BT Phoenix House
pp306
202 Elder Gate
Milton Keynes
Buckinghamshire
MK9 1BE
Judith Oliver
ICSTIS
4th Floor
Clove Building
4 Maguire Street
London SE1 2NQ
11 September 2003
BT Response to the ICSTIS Consultation ‘THE POSSIBLE INTRODUCTION OF PREMIUM
RATE HIGHER TARIFFS OF £2.50 AND £5.00 PER MINUTE’, June 2003
BT would welcome any comments on its position as laid out in this document which is available
electronically at http://www.btplc.com/responses
Comments should be addressed to Anthony Foster, Phoenix House, pp306, Station Square,
Milton Keynes MK9 1BE, email anthony.2.foster@bt.com or by telephone: 01908 297772
Summary
BT welcomes the opportunity to comment on ICSTIS’ proposals for the introduction of new
higher premium rate services.
BT believes that providers of electronic communication networks have a role to play in
supporting regulatory bodies in the regulation of PRS.
Consumer protection has to be central to the integrity of the service.
BT does not oppose the two price levels proposed.
It is crucial that HRPRS numbers must be easily identified, both during a trial, and
afterwards, should the service proceed. This supports consumer protection measures and
also aids the monitoring of debt issues during the trial. To this end BT recommends a
dedicated number range and proposes the range ‘09X’, where ‘X’ equals ‘2’ to ‘8’. Oftel may
wish to consider how this may impact on the National Telephone Numbering Plan, however
BT does not think such a solution need hold up a trial unduly.
BT believes that it would be appropriate for ICSTIS to consider the need for clear and
accurate pricing across all networks, particularly in the mobile market to support consumer
validation and clarification.
BT believes that our response is consistent with our previous discussions with the industry
and our response to their Statement of Requirements. However, there are still a number of
points of detail regarding technical and process matters that must be finalised before BT is
in a position to offer service. In particular, BT would urge ICSTIS to ensure that a robust
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process is agreed with the industry on such matters as the recording of consent and
scripting for the free to caller message.
It should be remembered that once BT opens up these services they will become accessible
through our interconnect arrangements. ICSTIS should consider initiating an information
programme to bring this to the attention of all network operators.
This proposal offers BT a number of commercial opportunities and we recognise that the
premium rate market has the potential for new, innovative services that can benefit
consumers. However, we acknowledge that many of these services will be new to
consumers and, as they cost considerably more than current premium rate tariffs, could lead
to unexpectedly high bills. Therefore, BT believes that introduction of these tariffs should
only take place in a way that provides our customers appropriate and proportionate
protection.
To that end BT does not oppose the limitations of the trial as proposed but has detailed
several issues relating to these limitations.
Furthermore, it is BT’s intention to reintroduce the ‘free to caller’ facility on our network for
these services upon their maximum call charge being reached. This would be in addition to
the requirement for Service Providers to implement such a facility and in no way replaces
their obligation.
This proposal is unlikely to be the end of the matter since the industry are likely to propose
services with even higher rates once the new higher premium rate tariffs are opened up.
This will bring even more serious consumer debt and detriment issues as well as more
lucrative fraud opportunities.
Specific Questions raised in the Consultation
It is proposed that any services which operate at £2.50 per minute or £5.00 per minute must
obtain ICSTIS’ permission before operating. Do you agree?
Yes, consumer protection has to be central to the integrity of the service. Insisting on prior
permission gives ICSTIS the opportunity to assess the potential risks inherent in each new
charge rate. Reputable services will also have the benefit of ICSTIS approval that should help
drive consumer confidence in the new services being offered. This would also be consistent with
the Industry discussions. It would also be a sensible safeguard for customers, and would go
some way towards minimising bad debt, fraud etc.
It is also proposed that the new tariffs should be introduced as part of a trial supervised by
ICSTIS. Do you agree?
Yes, this is in line with the Industry ‘Statement of Requirements’. A trial is preferable for
consumer protection and will allow BT to monitor any potential ‘bill shock’ and levels of bad
debt. Furthermore it will allow the industry to test customer announcements, call pricing, bill
presentation, customer reaction etc.
Do you agree that participation in the trial should be limited to professional advice services
only?
BT does not oppose the trial limitations as detailed but recognises that the proposed limitations
may make the trial unattractive to potential Service Providers. Furthermore, there is an
increasing range of higher value content and services that will be inadvertently excluded. BT
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BT is an ISO 9001 Registered Company
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believes that the most important factor is for ICSTIS to validate the honest credentials and/or
long-standing reputation of the Service Provider. In stating this, we recognise that a number of
Service Providers in this area are new companies and will not have such credentials
Do you believe that advice services not linked to a professional body or any other types of
service should be included in the trial? If so, have you any suggestions as to how appropriate
consumer protection measures may be applied to these service types?
BT does not oppose other advice services provided that the action of thoroughly validating the
Service Provider's credentials, through a suitable, alternate and clearly defined method, takes
place and continues into the post launch service. If the trial is to be extended then BT believes
that the ICSTIS prior permissions process, in addition to adequate, clearly defined trial criteria,
amendments to the Code of Practice to reflect any additional requirements for the higher tariffs,
appropriate messaging with forced release mechanisms and regular monitoring of these
services by ICSTIS and the networks would go some way to address such issues. In addition,
clear ICSTIS guidelines based on Distance Selling Regulations and Data Protection should be
enforced. BT would be interested to know how any method of validation is to be implemented to
impose these controls on Service Providers operating in international locations.
Have you evidence to show that any business to business services could be viable if these tariff
points were opened up?
No evidence.
Do you agree with the proposed maximum spend limit for services at these tariffs?
Having discussed this with industry over a long period of time and indicated acceptance of these
rates and maximum spend in our response to their Statement of Requirements, BT does not
oppose these price levels.
If you are responding as an Originating Network Operator, do you envisage that services at
these price points would be charged to your consumers at £2.50 and £5.00 per minute? .
Yes.
Do you agree that cost and other necessary information should be given on connection and that
this information should be free to consumers?
Yes, customers are entitled to this information before being committed to the call and BT has
agreed to this in our response to the Industry Statement of Requirements. However, we would
wish it to be noted that in our response to the Statement of Requirements we asked for greater
detail, on how, in the event of a dispute, a Service Provider would demonstrate that a caller had
been given adequate warning during the free to caller period, the caller had agreed to the
charge and the identity of the calling line would be identified. We would still wish for this to be
clarified. Furthermore, failure to do this will result in large volumes of customer enquiries,
disputes, waived charges and bad debt.
The level at which a free message might be provided - Originating Network Operator,
Terminating Network Operator or Service Provider - is for the industry to decide. If you are
responding as a Network Operator please could you confirm how you envisage that this
requirement could be met.
The industry Statement of Requirements and our response were based on the Service Provider
providing the message. However, it is BT’s intention to reintroduce the ‘free to caller’ facility on
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BT is an ISO 9001 Registered Company
British Telecommunications plc Registered Office 81 Newgate Street LONDON EC1A 7AJ Registered in England no. 1800000
our network for these services upon their maximum call charge being reached. This would be in
addition to the requirement for Service Providers to implement such a facility and in no way
replaces their obligation.
Are you able to suggest any alternative measures for ensuring that all users of new higher rate
services would be made aware of call costs in the absence of this requirement?
No. Furthermore, BT would not support any alternative in the absence of a free message. There
is no other arrangement that guarantees that the customer had consciously acknowledged
receipt of pricing information and consented to the call proceeding into the chargeable period.
Do you agree that service providers should be required to give cumulative cost warnings at
intervals throughout the service?
No, as this could be a bad user experience but this is conditional on mandatory clear pricing
information given at the beginning of the call. However, this issue should be assessed as part of
the trial.
In what circumstances do you think such a requirement should be imposed?
If there is a failure to mandate or adhere to overall cost capping and unambiguous pricing
information including examples of charges in the pre-amble.
13. Do you agree with the parameters of the trial?
As per the conditions stated previously.
If you are responding as an Originating Network Operator, to what extent would you be able to
provide details of bad debt or developing high bills attributable directly to services at these new
tariffs?
This will depend on the numbering arrangements, the outcome of the trial and the customer
reaction to it. No doubt BT will be able to identify examples of these, but BT will need to
observe data protection guidelines when gathering evidence.
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BT is an ISO 9001 Registered Company
British Telecommunications plc Registered Office 81 Newgate Street LONDON EC1A 7AJ Registered in England no. 1800000