Ofcom requires communications providers (fixed and mobile) to provide a range of services designed to benefit disabled customers, including:
Communications providers are also obliged to take reasonable steps to ensure that these services are widely publicised. We have taken the view that as a minimum, 'reasonable steps' would include providers ensuring that consumers are given accurate information when they enquire about relevant services and publishing clear and easy-to-find information on their own websites.
To test compliance with the obligation to publicise these services, Ofcom commissioned mystery shopping designed to see what advice consumers were given on the phone or by email, and what information was available on the providers' websites. Similar research was previously carried out in 2006.
The disabilities mentioned, and the services likely to be relevant to people with those disabilities, were:
1,272 telephone calls were made, around 150 to each operator, to enable statistically robust comparisons to be made. Six calls per provider were made via the text relay service. In addition to the quantitative telephone research, the research agency also conducted qualitative exercises to assess how providers responded to queries by email, and they also visited each communication provider's website, using search terms such as 'deaf', 'disabled' and 'relay service' to look for relevant information and to see how easy it was to find.
The following fixed line and mobile phone providers with a market share of 5% or more at the time the research was commissioned were included in the exercise: BT, Virgin Media, TalkTalk, T-Mobile, Vodafone, Orange, O2 and 3.
The report by the research agency can be read here http://stakeholders.ofcom.org.uk/binaries/research/telecoms-research/783922/DisabilitiesMysteryShoppin.pdf.
The results were fairly poor across all the providers surveyed. There were some slight improvements in spontaneous mentions of mandated service since we last carried out research of this kind. However, absolute levels of spontaneous mentions remain poor, and prompted mentions have fallen since 2006, in some cases by a large amount. All companies surveyed performed less well than in 2006 on prompted mentions.
On average, at least one mandated service was mentioned spontaneously 37% of the time. After prompting, this rose to 75%, suggesting that call handlers often did know about the service in question, but hadn't mentioned it spontaneously. However, it should be noted that, even after prompting, a significant number of calls resulted in no mandated service being mentioned, or in the caller being told specifically that the provider did not offer any special services for disabled customers (as opposed to just not mentioning any services).
Although at least one service was mentioned 75% of the time on average, this is not necessarily the service most likely to benefit that consumer, or all the services to which the disabled person would have been entitled - for example, priority fault repair might be suggested for a blind consumer, but not free directory enquires. Spontaneous and prompted mentions of more than one service were very low: for 3 or more services, the average was 4% spontaneous and 18% prompted.
Where blindness or visual impairment was mentioned by the mystery shoppers, providers were the most likely to offer at least one mandated service (both spontaneously and after prompting). This may reflect the fact that there are more services mandated for blind consumers. However, even after prompting, free directory enquiries were only mentioned 21% of the time (70% in 2006). Almost one in five (19%) of the mystery shopping enquiries on behalf of blind people resulted in the mystery shopper being told specifically that there were no special services for disabled customers and no priority fault repair.
The most commonly mentioned service for deaf or hearing impaired consumers was text relay. However, this was only mentioned 49% of the time even after prompting (78% in 2006). Rebates for users of text relay were only mentioned 6% of the time (33% in 2006), and 18% of callers were specifically told that there were no discounts or special services for disabled customers. Calls via text relay produced a wide range of responses from call handlers, including some apparent hang-ups.
For people with cognitive impairments or who were in hospital long term, priority fault repair was only mentioned 23% of the time, even after prompting. Callers were specifically told that there were no special services for disabled customers 20% of the time.
Only 70% of email enquiries sent received a 'personal' response (i.e. not just an automated acknowledgement), and 31 of the 105 emails sent did not receive a reply during the fieldwork period. The replies contained a variety of information, but very little related directly to mandated services. Replies to email enquiries generally contained less information about mandated services than those made by phone even though it would have been possible for the provider's member of staff to check which services were available. Although caution should be used because of the small numbers of emails sent, this aspect of the research suggests that information provided by email is overall no better than the response to telephone enquiries.
Ofcom has discussed the findings of this research with the communications providers concerned and required them to produce detailed action plans setting out how they propose to improve the situation. We have also asked to see copies of the training and reference materials that are provided to call handlers to inform them about these services. We will be meeting them regularly over the coming months to review progress in this area.
We have also made it clear to providers that we will be repeating the mystery shopping exercise in future and if improvement is not apparent we can move to formal enforcement action.