3.30  Most respondents welcomed Ofcom’s consumer protection proposals and the creation of a code of practice, although there were mixed views as to who should implement it. One respondent however, felt there may already be sufficient pricing information available to consumers....

3.37  One SP respondent felt change was not required and consumers were already familiar with the numbering schemes in use. It was therefore unnecessary to provide further pricing information...

...Vodafone does wish to question the need, at this juncture, for the additional consumer protection measures contemplated by Ofcom in conjunction with this Option 2.  In general Vodafone suggests that Ofcom should keep in mind the research conducted under the banner of the Telecommunications Review. This demonstrates that, in the case of mobile, not only
are 80% of consumers either satisfied or very satisfied with their services but that “many consumers think that the amount of reliable available information available is about right” (in fact there are more people that say there is too much pricing information rather than too little).

More specifically, Vodafone submits that is no evidence that the current arrangements for retail NTS
charging cause any significant consumer harm (or that a move to option 2 will do so) or warrant additional measures to ‘protect’ customers. In fact, as Ofcom notes, “there is a very strong tendency for customers to over-estimate the cost of calling 0845 and 0870 numbers”. Ofcom’s evidence is that consumers over-estimate the cost of calling 0845 numbers by over 500% and the cost of calling 0870 numbers by nearly 300%. Customers who continue to make calls in these
circumstances can hardly be said to have come to any harm...