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.

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



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

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...

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

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.

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...

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