ICSTIS, the incompetent and impotent PRS regulator, has today launced a pre-consultation (!!!) relating to 0871 regulation:

Press release: http://www.icstis.org/pdfs_news/0871.pdf

<<
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.
>>

Pre-consultation paper:

http://www.icstis.org/pdfs_consult/0871preconsultation.pdf

including the questions:

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.

Thanks for this idb.

Although this is just a pre-consultation I'll think we still need to respond otherwise the final consultation may not even include anything that protects us consumers from misuse like prohibiting call queuing like 09x numbers.

I have also made this a sticky for the time being.

I just sent this off to ICTIS but not holding out for a positive reply but thought it a good idea at the time!

Why not implement a "cost warning" based on the French system of a range different coloured cartouche (s?)

FYI,  I believe the French have Numero Vert for Freephone or Toll Free and Numero Azur for the next range of numbers with possibly Numero Mauve for their 0871 equivalent.

Each cartouche has the minimum cost of the call beneath it whether it by the minute or total cost.

An easy and workable solution that the public would immediately recognise perghaps?

I tried to copy and paste an example imge here but no success, can someone help please?

Oh dear no, let's not suggest copying the French system. Numeros verts are free (but not from mobiles) however the rest are effectively premium as many people have "illimité" calls to landlines so pay no attention to "numero azur" local call costs etc as it's the same old garbage as UK's 0845. The whole thing does seem to be brainwashing since people do seem to use those numbers.

The way forward is to follow the US's lead of 800/888/877 etc. Europe does not bode well: NL is bad, Germany is getting bad and the EU is in the lead for an international premium rate country code (efforts to smack roaming charges miss the point of breaking vertical monopolies IMHO).

The "incompetent and impotent PRS regulator" has even managed to give a list of "questions" where most of them are not actually questions at all (even if I'm being a bit pedantic)!

Anyway,  I don't know how to phrase it in terms of answers to those questions, but what should happen is that 0871 should be treated the same as any other premium rate number.

In particular, queueing should not be permitted at all. If companies want to run a helpline and need queueing for genuine reasons, they should use a different type of number. I don't see how anyone can justify charging customers while they are waiting for a service. For example, a solicitor might charge by the hour, and charge a small fortune. Yet you don't pay for the time you're sitting waiting outside his office while he's in with another client. Plumbers also charge a handsome rate, yet even they don't charge you for the whole morning you stayed at home waiting...

What is the point of even thinking about joining in the 'game' of 'consultation'?
We saw what happened to the efforts of all of us who replied to the Ofom 'consultation' - we were simply used as fodder - they only accept the HMV solutions (His Master's Voice, ie telecom companies) and then generalise to say things like 'the majority of respondants want....' and fill in their own answers!
Waste of time and effort, I'm afraid - and our MPs are not really interested - so where do we go??  (put your answers in a bottle and throw into the sea!!).

firestop wrote on Aug 2^nd, 2006 at 5:41am:

What is the point of even thinking about joining in the 'game' of 'consultation'?

I agree where you're coming from but at the same time 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 bypass ICSTIS regulation.

I intend to send in the following:


Re 0871  -  A wolf in sheep's clothing.

Ofcom and Ictis appear not to be able to make clear and effective regulations. Most understand that “09" telephone numbers are expensive premium rate numbers and use them, if at all, with care.  It is reasonablely well known that they are expensive.

But 0871 are different; many do not realise that 0871 cost 10ppm at all times.  Recently I challenged two organisations who use an 0871 for routine communications.  One a retail shop the other a motor insurance broker.  One said 0871 was a free-phone number, the other said it was a national rate call.

Because 0871 is a clandestine premium number, 0871 should be subject to even tighter regulation than a “09"  number, whose character are more readily known.

Full transparence should be the aim. What valid objection could an honest organisation have to making a caller 100% aware of the nature and cost of calling an 0871 number. The following, should be the minimum requirement:

All 0871 numbers should have a short pre recorded message as to the cost per minute and the caller should be able to hang-up without incurring any cost.

The pre recorded message should also advise the caller that part of the cost of the call is received by the organisation receiving the call.

All 0871 numbers should be capable of being blocked by the subscriber.

Charging for queuing should be prohibited..

Even small advertisements,  listings or printed matter, should have “10p a minute” after the number and in the same type size as the number.

A wolf in sheep's clothing is more dangerous than a wolf.

Further to my above post:  0871 - A wolf in sheep’s clothing.  

I have an old edition of BT’s  “The Phone Book Companion 2002".  Section 3:2 is a “Special codes decoder”

The description for 0871 is:  “0871 for internet services”.  

This specialised number for internet services has been hijacked for voice communication.  Why should Ictis be reluctant to upset the users of 0871, when it is clear that they had no business using that number for voice communication in the first place.

Modified 4 Aug:

I have just noticed the following under special rate numbers:  "There may be a charge for calls beginning with 0844 and 0871"
It is clear that this type of number was not initially envisaged a premium cost number.

The closing date for this pre-consultation is THIS 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.

I've only scanned the pre-consultation so far but here 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."

Continued...

... Continued

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 there 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).

---

Hi bbb

Read you comments and would go along with - as that is what the Law requires.  My concern is that 0871 is in the same steps as 0845 and 0870. OFCOM who has done nothing with 0845/0870 also tells  ICSTICS what role to play.

1. Cost of any call costing more than a normal call is termed as a Perium rate number, thus the Cost of that call should be clearly disclosed before hand. The should be free Business to Consumer annoucement to the cost of the call - which OFCOM has failed on.

2. Failure to disclose or mislead the consumer that it is a cost of normal call should cost a fine and stop the use of the number. It is also against Eu Legislation.

3. It is distrubing that all adverts advertisnig 0871 or 0845 or 0870 are saying to businesses use these numbers as "you can generate income from incoming calls".  It is my view that this is Unfair Consumer Practice

4. No real reason can be give for having 0871 number as with 0845 or 0870, as the same operation can be carried out by normal numbers, eg, diverting, etc - there is 3 clear facts -
(a)  that the only reason that there is the 0871 is to generate money from consumers to profit from, for the business  and      
(b) That if a message was given of the land line - be it in India or the UK it would be still cheaper for the consumer to call directly, then to be diverted by a 0871 or 0845/0870 number.
(c) Tiny Computers showed the abuse by the Businesses in keeping customers hanging on these numbers for an hour at a time 60 min x 10p = £6.00 per hour - at the consumers expense.

I spoke to my MEP today to pursue this matter to the EU Commissioner to investigate the failure to have transparent price information -eg free Business to Consumer price announcement and even to state the price of the call and the Anti Consumer/Unfair Consumer Practice the the only reason to have these number is to generate money from consumers. I  trust yourselves will do the same

Bobby

Ok, I've read more of the pre-consultation now and something I noticed is a worrying:-


Quote:

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.  We, like Ofcom, observe that any provisions by us in this area will be the subject of consultation and a balance 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:

Quote:

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.

I suggest those that want to ensure that being charged for call queuing is prohibited reply to this consultation and let them know.

I'd just remind ICSTIS that despite what they say call queuing can be a big problem as mentioned in the press like here and from it I quote:-

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

Quote:

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

The deadline for this consultation is tomorrow (Friday) and hopefully if enough people respond to this consultation it will convince ICSTIS to ensure call queuing on 0871 numbers is prohibited and costs are always displayed when anyone publishes an 0871 number - just like 09x numbers now.

Their consultation looks like they only want to apply very "light" regulation as customer detriment, according to them, is low and is likely to be low except where the number is used for chat lines and not general call centres like customer services, tech support, etc.

The deadline for this consultation is TODAY.

bbb_uk, thanks for the reminder. I haven't read the document, but I intend to send a short response. Thanks for posting the questions and your draft responses. Have you thought of anything further that you have added?

Dave wrote on Sep 29^th, 2006 at 7:50am:

Have you thought of anything further that you have added?

Just highlighting that despite what they may think there is likely to be customer detriment even more in the future when revenue sharing on 0870 stops as companies are likely to migrate to the next highest revenue earner for them which is 0871.

I plan on reminding them (mentioned in my summary) that they've had thousands of enquiries about 0871 so that to me proves there is consumer detriment now which is likely to get worse once revenue sharing from 0870 is removed.

I'm also going to remind them that consumer detriment is more likely on call centre usage of 0871 (cust serv, tech support, etc) as this will be the MAIN use of such number rather than live chat lines which is rare so ensuring that live chat line use is given greater regulation than call centre usage doesn't make sense.

I'm also going to remind them that press reports some recent have highlighted cases where us consumers can be held in queues (15mins recently reported) but can be higher and this is where the call charges are mostly expensive - not generally from the few minutes you may actually be speaking with the call centres.

The whole consultation sounds like they want the lightest regulatory touch for 0871 numbers.

BB

why dont you sum it up and say the 0871 number is a Premium rate number and should be treat as so. That is the bottem line.  Ask them what they think it is.

Bobby

Quote:

why dont you sum it up and say the 0871 number is a Premium rate number and should be treat as so. That is the bottem line.  Ask them what they think it is.

We all know it's a premium rate number and so does Ofcom/ICSTIS but both Ofcom/ICSTIS DON'T WANT IT TO BE KNOWN THAT THESE ARE PREMIUM RATE NUMBERS as that would mean possibly jeopardising the revenue that Teleco's and companies make.  Right now these numbers, to most consumers, are still known as 'national' rate and even for those that are aware they cost more I bet you they're not aware that revenue sharing exists on this and other NTS numbers.

It's useless informing ICSTIS of something they're aware as they want to keep the actual use of 0871 (ie to earn revenue same as a premium rate number) unknown from consumers hence why Ofcom want ICSTIS to apply lighter touch regulation and a completely new name for them and possibly new website so not to have them actually known as premium rate numbers.

Basically hide all this from consumers.

In my opinion, all consumers should have a right to know any number that is a premium rate number (whether 09x or not).  Of course, Ofcom don't want this and will do their best to hide it from the consumers.

If a consumer knowing the cost of these numbers from where they're calling from and the fact they are a premium rate number (albeit on a smaller scale than 09x) numbers and continue to ring them then that is fine with me as that means consumers have made a fully informed choice on ringing them.  Most consumers now are not remotely aware of all of this so when ringing these numbers aren't doing having been fully informed.  In fact, if anything its because they misleadingly think they are either 'local' or 'national' rate.

bbb_uk wrote on Sep 29^th, 2006 at 9:48am:

The whole consultation sounds like they want the lightest regulatory touch for 0871 numbers.

And if they were to bring in more stringent rules like no queuing, then they would have to investigate complaints from pesky consumers. This will mean increased costs and therefore they will cross this off as not an option.

What about mentioning the fact that not giving pricing information is breaking certain EU directives? Which directives?

BB

The issue is not what OFCOM or  ISCTIC want 0871 (or 0845 or 0870) to be, but the fact that they are Premium Rate numbers. This is not because I say so or anyone has an opiniun but that the EU Commission termed them so. See link to Liz Lynn website on this issue. Please do not also forget that OFCOM tellls ISCTIC what to do as it is an arm of OFCOM.



As I have said repeatedly:   being Premium Rate numbers they must (as dave also mentions)
1. conform to the Misleading Advertising Directive - that is disclose the cost of the call before hand and must not mislead consumers that they are a costs of a normal call when they are not,

2.  Treat Consumers unfairly in a anti consumer practice.  The fact that they want to generate money out of consumers in my view is a unfair and unjust practice.

3. There is no reason to have 0871 or 0845 or 0870 as they provide no diffrent service then what was provide when businesses had land lines.

4. It is a fact that all businesses that have 0871  or 0845/0870 all have land lines. and it also a fact that if consumers were given a option to dial direct - even to India, or the any where in uk it is cheapr then being diverted by 0871/0845 or 0870.

Then ASK OFCOM and ISCTIC if they prepared to be investigated by the EU Commissioner and tell OFCOM and ISCTIC that you want this sites view that it cannot take part in Consultation - because of their deception to mask a Premium rate number when the commissioner has called them so.

Bobby

Pricing competition on services cannot work because call queuing is permitted. This assumes that call prices have to be displayed, as well.

Take a 10p/min service and a 5p/min service. The 5p/min queues calls, but the 10p/min doesn't. As a whole, the 5p/min service which appears to be half the price, is in fact more expensive due to call queuing.

Dave wrote on Sep 29^th, 2006 at 3:39pm:

Take a 10p/min service and a 5p/min service. The 5p/min queues calls, but the 10p/min doesn't. As a whole, the 5p/min service which appears to be half the price, is in fact more expensive due to call queuing.

That's what I've tried to get through to ICSTIS by mentioning I'd much prefer to ring an 09x number costing 10p/min rather than the current 0871 number costing the same.

As this pre-consultation is over I've removed it as a sticky.

It appears to be around February 2007 when the final consultation will be released.

Bobbyboy wrote on Sep 29^th, 2006 at 2:48pm:

Then ASK OFCOM and ISCTIC if they prepared to be investigated by the EU Commissioner and tell OFCOM and ISCTIC that you want this sites view that it cannot take part in Consultation - because of their deception to mask a Premium rate number when the commissioner has called them so.

I told them in my 8 page response that I would be making sure personally that they would be investigated by the Parliamentary Commissioner for Standards and by the European Commissioner if they failed to impose the same rules and the same branding on these 0871 numbers as all other Premium rate numbers starting 09.

I pointed out that in Ofcom NTS Way Forward the proposals were that 0871 be fully ICSTIS regulated and the only weasel excuse given for leaving it on the old 0871 numbers was the usual rubbish about how difficult it would be for business to move numbers etc, etc.  So strange then that Ofcom don't mind at all about all the companies now stuck with a Premium Rate so called Lo-Call 0845 number will have to change to a new 03 number if they don't want many of their customers to pay a 35p a minute premium rate from some mobile phone providers.

My suggestion was that because the use of 0871 for a premium rate number was inherently deceitful and misleading that they actually needed more high profile branding and notices to ensure that these weren't confuses with 0870 when those numbers become charged at geographic national rate.

I did complement them on making their proposals in only 20 pages rather than the 200 it usually took Ofcom but I still said I thought they could have had more charts and diagrams.  I said I had given up hope on responding to Ofcom consultations making any difference to the final regulations proposed but was hoping that it might be worthwhile in their case.

I'm sure though that they will still press ahead with the original Master Plan as agreed in smoke filled rooms with Bodge It & Scarper Carter.  And we will I'm sure have to go all the way to the European Commission if we are going to bring an end to the misdeeds of all of Ofcom's most unprincipled and careerist snout in the trough employees.

I said Ofcom was a "compromised regulator" in my ICSTIS response clearly implying that they wouldn't want to fall into this trap.

I did notice that in the Consultation document they suggested they were only looking for consumer groups to respond though - perhaps they were hoping for a complementary response from the Ofcom Mealy Mouthed Consumers Panel for instance who recently  had another vacancy but again refused to call me for an interview for the third time in just over a year (notice how no one from the Ofcom Cronies Panel ever campaigns publicly against Ofcom policies in the national press).  I bet it will come as a shock to ICSTIS when they get 30 or 40 real individuals responding but its a shame it won't be 1,000.  Most people have lost heart by now with these crooked regulators who pretend to consult and even have the cheek to suggest to the press they are doing something positive about 0870 while actually making arrangements first to let the cost go up by 3p per call with BT and then to let the whole 0870 scam increase in cost from 7.51p peak rate to 10p per minute at all times.

Unfortunately I didn't respond to the Numbering Plan Review a few months back because I knew I would have spent ages on it but it wouldn't have made any difference because it was clear it was already a done deal given their previous statement on the results of NTS Way Forward and how they were going to tackle 0844/0845/0870 and 0871.

I only responded to this consultation because it was ICSTIS to give them a chance to show they are not like Ofcom.

With an Ofcom consultation I honestly think you might actually achieve more by going and padlocking yourself to the doors of Riverside House and calling a Press Conference.  Its clear that Ofcom think they can just ignore what the general public want and instead do what the business cronies of New Labour want them to do with impunity. >:( >:( >:(

bbb_uk wrote on Sep 29^th, 2006 at 5:28pm:

As this pre-consultation is over I've removed it as a sticky. It appears to be around February 2007 when the final consultation will be released.

I particularly went to town on them saying they were worried that the current timetable was meetable in their questions section and told them they had damn well better meet it because they had already delayed at least 2 more years than everyone thought and we were about 10 years on from the start of 084/7 scamming.

I also asked in my response email if they will be publishing the responses to the consultation on their website as Ofcom do.

I also slammed them over them saying in the questions that they only particularly wanted the views of call centre trade bodies on call centre waiting times.  I suggested they should want all of our views and that my view was that any time call queuing should be reverse charged to the call centre on the same basis as the 0800 system as then call queuing would become self policing as any call centre that had long queues would then find it was costing  them a lot of money.  Otherwise under the current system those who provide bad customer service get paid extra.  Also I highlighted known 0871 call centres like Easyjet where you can wait up to 2 hours on 0871 only to get cut off before they ever answer.

I told them that what was effective and proportionate for the development of an effective consumer protection scheme was dirty great fines these proven call centre cowboys wouldn't forget and surely if they had learned nothing else from dealing with overseas "you've won a big prize" 09 number callback scammers and unsolciited reverse charged text message senders it should be that having tea and crumpets with these kind of people and giving them more time doesn't work.  Since when did your local council send you a polite friendly note to go in and have a chat if you failed to pay your parking ticket or your council tax on time.

Did anyone see that program Whistleblowers the other day about how Bailiffs use outrageous money with menaces techniques and  falsified charges for non existent visits to intimidate the generally poor and needy.  So its a jackboot for Mr and Mrs Socially Deprived but a nice friendly chat for the I Used to Be at Uni with Stephen Carter head of Call Scammers Unlimited UK. ;) :o

I took the liberty of CC'ng my full Response to the ICSTIS Pre Consultation to this list of senior Ofcom personnel and Ofcom Board Members.

Although I suppose you could argue that we shouldn't pass this information into enemy hands I expect you will find that ICSTSIS may let Ofcom see the Responses to this consultation anyway eventually and I expect it does no harm to let especially the Non Exec Ofcom Board Directors who feature in this list know how much unhappiness there still is with the disgracefully inadequate nature of their proposals for the whole 084/7 regime and especially 0844, 0845 and 0871 numbers.

Here are the people I CC'd on my response:-

stephen.carter@ofcom.org.uk; david.currie@ofcom.org.uk; ed.richards@ofcom.org.uk; kip.meek@ofcom.org.uk; sean.williams@ofcom.org.uk; matt.peacock@ofcom.org.uk; clive.hillier@ofcom.org.uk; colette.bowe@ofcomconsumerpanel.org.uk; gareth.davies@ofcom.org.uk; philip.graf@ofcom.org.uk; millie.banerjee@ofcom.org.uk; ian.hargreaves@ofcom.org.uk; stephanie.liston@ofcom.org.uk; sara.nathan@ofcom.org.uk; gareth.davies@ofcom.org.uk; geoff.brighton@ofcom.org.uk; steve.unger@ofcom.org.uk

BB

thanks for the feed back. I have dealt with the issue of "cost to business" as OFCOM in their letter to me said it would cost business £100 million. I worked out on a 6 hour day the cost to Consumers at 10p /min x 60 min x 6 x million calls x 365 days came to £1.2 billion approx. It is an Anti Consumer practice.

There is also a difference - the Buinesses is benefiting by an UNFAIR Consumer Practice which is costing the consumer on a 6 hour day £1.2 billion compared to £100 M. The consumer is at a Unfair, unjust detriment in breach of Law.    Secondley there is no need for Business to have 0871 etc thus the argument about cost to business is irrelevant.

I think it may be time to have letters exchanged or details in order that I or you or any one else can forward to MEP, MP and OFT. I noted this site does not have for Private messages.

BB did you send to Sue Cook at the OFT - she is a Director there.

Bobbyboy wrote on Sep 30^th, 2006 at 10:29am:

I noted this site does not have for Private messages. BB did you send to Sue Cook at the OFT - she is a Director there.

There is a "Personal Message" link on the bottom of every post by a forum member.  Just click that to send them a Private Message.  However you also need to go into your User Profile for the forum and turn on the feature that sends you an email and brings up a message box when you visit the forum if you have new Private Message.

I have constantly copied in Tessa Jowell the Culture minister and senior directors at the OFT and Competition Commission on many of my communications over the last two years but they have all turned deaf ears.  084/7 is a benefit fest for various important friends of New Labour in the commercial sector who do things New Labour wants and make donations to New Labour.  That is why this blatant scam never stops but only gets worse every month.  The media seem totally stupid on telecoms pricing issues and the business correspondents never take an interest in a matter worth over £1 billion a year of cost to consumers.  And when MPs question Ofcom do they go on about the £1 billion 084/7 scam.  No they get obsessed with 118 Directory Enquiries which there are lots of scams and is another area of major Ofcom incompetence and deceit (for instance call centres offer to connect you to the number you want but still go on charging 50p per minute) but nowhere near on the scale of 084/7.

I'm not quite clear of your background BobbyBoy and what has suddenly brought you to this web forum now rather than at an earlier stage?

ICSTIS have published the responses to their pre-consultation on 0871 numbers here.

Looking at the lack of consumer response then I'd say we've lost the battle to have, at the very least, charging whilst in a queue prohibited.  :(

I know this is only the pre-consultation but due to lack of response ICSTIS may not even mention it in their final consultation around February 2007.

bbb_uk wrote on Oct 23^rd, 2006 at 4:43pm:

ICSTIS have published the responses to their pre-consultation on 0871 numbers here. Looking at the lack of consumer response then I'd say we've lost the battle to have, at the very least, charging whilst in a queue prohibited.  :( I know this is only the pre-consultation but due to lack of response ICSTIS may not even mention it in their final consultation around February 2007.

Dear bbb,

I have only just seen the published response list to the pre-consultation (as I was desubscribed from this thread due to my new forum member ID) and it is very disappointing that so few members of the public have responded and I'm afraid it only goes to confirm that I was correct to be very disappointed that Daniel did not bother to send an email to all forum members 3 or 4 days before the Pre-Consultation closed advising them it was critical to respond.

Of particular concern is that the Site Owner has once again failed to respond to an important consultation document himself, still rather suggesting that his main priorities seem to lie elsewhere.  Also bbb_uk did you respond to this pre-consultation since although I see the name of the other main forum moderator on the responses list I do not see a name that appears to be you.  There is another member with the same first name as you who has responded but I know from previous PM correspondence with that person he is not you.  Perhaps though you are the anonymous respondent to the consultation?

The responses from the telco groups are the usual sickening stuff claiming that not much consumer detriment is involved so not much protection is needed.  No mention of extotionate rates from mobiles to 0871 potentially being charged and also not even being able to call the numbers at all from overseas.  Also very disappointing is the BT response where the commercial side of BT now seems to have gained the upper hand over the ethical and corporate responsibility side and their response seems an all out attempt to ensure a replacement for the substantial amounts of revenue their NTS number vending side will lose when 0870 revenue share is abolished.

Don't forget though that this is only a Pre-Consultation though and will lead to the full Consultation document in a couple of months time.  I can only hope that Daniel will remember to email all the forum's members 3 or 4 days before that Consultation closes (any more than that and people will put off doing it and not get round to it) stressing it is vital for as many people as possible to respond.

NGMsGhost wrote on Nov 1^st, 2006 at 3:25pm:

Perhaps though you are the anonymous respondent to the consultation?

Yep, that's me.

I believe the lack of responses were many reasons including:-

• The Ofcom consultation gave the impression that our concerns about call queuing, etc would be solved with the announcement of 0871 coming under ICSTIS remit.
  
• People just naturally thought that at the very least the main concern about call queuing and being charged would be dealt with as normal as it is for 09x numbers under ICSTIS remit.
  
• It was a pre-consultation and people couldn't be bothered responding to this and the next one - instead waiting until the final one!

I for one, didn't expect that ICSTIS was looking to apply what appears to be no rules at all really except coming up with a fancy new website so consumers didn't know they are premium rate numbers!

ICSTIS recommendations were basically to avoid applying cost transparency in adverts, etc, avoid applying call queuing, etc.  Basically, avoid applying anything at all.

The problem is we don't know if the option of prohibiting being charged whilst in a queue is even going to be mention in the final consultation on this so let's hope the option is still there.

I'm going to read the consultation shortly after it comes out next time instead of waiting until the very last minute as I normally do.

I mentioned this consultation a few times on MSE but got hardly any response at all which is a shame because we all know people hate these numbers but can't be bothered responding or haven't the time to respond.

I think we need to get MSE involved in this next (final) consultation otherwise there will be no difference between 0871 numbers now and when they will be under ICSTIS remit except a fancy new website!