Review of Quality of Service Information Phase 1: Information on Quality of Customer Service

Introduction and summary of BT’s views

BT welcomes the opportunity to comment on this subject, having been an active participant in the existing Topcomm scheme and in previous similar schemes for several years.

We completely support the view that consumers should be able to make fully-informed decisions when comparing and choosing communications providers, and for this reason we believe that a review of the current scheme is well overdue, since it is not fit for purpose in a number of respects. It is vital that, for a comparison scheme to work effectively, consumers are able to compare like-with-like in a manner which is guaranteed to be accurate and which cannot be misleading in any way, and in BT’s view the current scheme does not meet those aims, for reasons discussed more fully below. In particular:

• The current measures have not been researched with consumers to determine whether they properly reflect consumers’ interests and concerns when choosing a provider
• The definitions of each of the current parameters are open to interpretation and therefore do not present comparable data
• Different types of providers are compared side-by-side without proper explanation, again leading to a potentially misleading impression
• Business measures are provided on an averaged basis, with no attempt to differentiate between large corporates and small SMEs, or to ascertain what customers want, with the result that the information is fairly meaningless
• There are differing levels of verification and auditing of data, so that some providers’ data are more reliable than others
• There is no publicity of the scheme, and hence very low usage and no consumer benefit currently deriving from it, so all the cost and resource are currently wasted
• It is very difficult to reach a consensus on anything within the Topcomm forum, due to conflicting commercial views, and hence any improvements in any of these respects are almost impossible to agree and implement.

Whilst Ofcom has recognised many of these issues, BT believes that before going any further with its review, Ofcom should complete more comprehensive, quantitative market research into what consumers and business customers really want and need. For example, are consumers more interested in personal recommendations, experiences and satisfaction levels of other consumers, or do they want hard objective data based on averages and/or samples? Do businesses want objective data on quality of customer service, or are their decisions based rather on the packages, discounts and value-added services that suppliers offer them according to their line of business (as BT believes)? Do customers want quality of customer service data displayed alongside price, so that they can readily see the trade-off between one and the other? Given the existing high levels of churn within fixed telephony, mobile and broadband already, is there really evidence of strong enough demand from consumers for more quality of service data to help them make switching decisions, to justify the costs to industry of collection, auditing and publication, or do they feel adequately-informed already on factors of importance to them?

Until Ofcom has answers on these fundamental questions, BT believes it is too early to be discussing any extension of the current scheme to other services, or the detail regarding the measures, or the way in which data should be audited and published. However in the spirit of co-operation, we have given BT’s current views on the detailed questions raised by Ofcom as best we can in the remainder of this response.

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BT welcomes comments on the content of this document. Comments should be addressed by email to deirdre.cheek@bt.com.