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-lin...) 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/advic...), 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.

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.