Review of quality of service information

Executive Summary

Summary

Introduction

1.1 This consultation represents the beginning of the first phase of Ofcom’s review of quality of service information.

1.2 It looks at the provision of customer service information in the fixed voice, mobile and broadband markets. It does not consider technical or network quality of service information on these services. However these areas remain very important to Ofcom and will form the future phases of our review of quality of service information.

Ofcom’s approach to consumer information

1.3 We believe that consumer information plays a critical role in competitive markets. Markets work best when consumers are fully informed about what they are buying. Without this, consumers may make incorrect decisions and be reluctant to switch.

1.4 However, some consumers do not find it easy to make informed decisions and compare services. This may be because appropriate information does not exist. It might also be because the information they are presented with is complex, not easy to interpret and in a number of different places. Where this is the case, there may be a role for Ofcom in supporting consumers in their decision-making to help them make effective choices.

Quality of service information

1.5 In a competitive market there are clear incentives for providers with good customer service to let consumers know about this. But there is little economic incentive for providers with poor customer service to produce accessible and comparable quality of service information.

1.6 National regulatory authorities are able to require publication of such information where it is demonstrated that such information is not effectively available to the public

1.7 While charges and affordability dominate the reasons given for switching, service also features as a reason for a significant minority of those who have considered switching. Indeed customer service may represent a reason for dissatisfaction across the fixed voice (35%), mobile (28%) and broadband (48%) markets. We are conducting research to understand better the importance of customer service to consumers.

1.8 However we know that consumers find it more difficult to compare quality of service than the price of service and that many consumers would use service information if they were to change communications provider .

Scope of this consultation

1.9 In January 2005 Ofcom issued a Direction (the “QoS Direction”) on the provision of Quality of Service (‘QoS’) information. It requires certain fixed voice providers to publish defined quality of service information for residential and business customers. These providers have been responsible for the way in which the QoS Direction has been implemented and have established the industry body known as the TopComm Forum (‘the Forum’) to carry out this work. The 2005 Statement recognised the industry’s role in developing this scheme.

1.10 The aim of the information published by the Forum is to enable consumers to make informed decisions on which supplier to use. Now that the scheme has been running for a couple of years, we are able to consider whether any improvements should be made.

1.11 This consultation sets out Ofcom’s current thinking on the existing regulation. We consider whether we should have a regime for reporting quality of service information and if so, whether the existing regime could be improved to make quality of service information more useful to consumers, make the data more robust and make more consumers aware that it exists.

1.12 We strongly encourage all stakeholders to comment on and provide evidence in relation to this consultation.

Should the scope of the existing QoS Direction be amended? (Section 4)

1.13 The existing QoS Direction requires certain fixed voice providers to publish specified QoS parameters on an independent website. Ofcom is considering whether this requirement remains appropriate.

1.14 Without a QoS direction in place the market may not be effective in providing objective, comparable customer service information on its own terms. Keeping the requirement would mean consumers could continue to benefit by being able to make informed decisions about the services they buy. This would allow them to make their preferred trade-offs between quality of customer service and price, and the increased competitive pressure could drive up standards generally.

1.15 However there is a cost associated with collecting and publishing information on quality of customer service and usage of the current information has been very low.

1.16 We are consulting on whether to keep or remove the existing QoS Direction.

1.17 If we considered it was appropriate to continue requiring providers to publish QoS information we would need to consider whether there was any need to change the existing QoS Direction.

1.18 Keeping the QoS Direction as it is would not change the cost to industry of publishing the information. However we have identified various areas where the existing scheme is not working as effectively as is appropriate and considered whether these could be addressed by amending or replacing the existing Direction.

1.19 For example, we could:

1.19.1 consider expanding the scheme to include more services (not just fixed voice);

1.19.2 consider revising the threshold for providers required to publish information;

1.19.3 review the existing reporting requirements to ensure the information that is published is the most useful and relevant to consumers;

1.19.4 consider whether the existing processes for data verification could be improved; and

1.19.5 consider alternative ways to promote awareness of the information amongst consumers.

1.20 If after consultation and further research it appears that the existing regulation should be withdrawn or if there appear to be no problems with the existing regime, many of the options set out in this consultation will no longer be relevant. However in order properly to understand the costs and benefits of any reporting regime, it is necessary to consider how it could look.

1.21 We are therefore consulting on various options to amend the existing QoS Direction, should we consider the reporting requirements remain appropriate.

1.22 We are asking stakeholders for their views on the options we present, and for evidence on the ease and cost of implementing them.

What information should be published? (Section 5)

1.23 If we considered it was appropriate to continue requiring providers to publish QoS information, we could consider how the information should be defined and whether the existing parameters best reflect consumers’ experience of communications services and the types of quality of service information which may influence their choices.

1.24 We are consulting on whether providers should be left to draft and maintain the definitions of each parameter or whether Ofcom could incorporate them into any direction.

1.25 Besides considering how the required information should be defined, we would need to consider whether the information currently being published was and would remain useful and relevant to consumers in proportion to the costs required to collect it.

1.26 We are consulting on whether to remove, keep or replace the existing parameters. Our options include removing, keeping or introducing parameters on the following customer service issues;

1.26.1 How long it takes for a customer to receive a service

1.26.2 Total complaints

1.26.3 How long it takes to resolve a complaint

1.26.4 Total complaints about faults

1.26.5 How long it takes to resolve a complaint about a fault

1.26.6 Complaints about billing accuracy

1.26.7 How long it takes to answer a customer’s call

1.27 If we considered it was appropriate to continue requiring providers to publish QoS information – and that the existing QoS Direction should be amended – we would also need to consider who the information should be aimed at.

1.28 We are consulting on whether providers should continue to provide information to large business, small business and residential consumers. We also consider how these groups could be distinguished.

How could any information be verified? (Section 6)

1.29 The aim of TopComm is to help fixed line telecoms customers to make informed decisions on which supplier to use. For this reason, the information provided must be an accurate and fair basis for comparison.

1.30 In order for consumers to have confidence in the information that is published, we must be sure that the information has been sufficiently verified. It is also important that providers participating in the scheme are assured that their services are compared fairly with their competitors.

1.31 As such, Ofcom believes that there is a common goal for ensuring that accuracy and comparability is achieved.

1.32 If we considered it was appropriate to continue requiring providers to publish QoS information we could review the way that the information is currently verified and consider whether any changes should be made to the existing processes.

1.33 Responsibility for determining the requirements of the audit process currently rests with the Forum. Under the current industry scheme, the quality of service information supplied by providers is subject to a two stage audit process – the first by an internal auditor and the second by an independent auditor.

1.34 We are consulting on whether providers should be left to determine whether there is a verification process or whether there is a role for Ofcom to formalise the audit requirements. We are also consulting on whether a two stage audit process remains appropriate.

1.35 If we considered the two stage audit process was appropriate we could review the existing processes and consider whether they could be improved. We put forward further options for keeping the existing processes or making them more robust. These options take into account providers’ ability to gather accurate information; the frequency of audits; the frequency of data submission; and the number of site visits made by the auditors.

1.36 If we considered it was appropriate to audit the data independently and reflect this role in a QoS Direction, we could consider how the position was appointed and whether one or multiple auditors were best placed to carry out the tasks required.

1.37 We are consulting on whether providers should appoint their own independent auditor, whether Ofcom should have the power to veto any appointment or specify which auditor(s) providers may appoint. We are also consulting on whether Ofcom should ensure that providers all appoint the same independent auditor or whether this decision should be left to providers.

How could any information be published and promoted? (Section 7)

1.38 If we considered appropriate regulatory intervention was required to make sure consumers can access adequate and reliable information on quality of service, and ensure a healthy level of competition in communications markets, we would need to consider the manner in which the information was published and how it was promoted.

1.39 We are consulting on how frequently and in what format any information could be published. We are also asking for stakeholders’ views on how the information could be made more accessible to disabled consumers and those without internet access.

1.40 Consumer awareness of the TopComm website is currently low. This is reflected in low usage numbers. We could enhance the publicity of the scheme so that more consumers, consumer stakeholders and journalists were aware it was available and so the scheme became a more significant benchmarking tool for the industry. We are consulting on various methods to raise the profile of the scheme and welcome stakeholders’ views on what would be most effective.

1.41 We also welcome stakeholders’ views on whether ‘TopComm’ is a good branding name for the information to be published under. Is it something that consumers are likely to recognise and understand or are there alternatives that should be considered?