NGCS Communications Working Group – 20th July 2011, 12.30pm Ofcom
Attendees: Ben Carter (Virgin Media Chair), Andrew Wileman (Virgin Media), Ginnie Leatham (Virgin Media), Don Wilson (Vodafone), John Eccleston (Three), Joe Moore (BSkyB), Kath Embleton (BT), James Taqvi (BT), Graham Pottie (BT), Claire Marris (TalkTalk), Toby Jones (Colt), Justin Hornby (C&W Worldwide), Juliette Spenceley (C&W Worldwide), Kristie Blacklock (Daisy), Shirley Dent (PhonepayPlus), Sarah Icken (PhonepayPlus), Jacqui Brookes (FCS), Sue Eustace (Advertising Association), Nicholas Randel (Advertising Association), Michael Barford (118118), Robin Vernon (O2), Juan Lorenzo (TalkTalk), Simon Grossman (118118), Liz de Winton (Ofcom), Markham Sivak (Ofcom), Elizabeth Gannon (Ofcom), Matthew Walters (Ofcom).
Summary of specific ideas from the group
- A ladder to depict the numbering range
- A central website of charges
- Splitting out higher and lower cost business rate
- A logo for charitable donations
- Consulting with various other groups
- Alternative wording for access and service charges
Markham outlined the rationale for Ofcoms Strategic Review of Non-Geographic Call Services (NGCS). He noted that there was evidence of clear consumer confusion under the current system, which was being drive by a number of factors.
He also noted that Ofcom could not continue to impose regulation solely upon BT in the way it currently did in relation to these numbers. Therefore some kind of change to the current regulatory regime was necessary and inevitable.
Markham noted that Ofcoms current preference remained the unbundled option, with the ambition though undecided of a single access charge per package.
He noted Ofcom was continuing to build up its evidence base, for example, most recently through some behavioural economics research conducted in conjunction with London Economics, which Ofcom would seek to publish as soon as possible. He noted that the current aim was for Ofcom to publish a further consultation on its proposals towards the end of the year. He noted that the work from this group would help feed into those proposals.
Ofcom noted that its current review was restricted only to non-geographic numbers, specifically 03, 08, 09, 118 numbers (as well as a few other smaller ranges) and it had no intentions to widen that scope any further at the current time.
Terms of reference
The group agreed with the slides setting out the remit of the Communications Working Group. Markham noted that it was going to be important for the group to look beyond the regulatory debate and imagine what the world might look like under the different options, in particular how those would be communicated to consumers. He encouraged stakeholders to contact Ofcom to discuss any specific issues they had with the proposals on a bilateral basis if they wished to.
Some group members suggested that the group should also consider the likely cost of any proposals it formed, as well as how the ongoing maintenance of the new regime would be managed.
Jacqui Brookes suggested that the group, and Ofcom, could draw on the experience of major national number changes, which might help inform what had worked before and what might work for communicating these changes. It was suggested that the 118 regime change could perhaps form the basis of such an exploration.
A question was raised over what would happen if the group came to the conclusion that the communications challenges were too great. Elizabeth Gannon noted that any conclusions developed by the group would feed into Ofcoms next consultation on its proposals, along with a range of other evidence.
Some group members raised the issue of the cost to industry and the cost of implementation, in particular, whether this was something that Ofcom had considered, and whether Ofcom had a particular view on who would pay for communicating any changes. Don Wilson questioned whether the providers would be expected to maintain these costs on an ongoing basis. It was noted that it was difficult to produce a marketing plan without understanding the budget of communicating the potential changes.
Three raised the issue of whose responsibility it would be to communicate such messages the CPs or the SPs. They asked whether there would be new regulations around how pricing would be phrased in advertisements and bills. Ofcom noted that it expected that CPs and SPs would have different responsibilities in terms of what messages they would need to convey but both would likely be subject to some form of obligations. It noted, however, that these were issues which were still being actively considered and it was hoped that the work of the group would help inform those decisions.
Explaining different number ranges traffic light idea
Liz de Winton explained the rationale behind the idea of a potential traffic light system for the communicating of non-geographic numbers. She explained that there would be a set of standardised fonts and images, and a consistent categorisation of different number types. She noted that the images which had been presented were merely a proposal in order to encourage discussion and were not based on a definitive Ofcom view of how these numbers should be communicated.
Concerns were raised from several group members, including, PhonepayPlus and BT about Ofcoms the use of traffic light colours. The red for stop was considered a negative message to give to consumers and would not be favoured by industry. It was noted that the use of the colour red could put consumers off calling, which should not be the intention of the logos. PhonepayPlus also said it would be difficult to persuade industry to use signs.
It was also noted that reproducing a traffic light system in black and white in newspapers/magazines would be difficult, as would presenting them in radio advertising.
The Advertising Association noted that BCAP set rules surrounding advertisements on TV and radio for premium rate services, and that it would be useful to investigate how such rules could be incorporated into the new regime. They also noted that any additional information to be communicated would add length to advertisements, in particular radio ads, impacting upon the media, the consumer, and the advertiser. There was a suggestion that the logos might be mandated only to appear on TV ads, which was where they would be most useful.
There was some agreement that logos could be useful, as quick indication to consumers of the likely cost of the call, particularly if they did not read the accompanying text and it could act as a flag that they needed to check the call price, i.e. particularly if it was a business or premium rate call. However, a number of group members questioned the purpose of the logos where the service charge cost was also being provided. It was suggested that the main consumer interest was how much the call was going to cost them and therefore a logo may not be useful. It was also questioned whether it was necessary to have a logo for geographic or mobile calls if the aim of the logos was for SPs to advertise the SC costs.
BT asked whether, in potentially communicating an unbundled call charge, whether the service charge across all providers could be presented consistently (some charge per minute, some per call). Ofcom responded by saying that it would be the responsibility of the service provider to communicate their service charge in a way that was clear and consistent.
There was some discussion about whether some of the categories should be further spilt out, for example whether the business and premium rate sections should be spilt by price range or type of service. BT proposed the idea of another logo for charitable donations. Vodafone suggested that it would perhaps be useful to separate out higher and lower business rate charges. It was noted that the premium rate group in particular covered a large range of prices and one icon for this range was not necessarily helpful. It was also highlighted that the icons did not currently include 118.
An alternative system of some type of ladder pricing was suggested, where it was made clear that, for example 084 would have a lower service charge than 087 numbers, and that 08 numbers would be less expensive than 09 numbers.
C&W also suggested that the logo could only be required to be published for the 09 range (as a flag to consumers) but that regulation on the 08 range should be removed and industry would look to self-regulate on the publication of the SC for this range. PhonepayPlus suggested pricing bands centred upon price for example, 50p - 1 being one band. It was noted that this would be difficult because currently Ofcom was not proposing to set a maximum access charge for different ranges, as well as the fact that the access charge could be different for different packages.
Three suggested a system of communicating prices like buying birthday cards, with call charges banded into groups and a specific code chosen to represent those groups that was then presented in advertising.
Some group members suggested that Ofcom should look to the advertising world for ideas and Jacqui Brookes suggested it would be useful to test any potential proposals on children. Jacqui Brookes also suggested that particular engagement was needed with service providers themselves. She noted that SPs were poorly represented within the group, and that they should be invited to comment on any proposals.
Ofcom noted that the intention was for the current meetings to include views from advertisers/marketers within communications providers, but that further engagement with SPs was planned. 118 suggested possibly inviting the CBI or the Federation of Small Businesses to gather their views. Similarly, it was noted that we should consult consumer groups on these issues.
Promotion of the Access Charge
Phonepayplus raised concerns about how the Access Charge would be communicated. It noted that, under the current system, it was very difficult for a consumer to search websites to understand the costs charges from their network, and that it would therefore be difficult for SPs to communicate this to their customers under the proposed new regime.
Vodafone noted that, under Ofcoms current proposals, the SP would only need to advertise its own service charge, and that there was an access charge, it did not need to state what that was. He also noted that it was a similar system to the current PhonepayPlus regulation for short codes (1 plus your standard network charge), which worked well and contained an appropriate level of detail.
PhonepayPlus suggested that all access charges could be referenced on one central website that consumers could access in order to aid their decision making. They also noted that a convention would need to be agreed in terms of pricing per call or per minute, potentially incorporating rules around elements such as average call duration.
Elizabeth Gannon noted that the key difference between the current regime, where to find a price consumers had to trawl through huge price lists to find the relevant charge, and what Ofcom was proposing was that there would be a limit of once, or possibly two access charges per package. Therefore it would be much easier for the communications provider to make that charge clear, and for the consumer to find it.
Communicating changes more widely
Questions were raised about who would be responsible for the communicating of such pricing information and what the intention in particular behind the logos and branding was. Don Wilson asked whether this would be a system just for Ofcom to communicate to consumers and, if it was, then the practicalities of implementing such a communications strategy did not matter as much. Jacqui Brookes asked whether this would be something that all business would be expected to adhere to, a sort of industry convention.
Ofcom noted that the intention was that it would be a consistent set of information that all industry could refer to and which would help aid consumer understanding of the likely costs of different non-geographic numbers. Ofcom noted it could therefore be a system that was used on communications providers websites, as well as Ofcoms own website and being presented by service providers.
The group had a brief discussion about the appropriateness of the terms access and service charge, and whether there were other terms that would be more useful to aid consumer understanding.
It was suggested that members of the group return to the next meeting with potential ideas for this. Liz de Winton noted that because the access charge would be referred to advertising, whereas the service charge would be a specific number defined in the ad, the definition of the access charge was particularly important.
Don Wilson noted that any transition to a new regime would involved a period of consumer education and in that sense, any wording could be used for the access and service charge, as long as it was used consistently and a period of time allowed for it to bed down in the consumer conscious.
It was broadly agreed that the amount of words used to communicate pricing should be kept to as small an amount as possible. Several suggestions for alternative wording were discussed, including phone companys charge, standard network rate, retailer charge, phone company applicable tariff, connection charge, network access charge, set up fee.
Don Wilson noted that a specific term, such as access charge as opposed to a more generic one such as standard network rate or retailer charge was necessary, because originating communications providers would need to be able to consistently refer to that charge in their pricing so that consumers would be able to readily identify it. He noted that access charges would vary according to different packages, and these would be different from rates for geographic or mobile numbers, and therefore consumers would need a clear identifier for those charges.
A suggestion was made that the wording could just refer to the type of number, eg. your premium rate charge, or your business rate charge.
ACTION - Liz de Winton agreed to set the date for the next meeting, aiming for the last week of August.
ACTION all agreed to further consider access and service charge wording alternatives for the next meeting