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Message started by irrelevant on Jan 3rd, 2009 at 12:18am

Title: Ofcom 070 review
Post by irrelevant on Jan 3rd, 2009 at 12:18am
I'd not even heard of this one, and couldn't find a reference to it on here on a quick search, but I've just had the following in an email from Flextel (a major supplier of 070 numbers). Obviously they wish to push their point of view, but if anybody has any definite opinions on the future of 070, either for or against, then time is running out to get your views in.

Quote:
Happy New Year to all our readers!

The team at FleXtel hope you had a restful holiday and that you found our service useful in handling calls efficiently, whilst your staff took a break. As usual any feedback is welcome, good or bad.

Now to the point of this email...
Next Wednesday, 7th January 2009 at 5pm, Ofcom's 070 consultation closes. This is your LAST CHANCE to help justify the powerful 070 service.
http://www.ofcom.org.uk/consult/condocs/070options/

It's easy to respond...
http://www.ofcom.org.uk/consult/condocs/070options/howtorespond/

Why not simply fill-out Ofcom's online form? Here...
http://www.ofcom.org.uk/consult/condocs/070options/howtorespond/form

Thanks to your help, Ofcom already seems to better understand the merits of 070. We're very encouraged with the quality and detail provided in this latest consultation, as mentioned in our Newsletter of October... http://www.flextel.co.uk/press/news.html

BUT CONFUSION IS APPEARING
==========================
Last week Ofcom's enforcement arm PPP, seems to have jumped the gun...
http://www.phonepayplus.org.uk/news/articles/nr_20081219.asp

FleXtel understands that "Due diligence for 070" is only a proposal at this time (see question 5 in Ofcom's consultation), so I have written to Ofcom seeking clarification and explaining why FleXtel believes this will be challenging, especially for those customers based outside the UK.
I understand that "Due diligence" means that FleXtel will be required to ask some customers for identification information e.g. passport, birth certificate, company registration documentation, driving licence and/or utility bills. Unlike premium rate users (to which due diligence rules normally apply), many 070 users reside abroad. It may be particularly difficult to transfer authenticated (legally notarised) documentation worldwide.

So it's really important you take a few minutes and tell Ofcom why you need 070 and answer their refreshingly simple questions.

FLEXTEL'S RESPONSE
==================
You may be interested to note how FleXtel is responding to these questions.
Our answers to Ofcom's consultation are broadly:
Q1 - Yes.
Q2 - Yes.
Q3 - Yes.
Q4 - Yes.
Q5 - Perhaps, but only where necessary, objectively justifiable and consistent with the need to avoid artificial barriers to EU and international trade.
Q6 - Yes. CLI is an important facility in normal use. If is is barred on 070 then it follows that it also should be barred from many other services. There are better, more generic, ways to deal with such scams e.g. the introduction of Call Price Labelling, so that callers can immediately check the call price and decide whether to pay for a return call.
Q7 - Yes. Patientline and similar services are clearly premium rate use, i.e. where the revenue is used to pay for equipment provision, not call forwarding. They should use 09x numbers.
Q8 - Yes. This concept was always fatally flawed, dangerous and not in line with EU and ITU regulations and recommendations. Ofcom had been warned about this several times, by industry experts, since 2004, but carried on regardless, in what appeared to be a reckless manner.

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 8th, 2009 at 4:31am
Whilst previous experience tells me that responses to all Ofcom consultations by members  of the general public are only met with their absolutely predictable utter disregard, disdain and contempt and this re-consultation in order to disregard their own original original proposals on 070 numbers actively proves that fact in this case like a moth to the flame I was drawn in and could not let this one pass.  I consequently submitted the following response:-


Quote:
What do you want Ofcom to keep confidential?:

Keep nothing confidential

If you want part of your response kept confidential, which parts?:

No part of my submission is in any way confidential but nor should any part of it be withheld, edited, amended, redacted, altered or otherwise tampered with by members of Ofcom’s legal staff without my prior permission, consultation and agreement. If such redaction is undertaken by Ofcom without my permission I will approach my Member of Parliament about the matter and have it referred for investigation to the Parliamentary & Health Service Ombudsman

I note that sections of my response to a previous Ofcom consultation were redacted and removed by members of Ofcom's staff without my permission and also without any prior explanation, notification or discussion of that decision. This all too clearly indicates the near total contempt in which Ofcom's board seems to hold the views of any ordinary members of the public who attempt to impede its secret pre-agreements with sections of the telecoms industry that it then dresses up retrospectively in sham consultations to overturn recommendations that it (Ofcom) had made in previous consultations on precisely the same subject. This appears to be because the telecoms industry have told Ofcom abolishing covert PRS numbers will slightly diminish its enormous profits from hidden premium rate NTS services and that it is prepared to go to court to defend this.

Ofcom may publish a response summary:

No

I confirm that I have read the declaration:

Yes

Ofcom should only publish this response after the consultation has ended:


You may publish my response on receipt

Question 1: Do you agree with our analysis of consumer detriment on the 070 number range?:

No I do not agree with any part of your analysis where you have completely ignored the fact that the use of the prefix 070 by Personal Number misusers occurs purely so that the caller will be confused in to thinking that the number is a mobile phone number charged at mobile phone rates.

This will be of the greatest possible detriment of all to users of mobile phones as large numbers of mobile phone users have contracts that give them a set number of bundled minutes per month to all UK fixed lines and to all normal UK mobile phone numbers. Callers will explicitly call back or call 070 numbers believing they are part of their mobile phone bundled minutes and will suffer huge detriment as a results when they end up with a £5 or £10 charge on their bill for what they thought was a free call.

070 numbers are Premium Rate Numbers on any normal price definition. The only reason that complacent and lethargic Ofcom is now trying to renege on the commitments it firmly previously gave to stop this abuse three years ago is because having allowed the scam to persist for this long it now fears that the scammers who run these numbers will go to the Competition Appeals Tribunal.

These numbers are deliberately and systematically abused and have never been used for the stated purpose. For instance they are used for hospital phone numbers for hospital patients that the patient does not own and cannot take elsewhere. They were also used as the main normal contact number by the company (RETAINACAR) that security etched my current car windows.

The complete and utter abuse of any normal misleading price indications requirements under the Consumer Protection Act 1987 implicit in allowing 070 to continue is utterly appalling yet Ofcom fears a reference to the Competition Appeals Tribunal far more than it apparently fears an investigation of its clandestine yet systematic non protection of the best interests of UK citizens and uk consumers in relation to phone call costs by the Office of Fair Trading and the Competition Commission.

I believe that Ofcom now appears content to exist only as a bureaucratic rubber stamp for legalised continued theft from UK citizen consumers by charging them premium rates for calls that they did not understand were premium rate before they made them.

Ofcom's record here is an utter disgrace but of course as they do not accept the right of the public to criticise their actions and rely instead on old fashioned Stalinist bureaucracy to push through their plans they can no doubt be expected to Redact (or in layman's speak censor) this section of my Response.


Continued/...........

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 8th, 2009 at 4:36am

Quote:
Question 2: Do you agree that the costs outweigh the benefits in relation to closing the 070 number range and migrating users to an alternative range?:

No I do not agree.

The cost to the citizen consumer of scams like Patientline's various successors being allowed to remain in business greatly outweigh any possible detriment in the business running them being forced to bear the full costs of using an 09 premium rate service charge at premium rate calling rates and having nothing at all to do with the 07 mobile phone code prefix.

But what can we expect from woolly minded Ofcom who still allows Jersey, Guernsey and the Isle of Man to have mobile phone number prefixes in the 07 number range, even though they are not part of the United Kingdom and calls to these numbers are not part of bundled UK mobile phone minutes or calling plans. Ofcom seems to suffer from a form of complete moral autism when it comes to the allocation of UK phone numbers and its only concern seems to be that telecoms scammers should not be forced to give up any form of hidden revenue stream they have become used to due to Ofcom's and Oftel's previous complacency and lethargy.

All of Ofcom's previous pledges to end these scams and abuse and make phone numbering transparent (most notably of all by its former Director of Communications, Matt Peacock in an interview with BBC Radio 4's You and Yours program) have proved utterly worthless and instead Ofcom has persistently ignored its principal duty to protect citizen consumers in favours of the interests of the telcos, who it continues to meet with in smoke filled rooms at various clandestine industry group meetings not open to input from telecoms consumers, such as the NTS Focus Group.

All of Ofcom's consultations are totally dishonest as when Ofcom gets an overall response to a consultation it does not like it either makes a firm promise of action (as with 0870) only to retract its promised regulations at the last minute two years later or otherwise it just puts the consultation on ice (as with 070) only to come out with another consultation proposing precisely the opposite of what it originally proposed three years earlier. Ofcom is as an utterly morally bankrupt organisation that sides only with the telecoms industry and ignores all valid attempts by consumer groups to engage with it. It has absolutely no forums whatsoever for engaging with consumers other than its so called Consumer Panel to which it only even gives interviews to existing paid up card carrying members of the telecoms and broadcasting industry establishment.

Question 3: Do you agree that Ofcom should keep the 070 range open and monitor the market in light of enforcement action by PhonepayPlus?:

No I believe that the 070 number range should be forcibly migrated immediately and without further notice on to a section of the 09 number range with all similar requirements to 09 numbers regarding call price announcements etc being immediately required to be applied to those former.070 numbers

Question 4: Do you agree that Ofcom should require OCPs to give greater prominence to the cost of calling 070 numbers in published price lists and promotional material?:


I believe there should be voice based pre announcements of the call rate and that the caller should be offered a free of charge voice based computerised call back at the end of the call or a free text back to tell them what the cost of the call has been.

It is imperative in particular that no user of a uk mobile phone should call an 070 number believing these calls will be charged out of their bundled mobile phone inclusive minutes only to find this is not the case. Equally pay as you go mobile phone users and landline phone users should not dial 070 only to find the call costing vastly more than a call to a normal UK mobile phone number,

The Pay As You Go mobile phone operators such as Vodafone should be forced to offer either free of charge itemised billing and/or free call back with the call charge of a call and/or a pre-call announcement of the cost per minute of a call for every call a customer may make if they wish to enable this facility. The fact that Vodafone makes it near impossible to find out the rate of calling an 070 number or the fact that it is different from a mobile call before a call is made and that it does not offer Pay As You Go customers itemised billing as standard is truly shocking and a complete indictment on the calamitous regime of regulatory non control of this sector that has prevailed under Ofcom's stewardship and also under that of OFTEL before it.


Continued/.............

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 8th, 2009 at 4:40am

Quote:
Question 5: Do you agree that Ofcom should amend its guidance to ensure that PNS providers carry out appropriate due diligence of sub-allocatees of personal numbers?:

No I just believe the whole damned lot should be renumbered to start 09 immediately and shown as such on all phone bills. I also believe it should be made illegal for pay as you go mobile phone operators not to offer free of charge itemised online billing for any customer who wants it as well as paper based itemised billing at a suitable fee that covers only printing and posting costs to any customer who wants it.

If you go to the supermarket you know what something will cost before you arrive at the checkout so why has Ofcom totally failed to ensure this principal applies when buying telephony services. Surely it is actually the law as defined by Part III of the Consumer Protection Act 1987 (misleading price indications).

Question 6: Do you agree that Ofcom should not bar the presentation of 070 CLI? Please provide evidence to support your response:

No I believe Ofcom should bar the presentation of 070 CLIs as the sole purpose of their presentation is to allow the perpetuation of these numerous scam abuses of the numbers that rely on the public being conned in to thinking they are calling an ordinary mobile phone number.

Ofcom knows this is the case but is now back tracking on its earlier promises because after meetings behind closed doors with people who are no doubt former business colleagues of at least some Ofcom employees it has no doubt decided that taking the right action in favour of the citizen consumer will cost these telecoms companies too much money.

Question 7: Should services provided by, for example, Hospedia, Premier Telesolutions and Trader Media be provided on an alternative number range to 070? Please provide any evidence to support your views.:


All services currently provided on 070 numbers should be moved to 09 forthwith without exception.

Ofcom knows perfectly well the only use of 070 numbers is to massively scam the general public but it is once again siding with the telecoms industry because it thinks they have access to bigger and better paid lawyers than UK citizen consumers do.

When Ofcom talks of the level of consumer detriment what it is actually saying is that this is a jolly profitable wease that various cowboys in the telecoms industry have got used to and will now go to court to try and defend.

As Ofcom seems to consider its actual principal remit to be the comfortable profitability of most of the telecoms industry it does not seem wish to go to court in order to fulfil its principal remit to ensure competitive markets for uk citizens and uk consumers (but not for telecoms operators) under Section 3(i) of the Communications Act 2003

Question 8: Do you agree that Ofcom should withdraw formally the requirement for pre-call announcements on 070 Personal Numbers?:

No I believe that compulsory pre-call announcements on all 070 numbers should be enforced if they are allowed to continue and any personal alarm devices or other devices that rely on the use of 070 numbers for their revenue stream should be forced to discontinue the use of those numbers and instead charge their customers a subscription or an itemised monthly bill for the value of the telecoms and goods and services they are currently receiving in phone charges.


Continued/..........

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 8th, 2009 at 4:41am

Quote:
Additional comments:

Ofcom originally proposed a clear cut solution that was its own suggestion to move 070 numbers to the 06 code prefix in its review "Safeguarding The Future of Numbers" so that all of the abuses associated with consumers mistaking 070 premium rate numbers for mobile phone numbers and thinking they would be included in mobile phone bundled minutes would be brought to an end.

Now some two to three years later Ofcom spinelessly caves in over the implementation of its earlier proposals and now claims that 070 numbers don't really do too much harm old chap and that consumers don't mind regularly having to pay several quid extra on their phone bills for calls that they thought were to normal mobile phone numbers.

All of the companies who operate on 070 use some of the most dubious and deceitful selling methods to obtain their customers ever known in almost any industry and it is utterly shocking that a so called regulator should be prepared to sanction and endorse this continued abuse of UK citizen consumers.

Ofcom tells us it will all be alright because it will ensure greater price transparency for the cost of 070 calls on phone bills but what confidence can we have in the word of or the competence or professionalism of a regulator who went back on its word that it would make 0870 call costs the same as call costs to 01/02 numbers and that still allows the vast majority of fixed line uk call carriers to issue bills to their customers that show 0845 and 0870 calls are "Lo-Call" and "National Rate" calls, even though both the ASA and Trading Standards have prevented the continuation of this activity in paid advertising. However unfortunately phone bills are not considered advertising but are subject only to Ofcom's own General Conditions regarding phone bills and call charges. Conditions which it, Ofcom, is so spectacularly lackadaisical in ever managing to enforce in the best interests of the UK citizen consumer.

While the saynoto0870 campaign of which I am member has more supporters than ever sadly very few of them will bother to respond to this consultation as after thousands of campaigners responded to previous Ofcom and ICSTIS/PhonePayPlus consultations on 0845, 0870 and 0871 numbers and were then resoundingly ignored in favour of the telecoms industry most UK citizen consumers have rightly come to realise that Ofcom is a body they cannot trust in any shape or form.



Title: Re: Ofcom 070 review
Post by loddon on Jan 9th, 2009 at 2:37pm
To: NGMsGhost,  

Well said and an entertaining and informative read, as your submissions usually are.   You have my support and I would be interested in any response or feedback you may get from Ofcom.    I regret that I didn't make a submission myself though I know very little about 070 numbers other than they are very expensive to call and can be easily mistaken for mobile numbers.   I could not have added anything to or improved on anything you say.    I only wonder if you have been too gentle and understanding with Ofcom ?:) ;)

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 11th, 2009 at 4:31pm

loddon wrote on Jan 9th, 2009 at 2:37pm:
Well said and an entertaining and informative read, as your submissions usually are.


Thanks loddon.  I wonder if I should make my submissions any less "entertaining" in order to be taken seriously by Ofcom.  But then again Ofcom never ever takes the views of members of the general public seriously anyway so why bother making them less "entertaining".


Quote:
You have my support and I would be interested in any response or feedback you may get from Ofcom.


I will naturally not get any response or feedback from Ofcom.  Ofcom does not engage with the public.  It only engages at various official forums with representatives of the telecoms industry. :o >:( :'(


Quote:
I regret that I didn't make a submission myself though I know very little about 070 numbers other than they are very expensive to call and can be easily mistaken for mobile numbers.   I could not have added anything to or improved on anything you say.


There is little to know about them other than that they are another form of premium rate number where the caller pays vast additional amounts to call the number for benefits that only then accrue to the called party and/or their telecoms supplier.

They are principally known for their misuse by the hospital bedside telephone operator Patientline in NHS Hospitals and otherwise are mainly used by people who want to divert calls to an overseas mobile phone without having to pay anything themselves for the additional costs of the overseas mobile phone call element.  There is a series of 070 number that cost about 40p per minute that will divert to mobile phones registered to numbers based in other EU countries but of course to most unsuspecting callers the 070 PNS number looks just like a UK mobile phone number.  070 calls are never included in bundled mobile phone inclusive minute calling plans.

So 070 numbers are similar in principal to 084/7 numbers but worse in practice because the level of call charges is far higher than with 084/7 numbers.

Patientline and other hospital operators deliberately adopted them so that they could charge 50p per minute without many callers realising this was the cost (wrongly thinking it was a mobile) and without being subject to any normal 09 premium rate call price disclosure requirements.  A further refinement of the scam by Patientline was for you to have to speak to one of their operators in a call centre for three or four minutes at 50p per minute before even being connected to the patient.

The only claimed justification of 070 numbers by OFTEL/Ofcom was that they always reached the caller wherever they were but even this was a lie with Patientline as the numbers belonged to Patientline and not to the patient..............

The main thing to know is they are yet another area where Ofcom has promised to end the scams and abuses only to then collude with the telecoms industry behind the public's back to allow all of the abuses to continue completely unfettered as before.... :o >:( [smiley=thumbdown.gif] [smiley=thumbdown.gif] [smiley=thumbdown.gif]

Title: Re: Ofcom 070 review
Post by andy9 on Jan 19th, 2009 at 2:17am

NGMsGhost wrote on Jan 8th, 2009 at 4:36am:

Quote:
[b]
But what can we expect from woolly minded Ofcom who still allows Jersey, Guernsey and the Isle of Man to have mobile phone number prefixes in the 07 number range, even though they are not part of the United Kingdom and calls to these numbers are not part of bundled UK mobile phone minutes or calling plans.  


I don't see the point of trying to confuse them with irrelevant other sniping comments, particularly on this subject, especially when you seem slightly confused yourself about some details.

2 main networks and some mvno providers include such calls in their contract bundles or at the same pay as you go rates as UK mobiles.

Ofcom don't mandate networks which calls they may or may not include. Instead you might lobby your own network to include the calls, rather than trying to wind up Ofcom into changing the numbers of such phones, to the probable paradoxical effect that they then would be excluded by all main UK networks, and cause needless disruption for the customers of the networks on the islands.


Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 19th, 2009 at 3:25am

andy9 wrote on Jan 19th, 2009 at 2:17am:
I don't see the point of trying to confuse them with irrelevant other sniping comments, particularly on this subject, especially when you seem slightly confused yourself about some details.

2 main networks and some mvno providers include such calls in their contract bundles or at the same pay as you go rates as UK mobiles.

Ofcom don't mandate networks which calls they may or may not include. Instead you might lobby your own network to include the calls, rather than trying to wind up Ofcom into changing the numbers of such phones, to the probable paradoxical effect that they then would be excluded by all main UK networks, and cause needless disruption for the customers of the networks on the islands.


These territories don't pay UK taxes and they have their own internet domains and their own car registration number system.  So why therefore should they have a UK country dialling code?

Also what concerns do you have about any UK callers to any mobile number in these territories that you may yourself use who are not dialling from one of the two UK networks you mention and so who may think they are calling out of bundled minutes only to discover they have been charged at international rates?

I find it odd that you should also have to resort to one of Ofcom's most weasle worded reason for not taking regulatory action to perpetuate the continuation of the current anomalous situation.

Title: Re: Ofcom 070 review
Post by andy9 on Jan 19th, 2009 at 10:55am

NGMsGhost wrote on Jan 19th, 2009 at 3:25am:
These territories don't pay UK taxes and they have their own internet domains and their own car registration number system.  So why therefore should they have a UK country dialling code?

Also what concerns do you have about any UK callers to any mobile number in these territories that you may yourself use who are not dialling from one of the two UK networks you mention and so who may think they are calling out of bundled minutes only to discover they have been charged at international rates?

I find it odd that you should also have to resort to one of Ofcom's most weasle worded reason for not taking regulatory action to perpetuate the continuation of the current anomalous situation.


Your argument is more than a little perverse - now you seem to want these numbers (and also the landlines there of course) excluded on the spurious grounds of taxation reasons not telecoms; part of the time (earlier) you're whingeing that the calls should be included in UK network inclusive minutes.

If you were able to achieve that they were numbered as a different territory, then they would certainly not be inclusive. I for one, and I'm sure thousands of others, would strongly canvass against your destructive impulses on this subject. I suspect the regulators in Guernsey Jersey and the Isle of Man would have something to say on the matter as well. You can read their current policy, and info about allocations and coordination with Ofcom, in the relevant places.

Ofcom cannot regulate which numbers the mobile networks count as mobile networks in their inclusive minutes. The original idea of contracts with inclusive minutes to other networks was invented by the networks themselves not by Ofcom.

As I've said before, lobby your own network to include the calls. There are certainly inconsistencies in their charges to these: 3 and Vodafone well over their tariffs for the rest of Europe

As for my personal behaviour in regard to these numbers - you moralistically allude to whether I should be concerned - people don't call me on one of those numbers and get an unpleasant surprise; they call me on my ordinary contract number which was forwarded. I would imagine that other users do similar or forward via a landline as well.

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 19th, 2009 at 12:50pm
andy9,

I decline to continue the debate since whatever I say you are bound to take exception to it.

I note that you seem to be alone in this regard and that no other forum member seems to have taken exception to my response to Ofcom regarding 070 numbers.

I do of course thank you for at least taking the time and trouble to carefully read through all of my submission. ;) ::)

Title: Re: Ofcom 070 review
Post by andy9 on Jan 19th, 2009 at 2:50pm

NGMsGhost wrote on Jan 19th, 2009 at 12:50pm:
andy9,

I decline to continue the debate since whatever I say you are bound to take exception to it.

I note that you seem to be alone in this regard and that no other forum member seems to have taken exception to my response to Ofcom regarding 070 numbers.

I do of course thank you for at least taking the time and trouble to carefully read through all of my submission. ;) ::)


Not all of your submission is about 070 numbers, and not all of it is actually correct.

If you could improve both of these aspects, it might make it a lot shorter and easier to read. Perhaps an improvement in diplomatic tone might also make it easier for some of these mandarins to empathise with.

I doubt that many people agree with the rather odd ambivalence of your stance about calls to the Channel Islands and the Isle of Man

Title: Re: Ofcom 070 review
Post by Dave on Jan 19th, 2009 at 9:12pm

NGMsGhost wrote on Jan 19th, 2009 at 3:25am:
These territories don't pay UK taxes and they have their own internet domains and their own car registration number system.  So why therefore should they have a UK country dialling code?

They share the UK's country code because that's the way it was done. I don't know why that is. In an ideal world, perhaps they should have their own ones. Are we to assume that you would like Jersey, Guernsey and IoM to change to their own country codes?


NGMsGhost wrote on Jan 19th, 2009 at 3:25am:
Also what concerns do you have about any UK callers to any mobile number in these territories that you may yourself use who are not dialling from one of the two UK networks you mention and so who may think they are calling out of bundled minutes only to discover they have been charged at international rates?

The issue of some 07 mobile numbers being outside of inclusive bundles does not just affect the three islands. I expect that other 075/077/078/079 numbers which are not allocated to the main networks (O2, Vodafone, T-Mobile, Orange and 3) will also be outside of inclusive minutes. It's strange that you don't mention these.

Title: Re: Ofcom 070 review
Post by irrelevant on Jan 19th, 2009 at 10:31pm

At least we're not yet in the mess that Gibraltar was in until recently with regard to their number space originally being within Spain ...

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 20th, 2009 at 1:22pm

Dave wrote on Jan 19th, 2009 at 9:12pm:
They share the UK's country code because that's the way it was done.


That's surely a bit like Tiscali, TalkTalk or Vodafone saying they charge the prices they currently do for 084/7 calls just because they can do and always have done.  But that surely doesn't make it right or ethical does it. ;) ::)


Quote:
I don't know why that is. In an ideal world, perhaps they should have their own ones. Are we to assume that you would like Jersey, Guernsey and IoM to change to their own country codes?


Either they should be deemed to be fully part of the UK for all call charging purposes, in which case they can retain their +44 code and current number allocations, or they should be deemed to be fully outside it and have their own country code so no one is misled.  Citizens of Glibraltar and the Falkland Islands have the right of abode in the UK if they so wish (like those of the Channel Islands and Isle of Man) but they still have their own telephone country codes.

The current situation is anomalous and deliberately misleading.


Quote:
The issue of some 07 mobile numbers being outside of inclusive bundles does not just affect the three islands. I expect that other 075/077/078/079 numbers which are not allocated to the main networks (O2, Vodafone, T-Mobile, Orange and 3) will also be outside of inclusive minutes. It's strange that you don't mention these.


I was not aware there were other UK based mobile operators who were not included in bundled cross network minutes packages.  Can you reveal who those operators are Dave?

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 20th, 2009 at 1:24pm

irrelevant wrote on Jan 19th, 2009 at 10:31pm:
At least we're not yet in the mess that Gibraltar was in until recently with regard to their number space originally being within Spain ...


With respect surely we are in precisely that situation as Jersey, Guernsey, Isle of Man currently have UK dialling codes but are not part of the United Kingdom.

Title: Re: Ofcom 070 review
Post by irrelevant on Jan 20th, 2009 at 3:17pm

NGMsGhost wrote on Jan 20th, 2009 at 1:24pm:
With respect surely we are in precisely that situation as Jersey, Guernsey, Isle of Man currently have UK dialling codes but are not part of the United Kingdom.


I was more referring to the mess referred to in the article whereby Spain considered Gibralter as part of their numbering plan, restricted them to using 5 figure numbers, and barred access to +350, wheras everybody else recognised +350 as a valid country code and allowed access to longer numbers, and consequently companies trying to route +350 calls via Spanish telecom operators had the calls dropped.

Title: Re: Ofcom 070 review
Post by andy9 on Jan 20th, 2009 at 4:32pm

NGMsGhost wrote on Jan 20th, 2009 at 1:22pm:
[
Either they should be deemed to be fully part of the UK for all call charging purposes, in which case they can retain their +44 code and current number allocations, or they should be deemed to be fully outside it and have their own country code so no one is misled.  Citizens of Glibraltar and the Falkland Islands have the right of abode in the UK if they so wish (like those of the Channel Islands and Isle of Man) but they still have their own telephone country codes.

The current situation is anomalous and deliberately misleading.


Quote:
The issue of some 07 mobile numbers being outside of inclusive bundles does not just affect the three islands. I expect that other 075/077/078/079 numbers which are not allocated to the main networks (O2, Vodafone, T-Mobile, Orange and 3) will also be outside of inclusive minutes. It's strange that you don't mention these.


I was not aware there were other UK based mobile operators who were not included in bundled cross network minutes packages.  Can you reveal who those operators are Dave?


Why is this issue winding you up so much?

The phone calls to there have to cross some sea, and they are terminated on networks run by different companies, so it isn't too surprising that charges may vary slightly.

As for your allegation that things are deliberately misleading: you just can't resist your default position of alleging corruption all the time, can you? And where is there any statement that is actually misleading? None at all; you're completely inventing most of this nonsense as you go along.

There are loads of companies with 07x mobile number allocations, VoIP, wi-fi, those dozen guard-band GSM networks, and others.

As I've already said, you don't like your own network's charges to non-included destinations, then canvass them to change. If not, switch network. Personally, I'm sceptical you're actually affected by this anyway.

Title: Re: Ofcom 070 review
Post by Dave on Jan 20th, 2009 at 10:41pm

NGMsGhost wrote on Jan 20th, 2009 at 1:22pm:

Dave wrote on Jan 19th, 2009 at 9:12pm:
They share the UK's country code because that's the way it was done.


That's surely a bit like Tiscali, TalkTalk or Vodafone saying they charge the prices they currently do for 084/7 calls just because they can do and always have done.  But that surely doesn't make it right or ethical does it. ;) ::)

What are you on about?  ::)

The prices they charge are set by market forces and doesn't necessarily reflect the actual cost (plus "reasonable" profit"). That is the point of having competing companies. I thought you knew more about economics than me!

I vote that we should drive on the right as driving on the left leaves us in a minority. Currently, cars must be modified to suit our strange ways. Visit saynotodrivingontheleft.com for more information.

Quite clearly such a change would nigh-on impossible.


NGMsGhost wrote on Jan 20th, 2009 at 1:22pm:

Quote:
I don't know why that is. In an ideal world, perhaps they should have their own ones. Are we to assume that you would like Jersey, Guernsey and IoM to change to their own country codes?


Either they should be deemed to be fully part of the UK for all call charging purposes, in which case they can retain their +44 code and current number allocations, or they should be deemed to be fully outside it and have their own country code so no one is misled.  Citizens of Glibraltar and the Falkland Islands have the right of abode in the UK if they so wish (like those of the Channel Islands and Isle of Man) but they still have their own telephone country codes.

Whilst I don't disagree with you in principal, a more pragmatic solution is to leave them as they are.


NGMsGhost wrote on Jan 20th, 2009 at 1:22pm:
The current situation is anomalous and deliberately misleading.

The use of the word "deliberately" implies that you think someone concocted it for devious intent!! lol


NGMsGhost wrote on Jan 20th, 2009 at 1:22pm:

Quote:
The issue of some 07 mobile numbers being outside of inclusive bundles does not just affect the three islands. I expect that other 075/077/078/079 numbers which are not allocated to the main networks (O2, Vodafone, T-Mobile, Orange and 3) will also be outside of inclusive minutes. It's strange that you don't mention these.


I was not aware there were other UK based mobile operators who were not included in bundled cross network minutes packages.  Can you reveal who those operators are Dave?

Source: Three Price Guide

Outside of inclusive allowances:

077442-9, 077552-5, 079118, 078931, 079112, 078745, 079784, 078744, 078939, 078223, 078220, 078920, 078727, 078922, 078930, 078921, 077001, 079780, 075201, 078730, 079788, 078221, 078644, 078224, 078226, 079785, 078225, 078933, 079789


Source: Vodafone Premium Call Charges

Up to 50 pence per minute:

07700, 077442, 077443, 077444, 077445, 077446, 077447, 077448, 077449, 077552, 077553, 077554, 077555, 079112, 07624, 07781, 077977, 077978, 077979, 079117, 079112

Up to 34 pence per minute:

078744, 078930

Title: Re: Ofcom 070 review
Post by idb on Jan 21st, 2009 at 1:05am

NGMsGhost wrote on Jan 20th, 2009 at 1:24pm:
With respect surely we are in precisely that situation as Jersey, Guernsey, Isle of Man currently have UK dialling codes but are not part of the United Kingdom.
The US, Canada and twenty-odd other territories of the NANP all share common 'dialling codes' (+1-nnn), although a call from +1-305 (Miami) to +1-212 (New York City) will, generally, be charged at a different rate from +1-305 to +1-441 (Bermuda). Is the situation within the British Isles vastly different in concept to this?

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 21st, 2009 at 2:17pm
All of the response to the Ofcom 070 consultation have now been published at:-

www.ofcom.org.uk/consult/condocs/070options/responses/

There are around 140 such responses in total but many of them are Name Withheld and are from the various individuals and businesses who insist on ripping off their callers by using an 070 number when they should be paying the forwarding cost themselves.

I do not recognise any other member of this group who I know the surname of (admittedly there are only about 10 or 15 such people who I do know by name) who have responded to this consultation.  Unfortunately the forum management massively fell down on this one by not putting a link to this consultation on its home page since 070 numbers have long been adversely commented on by this forum, both in the context of Patientline and mobile phone calling scams.

BT's response is interesting as they claim it would be disproportionate to bring 06 in to operation for this PNS use but then propose that 070 call recipients should be paying most or all of the higher call charges for the benefits they are receiving from the call redirection (instead of the caller).  But in which case surely 03 can already provide such a facility for anyone who wants a totally redirectable number but will pay for the redirection cost themselves?  If BT's suggestion was implemented then this would really be the final death knell for Patientline type hospital 070 services as I can't see the hospital patient being willing to pay 30p per minute incoming (the patient themselves obviously not being afflicted by quite the same guilt trip about needing to make contact as friends and loved ones, except I suppose where the prospects of surviving the op are not that good at all).  Of course I expect Ofcom will just roll on with their original proposal to leave the whole shoddy scam 070 number system in place since they seem much more concerned about not having to take on any businesses who challenge them at the Competition Appeals Tribunal.

However at least they published my response in full this time despite it being highly critical of Ofcom (but not libelous of any person or individual).  I think my threat to take any further redaction of my comments to the Parliamentary Ombudsman must have scared them off their scandalous redacting of various elements of my last Ofcom consultation response (which they just did but didn't even consult me about or offer any explanation for). >:(

Title: Re: Ofcom 070 review
Post by Dave on Jan 21st, 2009 at 2:45pm

NGMsGhost wrote on Jan 21st, 2009 at 2:17pm:
BT's response is interesting as they claim it would be disproportionate to bring 06 in to operation for this PNS use but then propose that 070 call recipients should be paying most or all of the higher call charges for the benefits they are receiving from the call redirection (instead of the caller). ...

That's interesting. So BT is actually in support of discontinuing so-called "personal numbers" and you support BT in this view!

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 21st, 2009 at 3:28pm

Dave wrote on Jan 21st, 2009 at 2:45pm:
That's interesting. So BT is actually in support of discontinuing so-called "personal numbers" and you support BT in this view!


No you are incorrect in your supposition here.

I believe PNS numbers should preferably be moved to 09 or failing that to 06 if their present level of high charging is retained.  Whereas BT are utterly opposed to the opening up of the 06 number range for this use and also are not in favour of altering the number range from 070, despite the clear cut potential for confusion with a mobile number.

BT's solution is to leave 070 numbers where they are but to get the call recipient to pay either all the additional cost (above geographic rates) or alternatively that the caller should only pay some of the additional cost and that the recipient should pay the rest of the additional cost (i.e its no longer a free lunch for the call recipient).

Personally I think BT are rather confused as if the recipient pays all the extra routing cost then the use is just the same as an 03 number but if the caller pays some of the cost and the recipient pays some of the cost then this is different from 03.  My view would remain that these numbers should then move to 06 or 09 in a shared cost scenario.

So whilst I am pleased that BT have made it clear that they in principle oppose the caller paying for benefits that mainly accrue to the called party I do not support the rest of their proposals.

I am shocked that no other longstanding members of this campaign has apparently responded to this consulation in view of the longstanding opposition of members of the campaign to both the 070 Patientline style abuses and the 070 callback scams to mobile phone numbers.  However I think most of the blame for this can be laid at the door of the website's management team who did not publicise the consultation on the forum home page.  By contrast Flextel and co have been hard at work lobbying their 070 users to make anonymous responses supporting Ofcom's 070 proposals to retains 070 numbers almost wholly unaltered. >:(

Title: Re: Ofcom 070 review
Post by kasg on Jan 21st, 2009 at 5:06pm
I've only just seen this and also had no idea that a consultation on 070 numbers was in progress (was being the operative word). I think it is outrageous that Ofcom is prepared to let this range continue and had no idea that the 06 migration proposal had been quietly dropped. 99% of people must think these are mobile numbers and the whole thing is an obvious front for scams. If they are supposed to be personal follow-me anywhere numbers, how come businesses like Saints transport are allowed to use them? I see their lorries with 07000 SAINTS plastered all over them on every motorway journey.

Title: Re: Ofcom 070 review
Post by irrelevant on Jan 21st, 2009 at 5:49pm
My first encounter with 070's was when they were still new: a customer used an 0700 number - I initially thought they were freehone like 0500 and 0800 !

Whilst I brought the review to the attention of this forum with my posting of Flextel's email, I'm afraid to say I didn't put in a response myself to this one.  A combination of lack of available time to construct a coherant response and a tight deadline was the main reason, plus knowing that they are a rip off and never calling such numbers, I perhaps didn't give it as high a priority as it may have deserved.

Title: Re: Ofcom 070 review
Post by Stoday on Jan 21st, 2009 at 10:20pm
I rarely post on this forum, but I did respond to this consulation.  I'm one of the "name withheld" responses but I've no idea which one.

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 22nd, 2009 at 12:29am

Stoday wrote on Jan 21st, 2009 at 10:20pm:
I rarely post on this forum, but I did respond to this consulation.  I'm one of the "name withheld" responses but I've no idea which one.


Its good to hear that I was not completely alone amongst the members of this forum in responding.

As to which Name Withheld I'm sure you would recognise your submission if you clicked Name Withheld enough times.  Also I would hope it is one of only four or five Name Withhelds opposing the Ofcom proposals rather than one of the many Name Withheld responses solicited by Flextel from their 070 customers saying things such as you have an 070 numbers engraved on the collars of your five pet dogs and will be gravely inconvenienced if you have to make up new labels for them (you think I'm kidding but this guy was for real, although he is in fact a named respondent).

Is there any particular reason you don't post on the forum here more often?

Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 22nd, 2009 at 12:41am

irrelevant wrote on Jan 21st, 2009 at 5:49pm:
Whilst I brought the review to the attention of this forum with my posting of Flextel's email, I'm afraid to say I didn't put in a response myself to this one.


You have a lot to answer for then in not bothering to put in a response yourself while having made me stay up till 4am writing my response on the night after the 070 consultation officially closed (perhaps in line with their generally laissez faire approach to life Ofcom routinely accept responses to consultations submitted up to 9am the following morning after the day of closure and often for 2 or 3 days more after that).  I suppose you were relying on someone like me who felt strongly to do the job for you.  But I can't understand members of this forum not feeling strongly about 070 when it is home to one of the biggest covert premium rate abuses of the lot - namely ripoff bedside hospital phone lines.

I am particularly disappointed to learn that even Dave and also SilentCallsVictim (the latter normally always assuring us that it is vital to respond to all relevant Ofcom consultations and also being the self appointed head of the anti NHS telco ripoffs campaign) did not bother to make the effort to respond on this matter.

There is no excuse for the fact that the Home Page of this website was not used to encourage responses to the consultation in the couple of weeks up to its closure date. >:(

Title: Re: Ofcom 070 review
Post by idb on Jan 22nd, 2009 at 2:19am
This is an interesting one:

http://www.ofcom.org.uk/consult/condocs/070options/responses/VirginMediaLtd.pdf

Header: Confidential

Cover page:

CONFIDENTIALITY
What do you want Ofcom to keep confidential?

Nothing Name/contact details/job title
Whole response X
Organisation
Part of the response
If there is no separate annex, which parts?

And then, it appears that the document is published in its entirety!

Good old Ofcom - a wonderful waste of one hundred and thirty three million pounds.

I expect this response will disappear tomorrow, so if you want to read it, you need to be quick.

Title: Re: Ofcom 070 review
Post by SilentCallsVictim on Jan 22nd, 2009 at 2:20am
For the record.

I have encouraged members who may wish to do so to take various actions, if I feel that this would be useful. I have never criticised, nor encouraged, inaction. I note that some members have often expressed their feelings about the pointlessness of responding to Ofcom consultations, although I cannot recall anyone being incited not to respond.

We must each do what we each feel is making the best use of our available time. I hope that none of us feels the need to justify their decisions to others. We may need to defend our views and opinions in argument in the forum, but answering for our behaviour is a quite separate matter.

False modesty prevents me from ever trying to take credit for mine  ;). Maybe that should grant me some immunity from criticism.

On the specific issue, I will try to help by commenting in general terms. My limited time and limited mental capacity cause me to focus on only a few issues. Those on which I focus have demanded a lot of time recently, whereas on other occassions I may have broadened my scope.

I also direct my efforts to matters where I feel that I can make a difference, regardless of the importance of the issue. I do not pretend that this is a particularly worthy approach, however I am not seeking moral brownie points, but achievement of objective results.

Title: Re: Ofcom 070 review
Post by SilentCallsVictim on Jan 22nd, 2009 at 2:25am

idb wrote on Jan 22nd, 2009 at 2:19am:
I expect this response will disappear tomorrow, so if you want to read it, you need to be quick.
Someone may like to take a copy and release serialised extracts (suitably redacted to avoid compromising a desire for anonymity).

Title: Re: Ofcom 070 review
Post by idb on Jan 22nd, 2009 at 2:27am

idb wrote on Jan 22nd, 2009 at 2:19am:
This is an interesting one:

http://www.ofcom.org.uk/consult/condocs/070options/responses/VirginMediaLtd.pdf

Header: Confidential

Cover page:

CONFIDENTIALITY
What do you want Ofcom to keep confidential?

Nothing Name/contact details/job title
Whole response X
[...]


including:

Question 7: Should services provided by, for example, Hospedia, Premier Telesolutions and Trader Media be provided on an alternative number range to 070? Please provide any evidence to support your views.

While we accept that the scope of services run by organisations such as Hospedia and Trader Media deviate somewhat from the original concept of personal numbering services, we do not currently believe that they should be required to be provided via alternative number ranges. These services are established and recognised by consumers and to migrate them to alternative ranges outside of the personal numbering environment at the present time would, to Virgin Media’s mind, serve only to cause disruption and consumer confusion.

Question 8: Do you agree that Ofcom should withdraw formally the requirement for pre-call announcements on 070 Personal Numbers?

Virgin Media strongly supports the proposed removal of the requirement for pre-call announcements. Given the risk to human life and property that would exist should the requirement remain in force, we believe that its removal is a necessity and that the case for prescribing such action is self-evident.

We recognise, of course, that the emergence of the potential for life-threatening scenarios to occur has understandably been the over-riding influence leading to Ofcom’s proposed decision on the matter. However, we do believe that the removal of the requirement to provide pre-call announcements will have secondary benefits for all parties concerned. As set out in our response to the various NTS policy reform consultations and indeed the recent numbering consultation, we believe that such a requirement would be unduly onerous, complex and costly for originating CPs. Furthermore, the mandated use of pre-call announcements would be disruptive for terminating CPs, service providers and consumers and overall represents a disproportionate remedy. Notwithstanding the risk to human life and property inherent in the pre-call announcement requirement, we believe that the extension of the scope of the GC14 obligations constitutes a far more appropriate and proportionate solution to price transparency issues.

Title: Re: Ofcom 070 review
Post by idb on Jan 22nd, 2009 at 2:31am
Question 4: Do you agree that Ofcom should require OCPs to give greater prominence to the cost of calling 070 numbers in published price lists and promotional material?

We generally welcome Ofcom’s proposals to give greater prominence to the cost of calling 070 numbers. As a consumer focussed organisation, Virgin Media takes its consumer interest and information obligations very seriously. Given the level of scams that have hitherto prevailed in the personal numbering environment, Virgin Media believes that consumer protection should be at the forefront of Ofcom’s objectives in undertaking this review. As such, we consider that the requirement for OCPs to afford greater prominence to 070 call charge information should be a constituent part of a wider package that also includes additional obligations on PNS providers - for example the requirement to undertake due diligence as per Ofcom’s proposed ‘Option 4’ in the consultation document. We therefore support the proposed extension of GC14 to encompass personal numbering services, on the basis that it is applied in parallel to extended obligations on PNS providers to undertake due diligence etc in accordance with the PhonepayPlus Code of Practice.

Furthermore, in extending the scope of GC14 we encourage Ofcom to ensure that originating CPs’ responsibilities are both proportionate and absolutely clear. Absence of ambiguity and scope for interpretation should be a key tenet of the establishment of any tariff transparency obligations – and to this extent we believe that the provision of examples and specific guidance would be beneficial to all stakeholders. For example, the proposed amendments to Annex 2 to General Condition 14 includes, at paragraph 3.2, a requirement on OCPs to ‘give prominence’ to certain pieces of information. By the same token, paragraph 4.2 obliges OCPs to provide ‘a clear reference’ as to where on websites and published price lists certain information can be found and paragraph 4.3 requires OCPs to include a ‘prominent statement’ indicating whether or not prices for call packages include calls to personal numbers. While we absolutely endorse the philosophy that Ofcom is attempting to foster within this Condition, we do believe that the terminology used has the potential to be interpreted in a number of ways and exposes the Condition to subjectivity. We suggest, therefore, that Ofcom provides a clearer set of guidelines or examples against which OCPs can develop and assess their compliance with the regulatory requirements.

Question 2: Do you agree that the costs outweigh the benefits in relation to closing the 070 number range and migrating users to an alternative range?

Virgin Media generally agrees that the costs of closing the 070 number range and migrating users to an alternative range would outweigh any benefit achieved. As Ofcom has identified, the costs to end users, service providers and indeed originating CPs would be substantial – and we believe that this would be the case irrespective of whether a completely new range was utilised or if the services were subsumed within an existing alternative range. Further, we believe that such migration would generate significant operational disruption, as well as potentially introducing additional inconsistencies to Ofcom’s objectives for number range/service transparency.
While personal numbering services are, in respect of service classification, perhaps not a ‘perfect fit’ alongside mobile numbers within the 07 range, Virgin Media is of the view that they reside more appropriately within this range than in certain of the alternatives proposed by Ofcom. That they have existed as a sub-range of 07 for a number of years, together with the absence of any conclusive proof of consumer confusion between 070 and mobile numbers constitutes, we believe, a strong argument to maintain the existing numbering arrangement. On this basis, and taking into account the perceived disruption and costs that would result from migration, we believe that migrating personal numbering services to an alternative number range at this time would be both impracticable and disproportionate.

Irrespective of which range ultimately supports personal numbering services, we believe that usage and application of the services should be closely monitored, with a view to undertaking further reviews of the situation as appropriate in the future.

Title: Re: Ofcom 070 review
Post by idb on Jan 22nd, 2009 at 2:49am

SilentCallsVictim wrote on Jan 22nd, 2009 at 2:20am:
[...]We must each do what we each feel is making the best use of our available time. I hope that none of us feels the need to justify their decisions to others. We may need to defend our views and opinions in argument in the forum, but answering for our behaviour is a quite separate matter. [...]
Fully agree with this. Contributors have distinct talents - some able to track down alternative numbers, some adept at searching for information, others with lobbying skills, and others with in-depth technical know-how.

Title: Re: Ofcom 070 review
Post by irrelevant on Jan 22nd, 2009 at 10:23am

NGMsGhost wrote on Jan 22nd, 2009 at 12:41am:
You have a lot to answer for then in not bothering to put in a response yourself while having made me stay up till 4am writing my response on the night after the 070 consultation officially closed (perhaps in line with their generally laissez faire approach to life Ofcom routinely accept responses to consultations submitted up to 9am the following morning after the day of closure and often for 2 or 3 days more after that).  I suppose you were relying on someone like me who felt strongly to do the job for you.  But I can't understand members of this forum not feeling strongly about 070 when it is home to one of the biggest covert premium rate abuses of the lot - namely ripoff bedside hospital phone lines.


I was fully intending to respond, but I don't have as much spare time as I would like, and it basically slipped my mind.  If I'd know about it a little more in advance, I would probably have done so.  I did respond to the 116 and DH 0844 consultations, and I do to other non-telecoms consutations occasionally.  I did, hower, recognise it's relevance to members of this forum when I got the email from Flextel, and afer checking to see if it had already been mentioned, create this topic.
If you choose to stay up until 4am formulating your response, then it's not really my problem, although I do commend your dedication, and I do recognise the sterling work you do generally in relation to the cause.  Most of my contributions to this forum are of a more technical nature, or trying to find alternates for people: My strengths are not in the campaigning field, and writing detailed responses are not second nature to me.  I also don't wish to get into personal arguments, so let's leave it there, eh?


Title: Re: Ofcom 070 review
Post by NGMsGhost on Jan 22nd, 2009 at 11:26am

irrelevant wrote on Jan 22nd, 2009 at 10:23am:
If you choose to stay up until 4am formulating your response, then it's not really my problem, although I do commend your dedication, and I do recognise the sterling work you do generally in relation to the cause.   I also don't wish to get into personal arguments, so let's leave it there, eh?


Sorry I should have a put a few winking smilies etc in to my previous post.

In reality I only didn't finish the response till 4am because I didn't start it till 1am.  I only had just over 24 hours and was staying with a relative at that stage so couldn't get down to it earlier in the evening.  I knew I would write a fair bit once I started and I always find having to deal with responding to Ofcom consultations a cause of usually acute pain (mainly because I know in advance that they will completely ignore me and side with all the telcos) usually only relieved by biting back at the beast that has caused that pain.

Only when I was about to miss my chance altogether could I finally bring myself to do it.  As I used the online form to submit it (rather than an email) and the online form still presented itself at that hour (it did not say consultation closed) I knew my comments would be accepted.  I did of course cut and paste them all in to a Word document before pressing the Submit button when they might possibly have disappeared in a puff of electronic smoke.

I do feel 070 are an especially glaring example of a number allocation intended in advance for misuse but then so are 0871 and 0844 for that matter as they were only given those allocations to quite deliberately cause the mis-association with the once local rate and national rate (at least for customers making calls with BT) 0845 and 0870 codes.  OFTEL and Ofcom's game plan for the last 10+ years always seems to have been to create a telephone numbering system that creates the maximum possible scope for misselling to and total incomprehension by the UK citizen consumer.  :o >:( [smiley=thumbdown.gif]

Title: Re: Ofcom 070 review
Post by Stoday on Jan 23rd, 2009 at 3:26am

NGMsGhost wrote on Jan 22nd, 2009 at 12:29am:
As to which Name Withheld I'm sure you would recognise your submission if you clicked Name Withheld enough times.  


I started. After reading 2 or 3 I decided I'd prefer waterboarding at Guantanamo.


Quote:
Also I would hope it is one of only four or five Name Withhelds opposing the Ofcom proposals


Of course it was. I had no idea there were so few in opposition. Oh dear!


Quote:
Is there any particular reason you don't post on the forum here more often?


I don't have anything to say!

Title: Re: Ofcom 070 review
Post by idb on Feb 5th, 2009 at 3:44am

idb wrote on Jan 22nd, 2009 at 2:19am:
This is an interesting one:

http://www.ofcom.org.uk/consult/condocs/070options/responses/VirginMediaLtd.pdf

Header: Confidential

Cover page:

CONFIDENTIALITY
What do you want Ofcom to keep confidential?

Nothing Name/contact details/job title
Whole response X
Organisation
Part of the response
If there is no separate annex, which parts?

And then, it appears that the document is published in its entirety!

Good old Ofcom - a wonderful waste of one hundred and thirty three million pounds.

I expect this response will disappear tomorrow, so if you want to read it, you need to be quick.
As predicted, this has now been removed!

Title: Re: Ofcom 070 review
Post by sherbert on Feb 5th, 2009 at 8:48am

idb wrote on Feb 5th, 2009 at 3:44am:

idb wrote on Jan 22nd, 2009 at 2:19am:


I expect this response will disappear tomorrow, so if you want to read it, you need to be quick.
As predicted, this has now been removed!


Yup, it has gone! :(

Title: Re: Ofcom 070 review
Post by kasg on Feb 27th, 2009 at 11:31am
Statement issued today:

http://www.ofcom.org.uk/consult/condocs/070options/statement/

Looks like Ofcom has decided that everything is fine now. That's all right then.

Title: Ofcom Ignores All 070 Consultation Responses
Post by NGMsGhost on Feb 27th, 2009 at 11:42am
So its official then.

Responding to any Ofcom consultation is only a way of putting one's criticism of Ofcom's proposals on the public record but Ofcom never ever takes any notice whatsoever of consultation responses and instead always ploughs on utterly regardless with its original proposals in the consultation. :o >:( [smiley=thumbdown.gif] [smiley=thumbdown.gif] [smiley=thumbdown.gif]

It can of course however throw its own proposals in the dustbin or reverse them whenever it feels like it or it receives instructions from government ministers to do so. >:( >:( >:(

Yet they still have the nerve to say in their Statement on 070 that:-


Quote:
1.4 We consulted on our proposals on 15 October 2008. We have taken into account responses received as well as updated complaints data in finalising our analysis

Title: Re: Ofcom 070 review
Post by SilentCallsVictim on Feb 27th, 2009 at 12:05pm

kasg wrote on Feb 27th, 2009 at 11:31am:
Statement issued today:

http://www.ofcom.org.uk/consult/condocs/070options/statement/

Looks like Ofcom has decided that everything is fine now. That's all right then.

It clearly is not, however I would offer some advice to those who see this as an important area for campaigning activity.

The Ofcom policy is now set; it may be vigorously criticised, however it will not be changed in the near future.

It would seem to me that the focus should now be on public awareness. Firstly, to avoid the misunderstanding that 070 numbers are charged at the same rate as calls to mobiles. Secondly, the identified abusers with public reputations need to be exposed publicly.

Ofcom's reliance on raw complaints data is a classic example of the mis-application of the principles of consumerism. Consumerism relies on every participant in the market playing their part. It thereby totally ignores the situation of those who are scammed, misled or otherwise caused detriment but do not see the need, or are unaware of how, to make a formal complaint. The classic example of this is using monthly figures on the assumption that those who have sufffered, complained and found that nothing happens will continue to register new complaints every month whilst they continue to suffer.

Total success is rarely possible. Those who wish to make progress on this issue may consider trying to get media involvement. I will be happy to help in any way I can.


NGMsGhost wrote on Feb 27th, 2009 at 11:42am:
Responding to any Ofcom consultation is only a way of putting one's criticism of Ofcom's proposals on the public record but Ofcom never ever takes any notice whatsoever of consultation responses and instead always ploughs on utterly regardless with its original proposals in the consultation.

This is a fair point, which may be applied to any form of public "consultation". This is a device used by those who have the responsibility of setting policy to check for any howling errors and to prepare a defence against subsequent criticism. It is also a way of giving notice to those who will be required to comply with policy once it is implemented.

Title: Re: Ofcom 070 review
Post by bbb_uk on Feb 27th, 2009 at 1:45pm

Quote:
1.6 We have decided to impose a number of other measures which we consider more appropriate in light of the detriment that currently exists:

* support and monitor the current enforcement programme being carried out by PhonepayPlus. Since May 2008 PhonepayPlus has made 10 adjudications relating to 070 numbers with fines totalling £625,000 and this activity appears to have had a significant impact on 070 complaints;

* require originating communications providers to publish their tariffs for calls to 070 numbers more prominently and to make them easier to understand for consumers, thereby improving the level of pricing transparency associated with 070 numbers;...
I have never heard so much crap in my life.  They cant even effectively enforce GC14.2 with regards to ensuring OCPs make sure 08x prices are more prominent.

I cant take anymore of OfcoN.  They refuse to enforce their own regulations/conditions effectively.  They, most of the time, refuse to investigate/enforce any complaint ordinary consumers have.  However, when a "stakeholder" has a problem, they are all ears and investigate without hesitation.  They have a habit of doing u-turns on anything that might actually benefit ordinary consumers as soon as a "stakeholder" makes a complaint.

In my opinion, I have yet to see any evidence that OfcoN are "independent" regulators!

Title: Re: Ofcom 070 review
Post by NGMsGhost on Feb 27th, 2009 at 4:07pm

bbb_uk wrote on Feb 27th, 2009 at 1:45pm:
In my opinion, I have yet to see any evidence that OfcoN are "independent" regulators!


They seem to suffer from precisely the same "jobs for the boys" syndrome that we are now seeing the appalling consequences of with the Financial Services Authority. :o >:( :'(

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