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Written evidence submitted by Ombudsman Services
Broadband and the Road to 5G Inquiry
I write in response to the DCMS Select Committee ‘Broadband and the Road to 5G Inquiry’
General Comments:
We welcome the inquiry into the area of ‘Broadband and the Road to 5G’. Our response provides general comments that we think will be key in consumers having a positive experience during the roll out and to aid the Government to meet the targets set on broadband and 5G. In our view, a positive consumer experience is critical to build consumer trust and confidence in the sector during this journey. This is so that, even when things go wrong or there are problems, consumers know those problems will be resolved in a timely manner and that they will be treated fairly.
We have provided, as an example at Annex A, data around the complaints that we see in the communications sector in relation to broadband service quality. We would be happy to provide further data and insight if that would be useful and provide oral evidence if appropriate. We have also facilitated workshops with both communication and energy providers on vulnerability. We have done this by using our own data and insight but also encouraging communication and energy providers to share their own data and insight, as well as invited experts working on different aspects of vulnerability to discuss key issues and good practice to help consumers in vulnerable circumstances. At Appendix A, we have included background information about Ombudsman Services.
In such unprecedented times with individuals, communities and businesses adjusting to new ways of being and working in the face of the Covid-19 global pandemic, the role and resilience of our broadband networks for communication, entertainment and information has been thrust into the spotlight as an absolute essential service for all people. It has highlighted how critical it is that the UK has strong communications infrastructure and high-quality services in place to ensure that we have a digital landscape that is fit for the future.
We have seen how the communications sector can work together during the Covid-19 crisis to help the most vulnerable consumer. By setting out and agreeing a number of important commitments, for example, providing support around paying bills, removing data caps, providing generous packages during the crisis and offering alternative methods of communications with vulnerable consumers, consumer trust is being built. We support these commitments and will play our part in helping to support vulnerable consumers where we can.
It is this more joined up working and approach that would be helpful in the sector and sets the right precedent towards meeting the challenges of broadband coverage and 5G.
Key points:
Consumer Protection / Complaints
We see complaints from consumers and microbusiness about a range of issues in the communications sector and broadband issues made up around 30% of all complaints. In 2019, we recorded over 2,000 complaints about broadband service quality. In fact, download speeds, intermittent service and loss of service make up the most common complaints, alongside new connection issues, coverage and disconnections. You will see from the heat map, those areas in red which experience more broadband service quality complaints. We know that more has been done by the regulator to ensure that consumers are aware of the speeds they can expect and that they are covered for a loss of service, however, issues still regularly arise.
For that reason, we welcome the outside-in approach being proposed by the Government – to make sure that those in rural areas are given priority. The term ‘outside-in’ more widely is known as taking a consumer-centric approach and putting consumers at the centre of building infrastructure and services. We welcome this approach, and in our view, it will help to build consumer trust and confidence in the sector and improve consumer resilience.
Building Trust
We have seen how broadband services play a key role in connecting people. They are also increasingly important to be able to participate in online activities such as banking and shopping, as well as, accessing entertainment and information. As a result of the Covid-19 pandemic, it’s clear how necessary broadband services are for maintaining a connected society and sustaining work life. This necessity for strong digital infrastructure and networks is only likely to multiply in the coming years, which is why we need to ensure that the future digital landscape is fit for purpose and inclusive of all generations.
The current landscape of complaints already highlights a gap between consumer expectations and what they in fact receive as a service. Consumers need to see a system that is fair and works for them now and need to feel confident that their broadband and network providers are offering them protections as new innovative connectivity technologies are rolled out. Our insights suggest that consumers want timely repairs, accurate billing and a reliable and good quality service. Indeed, this reassurance is needed even more so for those most vulnerable, which includes those in underinvested and rural areas.
We think it is useful to look at what has happened with past technology rollouts and learn from those experiences. As it may also be useful to review existing schemes to see if they result in the right outcomes for consumers. It’s important that as new services are rolled out, that existing service standards are maintained and supported appropriately in the interim. For example, when 4G services were rolled out, we saw consumers receiving a worse service when accessing the 3G network. Appropriate measures should be put in place to ensure that existing network services are maintained to their current standard ahead of and during any future 5G rollout.
As mentioned earlier, we deal with complaints about intermittent service or a complete loss of service. We think, that particularly when consumer experience these difficulties, if they are not rectified quickly, they lose trust in their supplier and the sector. We recognise that the regulator Ofcom has taken some strong steps to improve the consumer experience to ensure that consumers are aware of and can expect certain download speeds as well as receive compensation when things go wrong. It is necessary to ensure consistent consumer protection when things go wrong to help build trust. We want to work with Government, regulators and consumer bodies to prepare consumers for the changes to the services they rely on, and to ensure that trust is built in order to help meet the national targets set out for the telecoms sector.
Working Together
As one of two Alternative Dispute Resolution (ADR) providers in the communications sector, we gather a lot of data about consumer complaints. We are ideally placed to receive early signs of technology, process, procedural or policy shortfalls when consumers and microbusinesses contact us to raise a complaint which they feel has been unresolved by their provider.
We think it is important to drive up standards in the industry by sharing data and insights and working together to make improvements, manage expectations and inform policy. In the energy sector, there is a tripartite model in which Ofgem, Citizens Advice (and the Extra Help Unit) and Ombudsman Services work together to good effect to share data and insights and take measures to identify early signs of consumer detriment. Prevention being better than cure.
There is room to broaden interactions within the communications sector. For example, making more use of the interactions between Ofcom and the two ADR schemes, the Consumer Panel and in the future, subject to the work the Department for Digital, Culture, Media and Sport undertakes around putting in place a statutory consumer advocacy body (the proposal is that this role is undertaken by Citizens Advice), the nominated statutory consumer advocacy body in communications. This would provide opportunities to share best practice across stakeholders, ensure stronger collaboration and data sharing within the communications sector and also provide valuable insight into how the Ofcom fairness Framework is being applied and the view of consumers around what is fair.
Please do not hesitate to contact us if you would like further information regarding our response. Our response is not confidential.
Ed Dodman
Director of Regulatory Affairs
Appendix A
About Ombudsman Services:
Ombudsman Services is a not-for-profit private limited company established in 2002 which runs a range of discrete national ombudsman schemes across different sectors including energy, communications and an appeals service in private parking. Each scheme is funded by the companies under our jurisdiction and our service is free to consumers. In 2018 we received 174,855 initial contacts from complainants and resolved 68,063 complaints. In the energy sector we received 108,349 initial contacts and resolved 45,667 cases, and in the communications sector, we received 62,233 initial contacts and resolved 21,251 cases. We also received over 67,000 appeals in our private parking appeals service.
We are: