I've noticed that a few 0845 numbers linger on for automated council service such as telephone payments or library book renewals.

With this in mind, I've just sent off a complaint to my local council, Cheshire West. Will update with an outcome at some point, but in the meantime I thought I'd post a copy of my complaint here in case anybody living in any other council area is thinking of tackling their local authority and would like to use it as a template.

Complaint split into two parts, to fit the council's online form:-


Quote:

What is your complaint? I am concerned that the council persists in using a premium rate, 0845 phone number for its library service's automated renewal line. I believe that this is an inappropriate use of an 0845 number and that the council is breaching various guidelines relating to the use of such numbers. To provide some context, it should be noted that calls to the council on 01244 or 0300 numbers will typically be included in people's existing call allowances at no extra cost or cost only a trivial amount of money to call, whereas an 0845 number will typically be charged at a minimum of 11p per minute from a landline or 45p to 55p per minute from a mobile phone. This is not a matter of consumers picking the wrong phone company or tariff; 0845 calls are universally charged at higher rates due to the inclusion of a service charge that benefits the call recipient (i.e. you) or their telecoms provider. In other words, your choice to use an 0845 number directly places an unavoidable additional cost burden on virtually anybody who needs to call you. I believe that it is inappropriate for the council to be providing any public services through telephone numbers that impose a surcharge on callers – it is morally wrong to impose extra charges on your service users and would seem in conflict with your duties to provide a service that is free at point of use. Indeed, the Cabinet Office has issued explicit guidance to all public bodies (https://www.gov.uk/government/publications/hmg-guidance-for-customer-service-lines) that only standard rate (01, 02 or 03) numbers or freephone (0800 or 0808) numbers should be used for most services. The use of 0845 numbers is also potentially of concern in terms of equality of access to your services. Your telephone number is most likely to be called by those without home internet access – typically individuals who are elderly or socially disadvantaged. Accordingly, I would argue that you are potentially placing an unfair cost on such social groups. Furthermore, I would draw your attention to the fact that those who are most socially disadvantaged are likely to be reliant on mobile phones with no access to landlines - but calls to your 0845 numbers cost a minimum of 45p per minute from the major mobile phone providers. Also of concern is that you are failing to comply with the clear and specific rules put in place by Ofcom (https://www.ofcom.org.uk/phones-telecoms-and-internet/advice-for-consumers/advice/uk-calling/uk-calling-for-businesses), and the CAP and ASA (https://www.asa.org.uk/advice-online/non-geographic-call-charges.html) that require you to clearly state the applicable call charges alongside your 0845 number wherever it is published. For the avoidance of doubt, it is a requirement that every time you display your 0845 number you must include an unambiguous pricing statement, typically in the format: “Calls costs 5p per minute, plus your phone company's access charge”. I note that while your 0845 number is widely publicised  on your web pages, in your online library catalogue and on various corporate and locally-produced publicity materials, it is never accompanied by the required pricing statement. Ideally, what would you like us to do? 1. In the interim, to provide a clear pricing statement everywhere you publicise your 0845 number. This has been a requirement for well over two years, so the fact that the statement is missing from your website and recently-produced publicity materials is inexcusable. 2. To urgently consult with the provider of your automated renewals service about transitioning to a compliant and sensibly priced alternative number. This should be a normal geographic number (e.g. 01244, 020, etc.) or a number charged at the same rate (e.g. 0300, 0333, 0345, etc.) 3. If you feel in a position to argue that the use of a premium rate 0845 number is appropriate, to publish the justification for this and communicate it with service users. Thank you in advance for your attention and your prompt action in resolving what I hope is simply an unfortunate oversight on the council's part.

Welcome NumbeMoose  :)

While your dealing with them you might like to ask them why here 

https://www.cheshirewestandchester.gov.uk/residents/contact-us/out-of-hours-emergency-contact.aspx

under Household Emergencies  United Utilities (Water Supply) , they promote 0845 746 2200 which is not United Utilities correct number and is in fact a scam contact number supplied by http://contactnumbersfor.co.uk/united-utilities-customer-service-helpline/   :o

The correct number to call is 0345 672 3723

see https://www.unitedutilities.com/help-and-support/contact-us/

Also the correct non emergency number to contact Cheshire police on is 101 or  01244 350000  if the caller needs to call a geographical number not the old 0845 one they quote.

That template letter is excellent and covers all the necessary points.

You may, however, wish to consider some alternative URLs for the Ofcom and ASA information.
- https://www.ofcom.org.uk/phones-telecoms-and-internet/advice-for-consumers/advice/uk-calling/uk-calling-for-businesses
- https://www.cap.org.uk/Advice-Training-on-the-rules/Advice-Online-Database/Chargeable-08-numbers-General.aspx
Of course, if Devon County Council get rid of their 0845 numbers, as they should, the information on declaring call charges is irrelevant.

It may be worthwhile pointing out that the simplest migration available to users of 084 and 087 numbers is to the exactly matching 034 or 037 number. Ofcom made these 03 ranges available for this purpose in 2007. This migration is simple to advertise to callers - the leading 08 is changed to 03. Government departments and charities also have the option to choose a completely new 030 number.


Good spot on the ICSS scam number being promoted . That certainly needs fixing.

bigjohn wrote on Apr 17^th, 2017 at 7:08pm:

Welcome NumbeMoose  :) While your dealing with them you might like to ask them why [...] under Household Emergencies  United Utilities (Water Supply) , they promote 0845 746 2200 which is not United Utilities correct number and is in fact a scam contact number.

Thanks!

One good thing Cheshire West do is include a feedback form on each of their webpages. I've sent them a nudge about this and some other old numbers in this way.

Goodness knows why councils are so keen to make a rod for their own back by republishing information like this and getting it wrong or letting it go out of date. Don't understand why they don't just provide links to the relevant organisations' websites so people can find out what they need first hand!

Ian01 wrote on Apr 17^th, 2017 at 9:12pm:

That template letter is excellent and covers all the necessary points. You may, however, wish to consider some alternative URLs for the Ofcom and ASA information.

Thanks. ASA do seem to gloss over 084 and concentrate on 087 / 09, but both useful for future communications!

Is it just me, or is Ofcom's advice on this area somewhat lacking? The new charging regime they set up relies on organisations publishing service charges - but there's very little guidance for organisations about what they should be doing on the Ofcom website, no guide to business numbering, etc. Just seems to be buried, repurposed content from their rather lacklustre UK Calling campaign.

NumberMoose wrote on Apr 17^th, 2017 at 11:29pm:

Thanks. ASA do seem to gloss over 084 and concentrate on 087 / 09, but both useful for future communications!

Thanks for the warning. It seems that ASA have re-arranged their website again.

I was trying to flag this item: http://web.archive.org/web/20160920004758/www.cap.org.uk/Advice-Training-on-the-rules/Advice-Online-Database/Chargeable-08-numbers-General.aspx but that URL now redirects to a completely different article.

(EDIT) It seems that article I was trying to flag is now here:
https://www.asa.org.uk/advice-online/non-geographic-call-charges.html
and is the one you already had.



NumberMoose wrote on Apr 17^th, 2017 at 11:29pm:

Is it just me, or is Ofcom's advice on this area somewhat lacking? The new charging regime they set up relies on organisations publishing service charges - but there's very little guidance for organisations about what they should be doing on the Ofcom website, no guide to business numbering, etc. Just seems to be buried, repurposed content from their rather lacklustre UK Calling campaign.

You are lucky to have those two pages on Ofcom's website. The UK Calling website ran for around nine months either side of 1 July 2015. When it closed, Ofcom initially had nothing to replace it. The suggestion to have basic information was accepted after good reasons were put forward.

The new pages are here...
https://www.ofcom.org.uk/phones-telecoms-and-internet/advice-for-consumers/advice/uk-calling
https://www.ofcom.org.uk/phones-telecoms-and-internet/advice-for-consumers/advice/uk-calling/uk-calling-for-businesses

Service Charges can be looked up here: http://checkit.uboss.com/

Whilst Ofcom and the ASA have no or weak (respectively) enforcement powers in respect of 084 numbers, the PSA is well able to deal with users of 087 and 09 numbers, albeit that, as in all cases, enforcement is complaint-driven.

In the case of 084 and 087 numbers the objective must be to persuade them to be abandoned, not least because the Access Charge benefit invariably exceeds the Service Charge.

A link to this document helps to point out why we describe those who use 084 and 087 numbers as "greedy and foolish", notwithstanding regulatory provisions and enforcement mechanisms.

It is very comforting to note that the number of offenders continues to fall, however we must keep up the pressure on the laggards.

I am pleased to note that it seems the council are now addressing this:


Quote:

Thank you for your feedback regarding the existing 0845 renewal number for Library Services. We currently put details of the renewal line costs on our monthly email and self-produced publicity. We will add the information to our website. We are currently in the process of transition to an 0300 number and intend to have the new number tested and live in July. I hope this reassures your concerns.

Another tiny step forward, hopefully...