Proposals for Publishing Information on Complaints Received by Oftel

In November 1998 Oftel issued a consultation document on its proposals for publishing information on complaints received by Oftel.

After full consideration of the responses to the consultation document the Director General has concluded that the data will be published (for the first time in November 1999) in the following manner:

Criteria/information/thresholds:

• Analysis is based on number of issues raised by complainants – not number of complainants

• A complaint is defined as consumer expression of dissatisfaction relating to their telecoms company or a telecoms service

• No company will be included if complaints relating to the company are less than 5% of the total complaints received about that issue

• No company will be included if complaints relating to the company are less than 50 (equates to around 2 complaints a week)

• Includes business and residential customers

• Customer base information is for 30 June 1999

• Complaints per 10,000 customers will not be shown if a company does not wish to make its customer base information public

• Complaints about cable television are excluded

• A list of all the companies owned by companies complained about or which form part of the same group will be provided, eg in this example, Company B owns the following companies: Company aa, Company bb, Company cc

Criteria/information/thresholds:

• Analysis is based on number of issues raised by complainants – not number of complainants

• No company will be included if complaints relating to the company are less than 100 (around 8 complaints a week)

• A complaint is defined as consumer expression of dissatisfaction relating to their telecoms company or a telecoms service

• Includes business and residential customers

• Customer base information is for 30 June 1999

• A list of all the companies owned by companies complained about or which form part of the same group will be provided, eg Company B owns the following companies: Company aa, Company bb, Company cc

• In this example, Company X did not wish to make its customer base information public

How the data will be published

1.1 Criteria for inclusion in the published tables are listed in the summary.

1.2 Oftel does not feel it is appropriate either to base publication of complaints data on the CPI model, or to include Oftel complaints data in CPIs. CPIs offer complementary, but different, information. Oftel will publish its own data, not data from companies. CPIs are referred to as they provide information, Oftel’s data deals with issues and CPIs deal with measuring companies’ performance against certain criteria.

1.3 Oftel believes that the internal processes it already has in place for recording and checking consumer complaints data ensure its integrity. However, we recognise concerns raised by some respondents about this issue, therefore, Oftel proposes to appoint consultants to complete an audit of the whole process under which Oftel records and deals with consumer complaints by the end of 1999.

1.4 Both tables A and B will now show volume of complaints and complaints per 10,000 customers. The later will be published only where companies agree to their customer base information being disclosed.

1.5 The six month period between publications will be reviewed once the process is up and running, Oftel will consider moving towards quarterly publication of data when appropriate.

1.6 Oftel will publish information relating to the ‘main company’ rather than individual local companies or franchises. We believe it is not practical to publish information on local companies or individual franchise areas as it would be difficult to obtain customer base information. In addition it was felt that the ‘main companies’ were becoming better known as a result of efforts to establish corporate identity. However, information will be included in the published data to allow consumers to identify the ‘main company’ that incorporates their telecoms company. In addition, if Oftel is receiving a significant volume of complaints about a particular local company which raises issues of concern, we will name that company in the Oftel comments in the relevant table. Consumers can therefore be made aware if Oftel is receiving a number of complaints about their local company.

1.7 The Consultation Document explained that calculation of the denominator in the mobile market is slightly more complex than other areas as complaints can either relate to a network or a service provider. The four mobile operators differ in the extent to which they rely upon service providers. Orange and One-2-One usually – though not always – deal directly with customers while Vodafone and Cellnet must use either independent or separate company-owned service providers. Oftel feels the proposals already put forward will ensure that each of the four companies are treated consistently and that consumers can compare independent service provision and network owned service provision. To this end a separate calculation will be carried out for network complaints and service provider complaints. Oftel defines ‘Network’ as issues relating to coverage or reception quality. Mobile companies, if included in the published data, will therefore be listed in the following way:

• Cellnet (mobile network)
• Cellnet (mobile service provision)
• One2one (mobile network)
• One2one (mobile service provision)
• Orange (mobile network)
• Orange (mobile service provision)
• Vodafone (mobile network)
• Vodafone (mobile service provider)
• [Independent company] (mobile service provider)

1.8 The published data will not include data available from other organisations such as local Trading Standards departments and Citizens Advice Bureau as it would be impractical to do so. However, reference will be made in the published data as to where such further information can be found.

1.9 The published data will cover complaints received by the whole UK population. It is not possible to look individually at Scotland, Wales, Northern Ireland, or regionally as customer base information is not always available in this format.

1.10 A company’s position in the previous publication would be shown where applicable.

1.11 Crown Copyright will apply to the published Data. Whilst Oftel believe that the publication of this data will assist consumers it is not intended to be either an official endorsement or criticism of the companies named. The data is not intended for use in any advertising or marketing exercise. If there is any attempt to use the information for commercial purposes, or to imply that Oftel has in any way endorsed or criticised a company by the publication of this data, Oftel will consider issuing a press notice on the subject. Where the use is felt to be misleading or otherwise in breach of the relevant Codes of Practice, Oftel will consider referring the matter to the Advertising Standards Authority or to the Independent Television Commission. Potential advertisers may find the adjudication of the ITC in relation to Orange plc (June 1999) of assistance in this area.

1.12 Oftel will include, in covering text, details of the number of complaints received during the period about Oftel.

Responses to Consultation questions

2.1 Oftel received 44 responses, details of respondents is shown in annex A

2.2 Two benefits are achievable from greater transparency in respect of complaints:

• a greater incentive is provided to telecoms companies to address the cause of complaints, and
• improved information to consumer representatives and individual consumers to allow customers to make better-informed decisions about their choice of service.

2.3  The majority of respondents broadly agreed with Oftel’s reasons for publication. Some respondents felt that current market forces already provided telecoms companies with the incentive to address their customer complaints. A few respondents felt the naming of telecoms companies did not meet Oftel’s objectives on improving its accountability and transparency. Oftel notes this view, however, we believe that publishing complaints data in this format does help improve the transparency of our actions as it enables consumers to look at the work of Oftel’s consumer representation. Where Oftel’s consumer complaints data indicates serious consumer concerns over the quality of a company’s customer services, Oftel will where appropriate, aim to meet with that company informally to highlight our concerns. The inclusion of both the company’s and Oftel’s comments in the proposed publication will indicate how both work together to resolve problems. Where a company is slow in resolving a problem this will be highlighted in subsequent publications and should act as an incentive to the company concerned. Consumer complaints data is a resource that is used by Oftel when considering policy. Publishing data, including the naming of companies, will help improve understanding on Oftel’s policy decisions on particular issues or telecoms markets. Consumer complaints about some parts of the mobile industry charging for recorded announcements when a call is unsuccessful led to an Oftel investigation and subsequent MMC ruling. This illustrates the value of consumer complaints in pursuing our goal to provide the best possible deal for the consumer in terms of quality, choice and value for money.

2.4  Respondents put forward a number of views as to how rounded and balanced a view publishing the Top 10 companies and Top Ten Complaints would give. Oftel will now be making reference to customer base in both tables. With regard to the list of Companies most complained about, having reviewed all the arguments, some that even restricting to Top 10 companies was unnecessary, Oftel accepts the arguments made by a number of respondents that a Top 5 list of companies complained against is more appropriate given the level of consolidation of companies within the telecommunications industry. Oftel also agrees that it would be helpful for the list of companies to include reference to the main issues which have resulted in a company being listed in the Top 5.

2.5 Oftel will consider referring in the accompanying text to any significant issues that have generated only a small number of complaints and are not included in the Top 10 complaints table.

2.6 Respondents commented on the thresholds suggested by Oftel and some have now been removed. It was felt that it was reasonable to include complaints about new or small companies in Table B, but the threshold of 100 complaints would remain as in a 6 month period this was not a large number. The thresholds for inclusion in Table A remain the same as those proposed in the Consultation Document. Oftel believes these thresholds ensure statistically viable data is produced.

2.7 Oftel accepts some respondents’ concerns that a 6 month publication period was too infrequent, and we will consider publishing more frequently once the process is up and running.

2.8 As a point of clarification paragraph 3.3 of the Consultation Document stated that categorisations of complaints was listed in an annex. However, the annex actually produced in the document (in error) was a comprehensive list of all those categories available for use for recording both complaints and enquiries. It should be noted that not all will be appropriate for use as part of this exercise, as at present Oftel does not propose to publish data on enquires. An amended list of categories is shown at Annex B.

2.9 In the consultation paper Oftel stated that it does not refer all customer complaints to telecoms companies. Complaints not referred concern telecommunications policy (ie how Oftel regulates companies) or issues relating to the known commercial position of a telecoms company (eg customer complaints that a company’s tariffs are too high). Oftel has noted the concern of some respondents that complaints which may not have been passed to them are to be published. Consumers are nevertheless complaining about the telecoms companies regardless of whether Oftel passes the complaint on to the companies, and therefore it is appropriate to include this type of complaint in the statistics. Telecoms companies will have their own sources of customer feedback and it is Oftel’s experience that this will generally reflect the type of complaints received by Oftel. (Where Oftel’s ongoing analysis of its data indicates areas of specific customer concern about particular telecoms companies, Oftel already liaises with these companies and provides statistical information.)

2.10 Many respondents felt the layout would be improved by including total volume of complaints figures and customer base information on both tables. Oftel has amended the tables accordingly (whilst not disclosing confidential information).

2.11 Once respondent proposed a revised layout for Table A, and Oftel has incorporated the changes suggested.

2.12 Most respondents felt this timescale was reasonable.

Communications for Business

Consumer Communications for England

Disabled and Elderly Advisory Committee on Telecommunications

Local Telecommunications Advisory Committees:-

• Aberdeen & District
• Birmingham
• Clacton & District
• Colchester & District
• Coventry & Warwickshire
• East Suffolk
• East Sussex
• Forest of Dean
• Harlow
• Harwich & Manningtree
• Hasting and Rother
• Ipswich & District
• Leicestershire & Rutland
• Manchester
• North Lancashire & South Cumbria
• Nottinghamshire
• Purbeck & East Dorset
• Shropshire
• Taunton Deane
• Torridge & North Devon
• Truro
• Weston Super Mare
• Wolverhampton

Scottish Advisory Committee on Telecommunications

Welsh Advisory Committee on Telecommunications

Royal National Institute for the Blind

Nil return

Consumers’ Association

Office of Water Services

North Counties Chief Trading Standards Officers Group

British Telecom

Cable & Wireless

Cable London

Cellnet

Energis

One2one

Orange

Racal

Scottish Telecom

Vodafone

Antelope Consulting

The Cable Communications Association

Annex B

Complaint Categories and Sub-categories

A complaint is defined as consumer expression of dissatisfaction relating to their telecoms company or a telecoms service. These categories can therefore relate to a specific company or a telecoms service.

CPI – Comparable Performance Indicators: telecoms companies and several consumer organisations, with support from Oftel, have developed a set of comparable performance indicators for a range of telecommunications services. Mobile services are not covered. The information is provided by the telecoms company and by using independent market research companies.

Consumer – residential and business customers

Main Company – the company with effective management control