BT response to the DTi consultation on Consumer Representation and Redress

BT response to the DTi consultation on Consumer Representation and Redress

Issued April 19, 2006

Introduction

BT welcomes the DTi's consultation of January 2006 entitled 'Strengthen and Streamline Consumer Advocacy'. 

Detailed below are comments on the DTi's proposals in the three main areas followed by responses to the specific questions where we believe we have a contribution to make.

General comments

Scope of proposals
BT notes that this consultation talks of 'key' services: water; electricity; gas; postal services; electronic communications and financial services. The scope of these proposals is not 'utilities' in the traditional context and BT is surprised that other sectors with similar attributes, such as transport, do not appear to have been given consideration for inclusion. 

Despite the potential for this consultation to have wider-ranging impacts across the electronic communications sector the views of industry bodies in electronic communications have not been actively sought by the DTi.  This is of concern.  It contrasts poorly with the consultation approach in the water industry for example, where less impact is proposed at this time and yet 25 companies were actively approached for views.

Consumer Direct
The national rollout of Consumer Direct is welcomed.  There remains, however, a need for greater clarity on the role of this organisation in complaint handling.  In particular, BT would wish to see more information on how Consumer Direct will interact with existing complaint processes, particular Alternative Dispute Resolution (ADR) schemes.

Consumer awareness of Consumer Direct and the organisation's remit will be key to success.  As a result BT would be interested to understand more about how Consumer Direct is to be promoted to consumers.

Ombudsman
BT is pleased to note the DTi's support for the Ombudsman scheme that BT co-founded in the electronic communications sector and suggests that consideration should be given to extending these proposals to other sectors not covered by the current proposals (see comments in Scope). BT strongly supports the TOSL (Telecommunications Ombudsman Service Ltd) model.  We favour the governance structure and funding model; and value the existence of an Ombudsman. Our experience is that TOSL provides an effective and independent Alternative Dispute Resolution (ADR) process for consumers.  We would point out that there are not two Ombudsmen as the consultation suggests.

Consumer Voice
BT does not have strong views regarding the proposed establishment of a cross-sectoral consumer advocacy body; however it is difficult to comment in detail without more information on the proposed remit of Consumer Voice.    

Working relationships
It is essential that in developing the way forward in consumer advocacy, the remit of each organisation is clearly defined and understood.  The relationship between Consumer Voice, Consumer Direct and Ombudsman schemes and how they will interact with each other needs to be well defined, otherwise there is potential for confusion and inefficiency.  BT believes there should be strict guidelines agreed between Consumer Voice, Consumer Direct, and Ombudsman schemes to ensure that the independence of these organisations is maintained and that information sharing and its onward use is transparent.

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BT would welcome any comments, which should be addressed to Liz Williams at liz.ea.williams@bt.com.