices for four more years, whilst returning 0870 numbers to being charged the same way as 01 and 02 numbers in say 18 months time, that is contained within your other much better publicised current NGN consultation document.

But wait tucked away on Page 12 of 14 is Proposed Revised Guidance Point 9 which states "Recent examples of services that may not fit the traditional mode of Personal Numbering, but which Ofcom considers to be legitimate Personal Numbering Services include":-

sub point3:- "070 numbers allocated to hospital patients so that they can have their own number for the duration of their stay (but not where a generic 070 number is used that requires further PINs)

All of a sudden one realises that a well known uk company called Patientline has been operating services of precisely the kind described in Revised Guidance Point 9 Sub Para 3, except that Patientline historically required callers to be connected to the patient at the bedside by having to call a general 070 Patientline customer service centre number to get a Pin number for the patient concerned before then ringing another automated 07 number and entering a Pin before then finally being connected to the patient's bedside.  So could all this I now begin to ask myself have anything to do with another obscure Ofcom announcement called an Update Note (and one of four or five announcements a day that Ofcom often sends me and other people on its circulation list) issued on 19th October 2005 and referring to something Ofcom called an "Own Initiative Investigation against Patientline Limited about misuse of Personal Numbers". And this announcement tells us that Ofcom has strangely enough decided to extend an original deadline for bringing in direct dial to the patient bedside (instead of via the call centre and PIN system where Patientline clocked up another minute or two at 50p per minute) from 13th December 2005 to 13th June 2006 and that is after Ofcom had already granted another 6 months extension to Patientline on this deadline way back on 13th June 2005.

I agree, NGM. I'll have a look at the consultation document.

The question is why now? And why include such examples? What are most personal numbers used for? Are a significant amount used for hospital 'services'*?

* I use this term very very loosely!

Quote:


But you have over a month yet for those consultations which need long responses.

This consultation only needs an email of about three  paras saying it is outrageous Patientline be allowed to use PNS 070 whether they have DDI dialling to the bedside or not.  Also query whether Patientline number are actually redirectable to home phones or mobile phones when you leave hospital.  If not they don't meet the requirements and should be forced to move to 09 which is for fixed line revenue sharing.

Of course it is outrageous they have cut the consultation to 13 days but it seems clear they aren't going to budge.

I suppose I should ask what the formal complaint procedure is about having a short consultation like this and then when I find out let you all know who to email.  The FSA have an excellent complaints process about their own staff and procedures but the Ofcom approach seems to be to fob off all such attempts to complain about how they operate.

Quote:

But to have DDI will set a president for other scammers, err, communication providers, to do the same sort of thing in other fields. The flood gates are gradually being opened...

What's more, the basic idea of a PN is that the end-user is in charge of where it goes. It is a service provided to end-users [which often costs the caller a fortune]. How is the 'end-user', who is stuck in a hospital bed, able decide where they want the number to be pointed?

The examples of internet chat rooms and small-ads which give you a 070 PN allow you the end user to point it at whatever you want. You don't have that "choice" when in a hospital bed.