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Outcomes Evaluation of the Office of the Consumer Protector’s Consumer

Complaints Programme: 2014/15

PREPARED BY:

URBAN-ECON: DEVELOPMENT ECONOMISTS

Suite 20-102F, Building 20

The Waverley Business Park

Wyecroft Road

Mowbray

7700

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Executive Summary

Project Background and Purpose

Consumer protection can be defined as laws or organisations designed to ensure consumer rights,

fair competition and trade as well as accurate information in the market place. The South African

government noted the evolution of consumer protection internationally and nationally, and in

response to this established national and provincial bodies such as the Western Cape Office of the

Consumer Protector (OCP). These bodies are mandated to administer education and awareness

programmes as well as provide a platform where citizens can lodge a complaint.

With that in mind the purpose of this evaluation was to assess the implementation and performance

of the OCP’s two main interventions, namely the Consumer Education and Awareness (CEA) and

Consumer Complaints and Management (CCM) programme in terms of (1) the percentage of

Western Cape citizens aware of the OCP and its service offerings and (2) the percentage of

consumers satisfied with the level and standard of the complaints management. The evaluation

evaluated the following factors:

Programme operations and design;

Programme objectives, outcomes and indicators;

Assessment as to whether project objectives are still viable going forward;

Programme interventions and applied Theory of Change (TOC);

The percentage of Western Cape citizens aware of the OCP and its service offerings and;

The percentage of consumers satisfied with the level and standard of service offered by CCM

Global Perspective and Evaluation Framework

Case studies of consumer protection logic interventions were carried out in order to understand this

phenomenon around the world. It was identified that high income countries were more advanced

than low income countries in terms of establishing policy and regulatory frameworks. This was

attributed to varying socio-economic, political and financial disparities between developed and

developing countries. However South Africa was noted have more established frameworks than

other African countries such as Kenya and Zimbabwe. In totality, the following lessons were

understood: (1) developing countries need to consider policies specifically for consumer education in

order to improve awareness (in peri-urban and rural areas) ;(2) increase the awareness of consumer

protection rights and implementation mechanisms (how consumers can receive assistance) and (3)

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education programmes should be designed in such a way that they are needs-based so that they are

more applicable to target groups

Having set the foundation with the case studies, the evaluation framework was developed. The

process began by unpacking the theory of change involved in identifying favourable interventions

due to the important role it plays in identifying and developing interventions. Sub-objectives and

indicators that helped enhance the theory of change and assist with the evaluation were identified;

linking existing interventions and evaluating whether the approach was effective. The sub-objectives

included:

1. Implement a cost-effective marketing strategy through various platforms;

2. Ensure that PDAs are priority areas in which to educate and create awareness;

3. Ensure that workshop content complements challenges in targeted areas;

4. Ensure that programme design is unambiguous between programme managers and citizens;

5. Skilled and sufficient staff to implement marketing and manage consumer complaints

6. Sufficient financial capacity to implement programmes

Primary Findings and Impact Assessment

In addition to the case studies, two other primary data sources were utilised, namely interviews with

several stakeholders and administration of survey questionnaires to random Western Cape citizens.

The interviews with stakeholders probed information regarding programme design, implementation,

budget allocation and staff capacity – which highlighted government’s interventions. In addition, two

sets of survey questionnaires were administered. The first included 450 face-to-face questionnaires

to determine citizens’ awareness of the OCP and its service offerings and the second set included

310 telephonic questionnaires to determine the percentage of citizens satisfied with the OCP’s

service offering.

Findings from the study noted that the demographic profile of CEA respondents showed the

characteristics of citizens in Previously Disadvantaged Areas (PDAs) and also noted the following:

% of Western Cape citizens aware of the OCP and its service offerings

o CEA respondents =14.2%

o CCM respondents =41.0%

o The average level of awareness recorded in the survey is 24.9%1

% consumers satisfied with the level and standard of service offered by CCM

1 This percentage was derived by combining the CEA and CCM questionnaire answers

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o CCM respondents =47.5%

The satisfaction levels were evaluated based on the respondent’s opinion relating to staff

knowledge, friendliness, response time and overall satisfaction levels, which did not take into

consideration the legal mandate of the OCP. There is generally a high level of frustration amongst

respondents who have not had their issues resolved; this at times can be due unrealistic

expectations with the level to which the OCP is legally mandated to address the issue. This is

illustrated by the low levels of awareness of the existence of the OCP programme as well as what

they are legally able to achieve within the parameters of their mandate.

When comparing aspects such as employment status, income sources and household income it was

evident that CEA respondents were in a less advantageous position opposed to CCM counterparts.

With that in mind, the impact assessment below was able to reveal whether the OCP’s interventions

achieved the CPA’s mandate regarding consumer education and awareness as well as how effective,

platforms such as consumer complaints have been.

Table 1: Summary of Impact Assessment

Objective Assessment

1. Educate and create

awareness amongst Western

Cape citizens about their

consumer rights and the OCP

This objective was deemed to be acceptable. The number of workshops

conducted and print material distributed was effective within the

confinements of limited financial and human resources. Citizens were

aware of some of their rights but not how to address them when

violated. Thus there is room for improvement.

2. Implement a cost-effective

marketing strategy through

various platforms

Existing marketing platforms are sufficient although inexpensive

platforms such as social media can be considered in future.

3. Ensure that PDAs are priority

areas in which to educate and

create awareness

Education and awareness programmes and interventions continue to be

focused in PDAs, thus the objective was deemed to be effective and

good.

4. Ensure that workshop

content complements

challenges in targeted areas

A needs assessment underlying citizen’s experienced regarding consumer

protection lacks. This is valuable information which can guide the OCP

when developing the theory of change and interventions (enhance

existing content to address challenges identified).

5. Ensure that programme

design is unambiguous

between programme managers

and citizens

Definitions such as ‘case closed’ need to be redefined and mutually

understood between citizens and the OCP. There also needs to be a clear

outline and articulation of complaints management process to consumers

as this negatively impacts on citizens’ satisfaction.

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Objective Assessment

6. Skilled and sufficient staff to

implement marketing and

manage consumer complaints

Existing staff capacity is not sufficient to address the entire province. The

workload and pressure also limits marketing initiatives. Nonetheless, staff

members have been capitalising on departmental training programmes.

7. Sufficient financial capacity

to implement programmes

Coupled with limited staff capacity, the current budget is highly

insufficient to successfully administer education and awareness

programmes across the province as well as ensure customer satisfaction.

Recommendations

Once the impact assessment was carried out, recommendations were identified for two main

aspects: firstly the programme design and features and secondly, for the CEA and CCM programme.

With regard to the programme design, the strategic objective, objective statement, baseline and

outcomes identified in the Department of Economic Development and Tourism (DEDAT’s) previous

and proposed Strategic Five Year Plans were compared and analysed. Insight was provided to guide

the OCP as to whether the proposed features are realistic and achievable as well as factors that need

to be considered to ensure that they are achievable. Similarly, the same insight was provided for the

performance indicators, which had been noted to have been stagnant between 2012 and 2015. In

essence, the programme design and features need to take cognisance of the need to consider a

needs assessment. It would guide stakeholders to better design more effective programmes.

On the other hand, a variety of recommendations were identified for both the CEA and CCM

programme. The recommendations took cognisance of the issues identified in the analyses so as to

better implement the OCP’s mandate:

Table 2: Summary of Recommendations

CEA Issue Recommendation CCM Issue Recommendation

Revise the way

workshops are

administered

Regional co-ordinators

capitalise on ward councillors,

CBW & community meetings

(wider coverage)

Consider hosting workshops in

the evening & capitalise on

word of mouth

Outline the extent to

which OCP can and cannot

assist citizens

Include as part of workshop &

marketing content.

Inform citizens about what to

expect.

Employ interns to focus on

this.

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Include Customer

Complaints contact

details and service

offering as well as a

wider variety of

marketing platforms

Inform citizens of service

offerings & operations before

hand

Inform citizens of other

organisations

Develop marketing strategy &

expand (social media) =

inexpensive

Capitalise on DEDAT pocket for

marketing expenses

Investigators are

considered to be rude and

lack empathy. Their

response time and

feedback is poor.

Consider softer skills for

training.

Consider more technical skills

(law).

Additional content

design: factors to

consider before buying

second hand goods.

In addition to financial literacy

– add info about purchasing

second hand books.

Citizens prepared beforehand.

Use OCP if & when necessary.

Redefine the term “closed”

and redress the letter

indicating that a

complainant’s case has

been closed.

In letters of closure, explain:

why case is closed, steps taken

& reduce technical jargon.

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Table of Contents

Acronyms ................................................................................................................................................ 7

Tables ...................................................................................................................................................... 7

Figure ...................................................................................................................................................... 8

Annexures ............................................................................................................................................... 8

1.1 Project Background ........................................................................................................................... 9

1.2 Methodology ................................................................................................................................... 10

1.3 Report Outline................................................................................................................................. 11

1.4 Project Scope .................................................................................................................................. 12

2.1 Overview of Consumer Protection .................................................................................................. 13

2.2 Global Perceptive ............................................................................................................................ 14

2.2.1 Current state of Consumer Protection .................................................................................... 14

2.2.2 Role of Government and other Role-players ........................................................................... 15

2.2.3 Interventions in Developing Countries .................................................................................... 16

2.3 National Perspective ....................................................................................................................... 17

2.4 Provincial Perspective ..................................................................................................................... 18

2.5 Key Findings .................................................................................................................................... 19

3.1 Research Strategy ........................................................................................................................... 21

3.1.1 Research Design ....................................................................................................................... 21

3.1.2 Sampling Technique ................................................................................................................. 21

3.1.3 Sample Size .............................................................................................................................. 22

3.1.4 Data Collection Methods ......................................................................................................... 22

3.1.5 Limitations to Study ................................................................................................................. 23

3.2 Evaluation Guidelines...................................................................................................................... 24

3.3 Ethical considerations ..................................................................................................................... 25

4.1 Theory of Change (TOC) .................................................................................................................. 26

4.1.1 Defining a TOC ......................................................................................................................... 26

4.1.2 Implementing a TOC Evaluation .............................................................................................. 26

4.1.3 Past Implementation of TOC Evaluation Approach ................................................................. 28

4.2 Programme Design and Features .................................................................................................... 29

4.3 Evaluation Framework .................................................................................................................... 31

5.1 Primary Findings .............................................................................................................................. 36

5.2 Impact Assessment ......................................................................................................................... 38

5.2.1 Analysis of Findings .................................................................................................................. 38

5.2.2 Impact Assessment .................................................................................................................. 52

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6.1 Programme Design .......................................................................................................................... 57

6.2 Recommendations for CEA programme ......................................................................................... 62

6.3 Recommendations for CCM programme ........................................................................................ 64

Acronyms

CCM Consumer Complaints Management Programme

CEA Consumer Education and Awareness Programme

CPA Consumer Protection Act (2008)

DEDAT Provincial Department of Economic Development and Tourism

DPME National Department of Performance, Monitoring and Evaluation

FSB Financial Services Board

ICT Information Communication Technology

M&E Monitoring and Evaluation

NCC National Consumer Commission

NCF National Consumer Forum

NEPF National Evaluation Policy Framework

OCP Office of the Consumer Protector

SMART Specific, Measurable, Achievable, Relevance and Time-bound

TOC Theory of Change

UN United Nations

PDAs Previously Disadvantaged Areas

Tables Table 1: Summary of Impact Assessment ............................................................................................... 3

Table 2: Summary of Recommendations ................................................................................................ 4

Table 3: Number of CEA questionnaires required per region .............................................................. 22

Table 4: Number of CCM Questionnaires Required ............................................................................. 22

Table 5: Theory of Change Approach to Evaluation ............................................................................. 27

Table 6: OCP Programme Interventions ............................................................................................... 28

Table 7: Programme Features ............................................................................................................... 29

Table 8: Sector Specific Performance Indicators .................................................................................. 31

Table 9: Use of Elements in Log Frame ................................................................................................. 32

Table 10: Evaluation Framework .......................................................................................................... 34

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Table 11: Summary of CEA and CCM Demographic Profile .................................................................. 36

Table 12: Consumers’ Level of Awareness about their Consumer Rights delineated per right (CEA

respondents) ......................................................................................................................................... 39

Table 13: Consumer’s Awareness of interventions implemented by the OCP ..................................... 40

Table 14: Consumers’ Level of Awareness about their Consumer Rights (CCM Respondents) ........... 42

Table 15: CEA Respondents' Consideration for Awareness and Complaints ........................................ 46

Table 16: Customer Satisfaction ........................................................................................................... 49

Table 17: Staff Capacity ........................................................................................................................ 51

Table 18: Impact Assessment of CEA and CCM objectives ................................................................... 53

Table 19: Recommendations for Programme Features ........................................................................ 57

Table 20: Recommendations for Performance Indicators .................................................................... 60

Table 21: Recommendations for CEA Programme ............................................................................... 62

Table 22: Recommendations for CCM Programme .............................................................................. 64

Figures Figure 1: Evaluation Methodology ........................................................................................................ 10

Figure 2: Organisational Structure ........................................................................................................ 18

Figure 3: CEA – Marketing platforms known by respondents .............................................................. 44

Figure 4: CCM – Marketing platforms known by respondents ............................................................. 44

Figure 5: Most Prevalent Types of Consumer Complaints .................................................................... 47

Figure 6: Status of Case ......................................................................................................................... 49

Annexures Annexure A: Evaluation Framework

Annexure B: Demographic Profile

Annexure C: Stakeholder Questionnaires

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Chapter One: Introduction

1.1 Project Background

Concept and Problem of Consumer Protection

Consumer protection may be defined as laws or organisations designed to ensure consumer rights,

fair competition and trade as well as accurate information in the market place. They are designed to

prevent businesses from engaging in fraudulent or unfair practices. Consumer protection is a

government regulation which may require businesses to disclose information about their products

and services and implement programmes which help consumers make better choices as well as

consumer address complaints. It covers a range of topics which include but are not limited to:

privacy rights, unfair business practices, fraud, product liability, misrepresentation and other

consumer interactions.

Internationally, the consumer market has undergone profound change over the past 20 years. Policy

transformation, wider global markets, technological developments and growing consumer services

are just some of the factors that have aided this change. In most cases these changes have

contributed towards significant benefits to consumers but very little attention is paid to the

challenges they pose for consumers and businesses. For example, the markets contain a wider range

of more complex products and there is significant differentiation among related products and

services which make it more difficult for consumers to compare and assess the value. As the global

market place continues to integrate and expand, the internet has also provided new opportunities

and challenges for consumers, which has led to the emergence of consumer protection bodies that

are more vigilant and active.

Purpose and Objectives of the Evaluation

The South African government noted the aforementioned evolution of consumer protection

internationally and nationally, and in response to this established national and provincial bodies. The

Western Cape Office of the Consumer Protector (OCP) is a provincial consumer protection authority

situated in the Provincial Department of Economic Development and Tourism (DEDAT). It was

established in 2002 under the Western Cape Unfair Business Act (2002) with a mandate to offer

services, information, and education and redress services relating to consumer protection.

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As part of improving government’s service delivery performance, government departments are

required to conduct an outcomes evaluation of their service delivery so as to assess whether the

desired outcomes were attained during the given period. The outcomes evaluation is just one of

many performance management approaches, which include outputs; activities and inputs

monitoring and evaluations.

Therefore the purpose of this evaluation is to assess the implementation and performance for the

desired outcomes for the Consumer Education and Awareness (CEA) and Consumer Complaints and

Management (CCM) programme in terms of (1) the percentage of Western Cape citizens aware of

the OCP and its service offerings and (2) the percentage of consumers satisfied with the level and

standard of the complaints management. The evaluation will also evaluate the following factors:

Programme operations and design;

Programme objectives, outcomes and indicators;

Assessment as to whether project objectives are still viable going forward;

Programme interventions and applied Theory of Change (TOC);

The percentage of Western Cape citizens aware of the OCP and its service offerings and;

The percentage of consumers satisfied with the level and standard of service offered by

CCM.

1.2 Methodology

Figure 1 illustrates how the outcomes evaluation was carried out:

Figure 1: Evaluation Methodology

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1.3 Report Outline

The study comprises of various components that contribute towards the evaluation, thus the study

is outlined in a manner that collates these components:

Chapter 2: Discusses the concept and rationale of consumer protection as well as how

governments across the world are approaching it. The chapter also briefly discusses

consumer protection activities in South Africa on a national and provincial level.

Chapter 3: Outlines the research strategy implemented in order to collect data and also takes

into consideration the evaluation guidelines as set out by the National Department of

Performance, Monitoring and Evaluation (DPME).

Chapter 4: Discusses the concept and importance of Theory of Change (TOC), how it has been

considered in past evaluations as well as programme design. This is followed by an

explanation of the evaluation framework.

Chapter 5: Discusses the primary findings from interviews and questionnaires. The findings are

analysed according to objectives identified in Chapter 4, thereafter an impact

assessment is provided to illustrate to what extent each objective has been met.

Chapter 6: Provides recommendations based on the findings in Chapter 5. The

recommendations are categorised according to the issues and opportunities

identified for each OCP programme.

Project Inception and Literature Review

Survey questionnaire design and Sampling Technique

Survey interview and questionnaire administration

Evaluation Framework Design

OCP Programme Evaluation

Data Capturing, Analysis and Interpretation

Recommendations

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1.4 Project Scope

The study focused on the impact and effectiveness of CEA and CCM programmes with in the

Western Cape. It evaluated the programmes over a period of 12 months based on the following

criteria: (1) the most prevalent towns where the CEA programme was administered throughout 2014

and (2) closed file registers of complainants who contacted the CCM programme throughout 2014.

The evaluation was inclusive of diversity by addressing factors such as geography, language, age and

gender during the sampling stage. Furthermore, it not only evaluates the programmes over the 12

month period but also uses the information to guide input into the proposed DEDAT Strategic Five

Year Plan.

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Chapter Two: Consumer Protection in Context

This literature review aims to identify and assess consumer protection activities, assess trends and

interventions across the world but primarily in developing countries – given that South Africa can

relate more to developing than developed countries. The chapter begins by discussing what

consumer protection and consumer rights entail then reviews global and domestic interventions. A

brief summary of key points concludes the chapter. The aim of this chapter is to understand how

other government bodies are addressing this issue, what challenges they face and what

interventions they have implemented. This will guide the evaluation and the OCP in terms of

improving or restrategise their programmes.

2.1 Overview of Consumer Protection

Consumer protection may be defined as laws or organisations designed to ensure consumer rights,

fair competition and trade as well as accurate information in the market place. They are designed to

prevent businesses from engaging in fraudulent or unfair practices. Consumer protection is a

government regulation which may require businesses to disclose information about their products

and services and implement programmes which help consumers make better choices as well as

address consumer complaints. It covers a range of topics which include but are not limited to:

privacy rights, unfair business practices, fraud, product liability, misrepresentation and other

consumer interactions.

International organisations such as the United Nations (UN) noted the importance for developing

guidelines to address consumer protection. The UN’s Department of International Economic and

Social Affairs developed Guidelines for Consumer Protections in 1986. They provide a framework for

governments, particularly those of developing countries, to use in explaining consumer protection

policies and legislation. These guidelines for consumer protection have the following objectives:

To assist countries in achieving or maintaining adequate protection for their population as

consumers;

To facilitate production and distribution patterns responsive to the needs and desires of

consumers;

To encourage high levels of ethical conduct for those engaged in the production and

distribution of goods and services to consumers;

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To assist countries in curbing abusive business practices by all enterprises at the national

and international levels which adversely affect consumers;

To facilitate the developing of independent consumer groups;

To further international co-operation in the field of consumer protection;

To encourage the development of market conditions which provide consumers with greater

choice at lower prices (Brown, 2012)

The guidelines indicate that governments should develop, strengthen or maintain a strong consumer

protection policy, taking into account the guidelines set out below. In so doing, each government

must set its own priorities for the protection of consumers in accordance with the economic and

social circumstances of the country, and the needs of its population, and bearing in mind the costs

and benefits of proposed measures. The legitimate needs which the guidelines are intended to meet

are the following:

The protection of consumers from hazards to their health and safety;

The promotion and protection of the economic interests of consumers;

Access of consumers to adequate information to enable them to make informed choices

according to individual wishes and needs;

Consumer Education;

Availability of effective consumer redress;

Freedom to form consumer and other relevant groups or organizations and the opportunity

of such organizations to present their views in decision-making processes affecting them

(Brown, 2012)

2.2 Global Perceptive

2.2.1 Current state of Consumer Protection In 2013 Consumers International –an organisation dedicated to addressing consumer related issues -

conducted a survey on ‘the state of consumer protection around the world’ whereby 72 consumer

organisations in 60 countries took part, including South Africa. The survey addressed the following

four aspects: general consumer protection measures, consumer protection measures in specific

sectors, the legitimate needs of consumers and the consumer rights movement.

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With regard to the first aspect, general consumer protection measures, the importance of consumer

protection is acknowledged in most countries’ legislation with 77% of countries surveyed having a

general Consumer Protection Act although it is concerning that very few have a national policy on

consumer protection. The prevalence of both measures was linked to income levels and low income

countries were less likely to have either in place. Although many types of enforcement action were

employed, it is noteworthy that although 92% of countries impose fines, only 53% of countries

impose compensation orders. The survey noted that South Africa is one of few countries that have

adopted a very comprehensive and rights-based approach. Consumer protection measures were

most prevalent in the following sectors: information and communication technology (ICT),

healthcare and pharmaceutical products, financial services and environmental protection.

The UN Guidelines specify a set of ‘legitimate needs’ that governments should include in developing

consumer protection measures. Countries like South Africa have included basic consumer needs in

their constitutions and most countries have adopted legislation. However, many countries believe

(according to the surveys undertaken) that these laws are ineffective. Despite the widespread

regulation of advertising and use of labelling, the survey results highlighted a significant number of

gaps, particularly in low income countries. Measures to enable the “promotion of sustainable

consumption patterns” are also lacking. Lastly, with regard to consumer rights movement, consumer

organisations around the world play a vital role in protecting consumers and carry out a broad

spectrum of activities, ranging from awareness-raising to legal representation of consumers. The

countries surveyed stated that consumer education, campaigning and complaints handling were top

areas of activity (Consumers International, 2013). Organisations such as the National Consumer

Commission and National Consumer Forum are some of the platforms provided in South Africa to

address the aforementioned issues.

2.2.2 Role of Government and other Role-players Is it crucial for government to intervene in this realm primarily because they are advocates for

consumers, particularly those who do not have the resources to engage consumer related

challenges, and it has the regulatory power to ensure consumer safety. Measures that can be

implemented include: regulatory agencies, product labelling, product recall systems, market

monitoring, product safety laws and bans on unsafe products or imports. Furthermore, government

also has the power to enforce actions in response to consumer violations which include but are not

limited to:

Name and shame;

Compensation orders and criminal prosecution;

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Rescindment of contract;

Civil action and regulatory orders;

Seizure/ exchange or refund of goods and,

Suspension of business license.

Lastly, government can also intervene by providing support to consumer organisations and

programmes in the form of funding education programmes or funding consumer organisations. The

survey also found that not all governments meet their legal obligations to fund the work of

consumer organisations. They are currently struggling to keep up with the pace of technological

developments, but major challenges also remain in ‘traditional’ areas such as financial services.

Consumer organisations play a vital role in protecting consumers, and though this is recognised by

government, they often provide little or no support. Thus government’s involvement through

regulations, education programmes and funding consumer organisations, sets the foundation for

businesses and consumers to engage (Consumers International, 2013).

2.2.3 Interventions in Developing Countries The Kenya Consumers' Organization, the Consumer Council of Zimbabwe, the Housewives League in

South Africa, and the Institute for Consumer Protection in Mauritius are among the most prominent

and oldest of consumer organizations, and these and most others were formed before the late

1970s. They have been advocating for economic democracy because frequently African markets

provide few choices, and many activist groups tie the right to access goods with the right to enjoy

benefits of democracy and economic development.

Although these organisations have been around for a while, there is no clear policy with respect to

consumer education in many developing countries, specifically in Africa. Many government

departments or agencies might undertake small though typically uncoordinated exercises in

education but these are rare and limited. The majority of consumers in developing countries are not

fully aware of the rights they possess or the nature of consumer protection legislation or its

implementation mechanisms. There are very large obstacles to overcoming the problems of

inadequate consumer education. These include a low ratio of literacy particularly in rural

communities together with the high incidence of poverty. A critical issue is the lingering lack of

awareness about consumer issues which prevent consumers acting in their own interests. It should

also be noted that the most effective forms of consumer education are provided on the subject

matter and at the time when issues are of highest concern to consumers. In this regard consumer

education should be needs-based and should attempt to teach skills which go beyond dealing with

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issues immediately evident.

In order to remedy the situation The African Consumer Protection Dialogue (the 'African Dialogue')

was established in 2009 as an effort on behalf of African governments, non-governmental

organisations, and the United States Federal Trade Commission to create informal opportunities to

interface with each other, the United States, and the rest of the world on consumer protection

issues. The African Dialogue is open to the participation from both government officials and non-

governmental organisations from any African country.

Each month, African Dialogue teleconferences serve as the main forum for feedback and

communication between participants. Recently, consumer agencies and NGOs from over 20 African

countries have participated, including Egypt, Morocco, Tanzania, Uganda, Benin, South Africa,

Nigeria, Ghana, Liberia, Kenya, Mauritius, Senegal, Cote d'Ivoire, Zambia, Angola, Mozambique,

Tunisia, and others. The African Dialogue also engaged with the World Bank on the issue of financial

literacy, and looks forward to a collaboration that seeks to promote financial literacy programs in

Africa (International Consumer Protection Network, 2014).

2.3 National Perspective

Across South Africa, many consumers are faced with problems such as poor service, poor quality

products and misrepresentation, whereby service providers do not deliver what was intended. This

leads to consumers losing millions of Rands every year. Furthermore, consumers are often not aware

that they have consumer rights, which are based on consumer protection guidelines developed by

the United Nations (UN) in 1985 (Financial Services Board, 2014).

Consumers are protected by law - meaning that they can demand redress. There are a number of

regulations intended to protect consumers, namely the Consumer Protection Act (Act 68 of 2008)

and the National Credit Act (Act 34 of 2005). Consumers also have the right to information and

education. According to the Consumer Protection Act (CPA) consumers have the right to:

1. Be heard: on issues, policies, plans, programmes and decisions which affect them.

2. Safety: be protected against flaws or hidden dangers in products or services.

3. Redress: When sold an inferior product or service, consumers have the right to demand a

replacement or a refund.

4. Be informed: be given all the information they need about a product or service.

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5. Choice: the right to a variety of products and goods that are competitively priced.

6. Consumer education: education that will empower them to make informed choices.

7. Satisfaction of basic needs: the right to basic goods and services for survival, such as food,

water, education and sanitation.

8. A healthy environment: a physical environment that will enhance the quality of life.

Before consumers lodge a complaint they are encouraged to first try to settle their complaint

directly with the business or service provider. If that fails, the second step is to take it up with the

necessary Provincial Consumer Affairs Offices. These offices, in all nine provinces, offer advice,

education, information, and protection. There are also a variety of national organisations mandated

to address issues of consumer protection, these include: National Consumer Commission (NCC),

National Consumer Forum (NCF), South African National Consumer Union; Association for Savings

and Investment South Africa, Financial Services Board (FSB) and the Commission for Conciliation,

Mediation and Arbitration, as well as sector-specific ombudsmen.

2.4 Provincial Perspective

In accordance with the Unfair Business Act (2002) and Consumer Protection Act (2008) eight

consumer protection offices were established as a provincial consumer protection authorities

mandated to offer services, information, and education and redress services relating to consumer

protection. With that in mind the Western Cape OCP has three sub-programmes designed to address

the aforementioned mandate, namely the CEA, the CCM and Consumer Tribunal, which is currently

inactive.

Figure 2: Organisational Structure

Office of the Consumer Protector

Legal Institutional Support - Tribunal

Complaints Management Consumer Education and

Awareness

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The CEA programme addresses issues relating to increasing Western Cape citizen’s awareness about

their consumer rights, the OCP and its service offerings and work towards a change in the behaviour

of consumers and businesses. Socio-economic characteristics such as fluctuating living standards,

urban sprawl and high levels of illiteracy have contributed towards developing the consumer

education interventions in the Western Cape. Some of the interventions proposed for

implementation include:

Financial literacy education workshops (which is not discussed in this evaluation);

Print media such as advertorials, stories and interviews;

Free radio broadcasts e.g. mainstream and community platforms;

Community based-workshops organised by the OCP staff and;

Information sessions and campaigns targeting the general public.

Similarly, the CCM addresses challenges relating to complaints lodged by consumers. Projects and

interventions proposed include: the establishment of a Panel of Experts and Consumer Tribunal

(which are not included in the evaluation scope) as well as varying contact platforms such as:

1. Toll free number;

2. Walk-in facility,

3. E-mail system;

4. SMS

5. Please-call-me system

6. Fax

7. Snail Mail

8. Social Media

2.5 Key Findings

In conclusion, the UN guidelines provided a foundation for countries to establish a consumer

protection framework. Due to varying socio-economic, political and financial disparities between

developed and developing countries, the frameworks also vary in focus and detail. The following

lessons can be learnt:

Developing countries need to consider policies specifically for consumer education in order

to improve awareness (peri-urban and rural areas);

Increase the awareness of consumer protection rights and implementation mechanisms

(how consumers can receive assistance) and also take cognisance of the target group’s

literacy rates;

Education programmes should be designed in such a way that they are needs-based so that

they are more applicable to target groups;

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Engaging on platforms such as the African Consumer Protection Dialogue offers

opportunities to note how other African countries approach consumer protection and to

share/ tweak interventions and,

Further consideration should be given for financial literacy.

Building on the aforementioned guidelines, it should also be noted that in developing countries:

There is a need for more education and awareness programmes particularly in Africa.

Current levels of awareness are very low and the focus should be on consumer rights and

legislations;

Focus areas should be on areas with low literacy rates and high poverty, they are considered

to be more vulnerable than others and;

It should be also noted that in order to implement an effective education and awareness

programme, the subject matter should be relevant to consumers at that time – to be

determined by a needs assessment.

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Chapter 3: Evaluation Methodology

In order to address the aforementioned problem statement in a comprehensive manner, this section

highlights how the evaluation methodology was approached. For the CEA programme, a sample of

400 citizens was required and 310 for the CCM programme. The data collected assists in the

evaluation of the programmes’ objectives and outcomes. The section is followed by a discussion on

the evaluation guidelines as stated by the DPME and ethical considerations. The aim is to provide an

understanding of how the data was obtained, how it is guided according to government standards as

well as limitations that may impact the evaluation.

3.1 Research Strategy

3.1.1 Research Design

The evaluation comprises of a descriptive research design. Descriptive research designs help provide

answers to the questions of who, what, when, where, and how associated with a particular research

problem. The research approach comprised of both qualitative and quantitative data.

3.1.2 Sampling Technique

A Stratified Sampling Technique was used to sample the population. When sub-populations vary

considerably, it is advantageous to sample each subpopulation (stratum) independently. The

sampling was representative of all residents of the Cape Metro area as well as the Cape Winelands

District and the Eden District. The Overberg region was not included to due financial and logistical

limitations; it was not cost effective to travel a long distance for very few surveys.

As such it is necessary to ensure that the universum is stratified. This required delineating all

households within each suburb not only on a geographical basic but also in terms of other identified

characteristics. This included gender, race, age and home language. Once delineated, each

characteristic investigated was weighted and a proportionate sample was determined for each

geographical area. The number of surveys per geographical area was then adjusted to ensure that

the probability of gaining a response for each characteristic was ensured.

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3.1.3 Sample Size

According to the terms of reference at least 400 face-to-face questionnaires were required for the

CEA programme and at least 310 telephonic questionnaires were required for the CCM Programme.

Table 3: Number of CEA questionnaires required per region

District Distribution Sample Size

Cape Metro 282

Cape Winelands 114

Eden 54

TOTAL 450

As indicated in Table 1, an additional 50 surveys were required to ensure a bigger sampling scope

that accommodated factors such as race, language and gender. The sampling frame for the CCM

programme comprised of closed cases irrespective of the number of complaints resolved.

Table 4: Number of CCM Questionnaires Required

Q4

(2013/2014)

Q1

(2014/2015)

Q2

(2014/2015)

Q3

(2014/2015)

Total number of closed cased: 1,492 365 456 373 293

% of sample frame 24,5% 30,6% 25,0% 25,0%

Number of interviews to administer

per quarter

76

(75,8)

95

(94,7)

78

(77,5)

62

(61,9)

Number of interviews administered

per quarter

76 95 78 62

3.1.4 Data Collection Methods

The following data collection methods were used to compliment the qualitative and quantitative

research approaches:

1. Document Review (Secondary data source)

(Existing documents provided by DEDATs M&E Team and additional research)

2. Interviews (Primary data source)

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Face-to-face interviews and telephonic interviews

3. Questionnaires (Primary data source)

Paper-pencil questionnaires

Questionnaires were administered using two techniques: structured techniques and semi-structured

techniques. With that in mind, the following questionnaires were designed:

Semi-structured & open-ended questionnaire for stakeholders

(OCP Director, CEA Programme Manager, CCM Programme Manager, Regional Co-ordinator,

Call Centre Manager and Strategic Partner to be administered over 45min to 60min)

Semi-structured & close-ended questionnaire for programme beneficiaries

(Face-to-face surveys and telephonic surveys to be administered in approximately 3min. The

surveys were translated into Afrikaans and isiXhosa.)

In conclusion, the chosen research design, data collection methods, data sources and sampling

technique provided the necessary support required to address matters highlighted in the problem

statement as well as strategic intent.

3.1.5 Limitations to Study As with any research or study, limitations can be expected. Below is a summary of limitations

experienced during the data collection:

CEA data collection CCM data collection

Questionnaires were administered between

08h00 and 17h00 when the working-age

population had gone to work, leaving students

and the elderly to participate.

Some respondents’ contact details were

either: incomplete or non-existent or wrong

number.

Respondents had limited knowledge about

consumer rights and protection thus it took

approximately 20min to explain and administer

the purpose of the questionnaire.

Some respondents’ details were duplicated

across different quarters. In most cases, the

respondent indicated that only one

complaint was lodged.

Caucasian citizens were not interested in

participating particularly in small towns such

as Wellington, Ceres, Mossel Bay and Paarl.

Respondents mistook fieldworkers as the

OCP and expressed negative feedback before

dropping the call.

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3.2 Evaluation Guidelines

In order to ensure that government evaluation studies are carried out accordingly, specific

government guidelines and standards had to be followed. The DPME’s Standards for Evaluation in

Government (2012) have a set of standards that intend to support the use of evaluations conducted

through the national evaluation system through setting benchmarks of evaluation quality. They are

based on the National Evaluation Policy Framework (NEPF, 2011). According to the NEPF there are

four main purposes of evaluation, namely:

1. Improving policy or programme performance (evaluation for continuous improvement). This

aims to provide feedback to programme managers.

2. Evaluation for improving accountability e.g. where is public spending going? Is this spending

making a difference?

3. Improving decision-making e.g. should the intervention be continued? Should how it is

implemented be changed? Should increased budget be allocated?

4. Evaluation for generating knowledge (for learning): increasing knowledge about what works

and what does not with regards to a public policy, programme, function or organisation.

The South African government’s approach to putting into operation these four purposes intends to

promote the use of evaluation. Likewise the standards contained in this document encourage the

utilisation of findings and consider standards in relation to five stages of evaluation: (1) overarching

considerations prior to the evaluation, (2) planning the evaluation, (3) the evaluation process, (4) the

evaluation findings, and (5) the eventual use. These South African government evaluation standards

are based on a review of a range of international evaluation standards, their strengths, weaknesses,

and appropriateness for South Africa.

According to the NEPF (2011) evaluation poses questions against a pre-existing plan or strategic

intent. It seeks to determine whether plans are achieving their intended impacts, and to assess the

causal links between activities carried out under the plans and observed impacts. However, if plans

are not clear, then it is difficult to evaluate. A challenge in South Africa is that plans are of variable

quality and sometimes do not clearly identify the desired results and impacts and how these results

will be measured, to enable the plans to be evaluated. This Policy Framework therefore also includes

a brief section on key principles of planning which should be followed to enable evaluation to take

place effectively. Thus the evaluation process will assist the OCP’s programmes by assessing its

current processes, identifying opportunities and gaps that require further attention, improve their

implementation as well as monitoring and evaluation. Most importantly, the process will encourage

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both programmes to assess their relevance (and/or use) and reflection in preparation for the next

implementation period.

3.3 Ethical considerations

The CEA and CCM questionnaires were designed with consideration for human subjects. They were

not in any way offensive or leading. Before administering each survey, fieldworkers introduced

themselves, the company which they represented and the purpose of the questionnaire. Thereafter

fieldworkers asked respondents whether they would be willing to participate. Those who indicated

lack of interest were thanked and those you indicated interest were informed that they could at any

moment ask to skip a question if they were not comfortable answering. In order to ensure privacy

and discretion, respondents were not asked to provide their contact details, physical addresses or

any personal information. Those interested in providing their name (and surname) were also

informed that they could. Respondents were not given any incentives to participate, it was solely

based on their choice to participate or not.

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Chapter 4: Evaluation Framework

Chapter four sheds light on the steps involved in formulating the evaluation framework for the

outcomes evaluation. It begins by unpacking the theory of change involved in identifying favourable

interventions then provides an overview of the objectives, performance indicators, rating and

weighting of indicators. Annexure A provides more details on the Evaluation Framework.

4.1 Theory of Change (TOC)

4.1.1 Defining a TOC

TOC can be defined as a theory of how and why a programme or intervention works however, a TOC

approach to evaluation is defined as a systematic and cumulative study of the links between

activities, outcomes, and contexts of the initiative. This approach is used to find evaluation strategies

and methodologies that correspond well to the goals and designs of a programme or intervention

(Connell & Kubisch, 1998). The above indicates that the first step towards evaluating a programme is

to determine its intended outcomes, the activities it expects to implement to achieve those

outcomes, and the contextual factors that may have an effect on implementation of activities and

their potential to bring about desired outcomes (Connell & Kubisch, 1998). Grounding a programme

in good theory of change offers three advantages:

1. A theory of change approach can sharpen the planning and implementation of an initiative;

2. With a theory of change in hand, the measurement and data collection elements of the

evaluation process will be facilitated;

3. Articulating a theory of change at the outset and gaining agreement on it by all stakeholders

reduces, but does not eliminate, problems associated with causal attribution of impact.

In addition to the above a good TOC should be plausible, doable and testable. This can be achieved

by drawing upon various sources of information-program experience, scientifically generated

knowledge, and community residents' insights, to name some of the most important

4.1.2 Implementing a TOC Evaluation

Building on the TOC definition, the next stage involves describing how an evaluation based on a

theory of change might be carried out. The first step is to map out a process that should produce a

plausible, doable, and testable theory of change. Thereafter questions of how and when to measure

activities and outcomes included in the theories will be addressed. The final step is to examine

whether the information being generated is credible enough to make judgments about how well the

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programme is working. The table below provides a brief summary of the TOC approach to evaluating

programmes:

Table 5: Theory of Change Approach to Evaluation

STEP SUMMARY

Developing and

articulating a

theory of change

Programme implementers and stakeholders are encouraged to use the

participatory planning process to generate a theory of change that is viewed as

plausible, doable, and testable.

The following questions are recommended to be considered as part of the

planning process:

What longer-term outcomes does the programme seek to accomplish?

What interim outcomes and contextual conditions are necessary and

sufficient to produce those longer-term outcomes?

What activities should be initiated and what contextual supports are

necessary to achieve the early and medium-term outcomes?

What resources are required to implement the activities and maintain

the contextual supports necessary for the activities to be effective, and

how does the initiative gain the commitment of those resources?

Measuring a

programme’s

activities and

intended

outcomes

In any evaluation, outcomes and activities must be translated into observable

measures. Moreover, measurement in more circumscribed programme

evaluations tends to draw primarily on quantitative techniques, such as

enumerating participation through administrative records, surveying clients to

gauge exposure and experience, and actuarial activities to measure discrete

client outcomes

Measures of outcomes and activities must be developed at multiple levels. In the

case of outcomes, as in any other evaluation, some are more difficult to measure

than others.

Analysing and

interpreting the

results of an

evaluation,

The theory of change approach opposes that the more the activities predicted by

theory actually occur over the course of the programme, the more confidence

evaluators and others should have that the initiative's theory is right. We

suggest, then, that the major audiences for an evaluation of a CCI-including

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including their

implications for

adjusting the

initiative's theory

of change and its

allocation of

resources.

community residents, initiative managers and funders, and policy makers-should

be convinced that the initiative "worked" if four points can be demonstrated:

Up front and along the way, a well-specified and plausible theory of

change described steps toward an anticipated change (from historical

baselines) in important outcomes for the community, its institutions, and

its residents;

The activities of the programme that were part of these steps were

implemented at expected thresholds;

The magnitude of changes in the early, intermediate, and long-term

outcomes that followed these activities met predicted thresholds;

No obvious and pervasive contextual shift occurred that could otherwise

account for all these predicted sequences of activities and outcomes

4.1.3 Past Implementation of TOC Evaluation Approach

In a previous evaluation of the OCP in 2014, it was noted that the unit considered TOC as part of

delivering its interventions. It was tailor-made through discussions with DEDAT and the evaluator in

order to guide the evaluation process. The TOC presented beliefs about what was required by the

programme’s target population and various strategies that would enable them to address the

requirements. According to Devmonics (2014) the TOC established “a context for considering the

connection between a system’s mission, strategies and actual outcomes, while creating links

between who is being served, the strategies or activities that are being implemented, and the

desired outcomes” (Devnomics Developmentnomics Pty (Ltd), 2014). The following interventions

noted for the CEA and CCM programme in the 2010-2015 strategic plan, of which some were carried

over to the 2015-2020 plan, will be assessed to determine whether this evaluation approach is

conducive:

Table 6: OCP Programme Interventions

CEA Programme CCM Programme

Identifying suitable content per area (e.g

financial literary vs. social media marketing)

Toll Free Call Centre

Identifying workshop approach per region (e.g.

suitable time, target audience, content design,

Walk-in Centre

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CEA Programme CCM Programme

length of workshop, etc)

Identifying suitable marketing techniques

regionally (and per workshop)

Dispute resolution

Stakeholder engagement & identifying

supporting consumer policy

Budget determination

Focus on SMME particularly regarding financial

literary

Social research and social dialogue

4.2 Programme Design and Features

The table below illustrates programme features that will be unpacked in Chapter 6 for further clarity

where the programme design is concerned. They are worth noting now so as to guide the evaluation

framework.

Table 7: Programme Features

Strategic Plan 2010-2015 Updated Draft Strategic Plan 2015-2020

Strategic

Objective

A business environment that reflects high levels

of consumer rights awareness by a majority of

the Western Cape population and business

community, supported by effective complaints

management and resolution mechanisms.

To provide an effective and efficient

consumer protection service within the

province which is aligned to the objectives

and functions prescribed by provincial and

national consumer protection legislation.

Objective

Statement

Through various education and awareness

initiatives ensure that at least 60% of public in

the Province are aware of the OCP and services

it offers and the establishment of 25 Consumer

NGO’s partnerships.

To ensure that the WCG Provincial Strategic

Objective of making the Western Cape a

destination of choice in which to do business

is achieved through the provision of an

effective complaints resolution service,

ensuring that a minimum of 20 000

complaints are dealt with over five years,

resulting in a financial saving to consumers of

at least R15 million.

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Strategic Plan 2010-2015 Updated Draft Strategic Plan 2015-2020

Baseline

Low levels of awareness, where only

approximately 3 in 10 consumers are aware of

basic consumer rights. A highly effective

complaints management and resolution

mechanism at head office with low level service

delivery through NGO structures in rural areas.

2013/2014 financial year: Complaints

received =10 554; Complaints resolved = 10

063; Financial saving of R4 million.

Outcomes

1.A reduction in the number of regulatory

barriers that inhibit business growth and

development; and

2. An enhanced governance structure and

protocol within the programme.

1. Enhanced protection of consumers in the

Western Cape culminating in a value saving of

R30 million for consumers by virtue of the

assistance provided by the OCP during the

five-year period.

2. Ensuring that 200 SMMEs in the Western

Cape implement administrative and policy

procedures which comply with consumer

protection legislation.

3. Ensuring that the service satisfaction level

among consumers using the OCP's services is

enhanced by 20 per cent over the five-year

period.

Performance Indicators

When assessing the illustrated in the table below, performance indicators appear to be stagnant

between 2012/13 and 2014/15. The evaluation and impact assessment will also investigate why this

is the case and how this has implications and/or links to the objectives identified. This will include

determining whether these indicators are plausible and testable and how they have contributed to

the existence of ‘baselines’ (as identified in Table 5). Table 6 illustrates how the performance

indicators have remained the same for three years:

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Table 8: Sector Specific Performance Indicators

2012/13 2013/14 2014/15

Number of consumer

education programmes

conducted

Number of consumer education

workshops/ information programmes

conducted

Number of consumer education

programmes conducted

Number of complaints

received

Number of complaints

received

Number of complaints

Received

Number of complaints

resolved

Number of complaints

resolved

Number of complaints resolved

Number of consumer

Protection information

sheets/booklets developed and

distributed to citizens and

business

4.3 Evaluation Framework

The Logical Framework Approach (also known as the Log Frame) is systematic, analytical process for

project planning – in this case planning an evaluation. It helps to present the project in a standard

format to planners, decision makers and managers and serves as a reference for project

management. Below are definitions of the Log Frame elements. They categorise objectives in such a

manner that analyses linkages and determines whether the objectives are being achieved.

Inputs Specific tasks performed using resources and methods in order to achieve the

intended outputs.

Outputs Products and services produced or competences and capacities established directly

as a result of project activities.

Impacts Improvements of a situation in terms of social and economic benefits which respond

to identified development needs of the target population under a long-term vision.

Outcomes Intended situation at the end of or soon after the project's lifespan in terms of gains

in performance (as a result of changes in knowledge and behaviour).

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Table 9 illustrates HOW the elements are used in monitoring and evaluation.

Table 9: Use of Elements in Log Frame

Evaluation

Objectives

What has the programme achieved? Where has it failed or succeded?

What are possible explanations for this? Were there any unplanned or

unintended changes?

Activities (Inputs)

“what we do” “what we use

to do the work”

Was the budget sufficient? Did the inputs/activities contribute to the

expected outcomes?

Outputs

Did citizens’ awareness about the OCP and their consumer rights

increase? Are citizens who used the complaints platform satisfied with

the services received?

Outcomes

“what we wish to achieve”

What are the beneficiaries opinions and experiences of the service

being provided? Has the programme impacted them in any way?

Impacts

“how we have actually

influenced communities and

target groups”

Has the project brought about any change or improvements since

implementation?

By understanding the objectives, baseline and outcomes of the OCP programmes, it becomes

simpler to create linkages with performance indicators and stakeholders as well as guides

evaluation. The objectives are included/ identified in stage one of the Project Cycle – Programme

Identification so as to link with the issues. Based on the literature provided and an understanding of

the OCP’s main objectives, outcomes and performance indicators, the following sub-objectives were

identified for the purpose of this evaluation, to assess whether both programmes were implemented

accordingly:

1. Educate and create awareness amongst Western Cape citizens about their consumer rights

and the OCP;

2. Implement a cost-effective marketing strategy through various platforms;

3. Ensure that PDAs are priority areas in which to educate and create awareness;

4. Ensure that workshop content complements challenges in targeted areas;

5. Ensure that programme design is unambiguous between programme managers and citizens;

6. Skilled and sufficient staff to implement marketing and manage consumer complaints

7. Sufficient financial capacity to implement programmes

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These objectives each have indicators, objective weighting as well as indicator ranking which help

assess to what extent they are being achieved. Table 10 outlines seven sub-objectives which were

identified and the corresponding key performance indicators used to measure the attainment of

each objective. The weighting and ranking of objectives and indicators were done as follows:

1. Weighting of Objectives: Seven sub-objectives were identified and each of these objectives

was weighted according to their importance in the evaluation of the OCP programmes. The

weighting was determined out of a score of 100%. The more important the objective the

higher the score. The objectives have different weightings because some are considered

more important than others; they set the foundation on which other objectives can be

realised. This was determined by assessing the content and depth of information obtained

through stakeholder and citizen interviews as well as key elements identified in the case

study analysis.

2. Ranking of Indicators: For each of the objectives identified, a number of key performance

indicators were listed in order to measure the objective. Each objective’s indicators were

ranked based on a score of 100% (i.e. Objectives 1: the ranking scores of each indicator

within objective one adds up to 100%). The indicators are also ranked differently – the

highest percentage allocation ranked more than the lowest. This is due to the fact that

within each objective, there are indicators which must take priority in order to

accommodate the rest of the indicators

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OCP Objective:

A business environment that reflects high levels of consumer rights awareness by a majority of the Western Cape population and business community,

supported by effective complaints management and resolution mechanisms.

The following table provides an outline of the evaluation framework objectives, key performance indicators, relevant questions for each indicators as well

as the weighting (of objectives) and ranking (of the indicators).

Table 10: Evaluation Framework

Objective Key Performance Indicators Objective

Weighting

Indicator

Ranking

1. Educate and create awareness amongst

Western Cape citizens about their

consumer rights and the OCP

1.Number of programmes and workshops conducted

15%

15%

2. Number of print material given out at each workshops 25%

3. Content variety of print material 25%

4. Level of awareness about consumer rights 15%

5. Number of complaints received 10%

6. Number of complaints resolved 10%

2. Implement a cost-effective marketing

strategy through various platforms

1. Available marketing platforms

15%

50%

2. Number of complaints received 20%

3. Number of complaints resolved 30%

3. Ensure that PDAs are priority areas in

which to educate and create awareness 1. Target Previously Disadvantaged Areas 15% 100%

4. Ensure that workshop content

complements challenges in targeted areas

1. Conduct a needs assessment to determine consumer related challenges

and awareness in PDAs 15% 50%

2. Content is informative and easy to understand for citizens 50%

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Objective Key Performance Indicators Objective

Weighting

Indicator

Ranking

5. Ensure that programme design is

unambiguous between programme

managers and citizens

1. Clearly defined terms and phrases such as 'case closed'

10%

30%

2. Clear outline and articulation of complaints management process to

consumers 30%

3. Design interventions based on needs assessment conducted 20%

4. Level of satisfaction with complaints management 20%

6. Skilled and sufficient staff to implement

marketing and manage consumer

complaints

1. Identify relevant and supporting skills suitable to achieve programme 15%

40%

2. Sufficient staff to address Western Cape population (on and off the ground) 40%

3. Capitalise on departmental training programmes 20%

7. Sufficient financial capacity to

implement programmes 1. Budget for marketing material and workshop administration 15%

35%

2. Budget for staffing (and training) 30%

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Chapter 5: Primary Findings and Impact Assessment

This chapter discusses the primary findings obtained from stakeholder interviews as well as face-to-

face and telephonic interviews with Western Cape citizens. The chapter begins by discussing how

the CEA and CCM programmes are designed and carried out, programme successes as well as

challenges. This will be followed by a discussion on Western Cape citizens’ level of awareness

regarding their consumer rights and their level of satisfaction.

5.1 Primary Findings

The table below summarises the demographic profile of respondents who participated in the survey

questionnaires. It indicates and identifies gaps where further intervention may be required. Further

details are available in Annexure B. The information also contributes to the sections that follow.

Table 11: Summary of CEA and CCM Demographic Profile

Age

CEA respondents’ age distribution includes respondents who may be considered youth in

their twenties or less (14.0%) or 21-30 (31.8%). On the other hand, CCM respondent

mainly comprise of the working age population which ranges between 21 and 60. The

majority of respondents were aged 41-50 (34.1%) followed by 51-60 (22.0%).

Gender

Most of the CEA respondents were female (56.4%) compared to the CCM respondents

which was 39.6% of the population. This may be attributed to observations noted during

CEA questionnaire administration that mostly women were available and more accessible

because they were either housewives, unemployed, students awaiting school to resume

or elderly.

Language

The most prevalent language amongst CEA respondents was Afrikaans (51.6%) followed

by isiXhosa (32.0%). Other languages included Igbo, Sesotho, Setswana and isiZulu. CCM

respondents were a mix of English (39.8%) and Afrikaans (35.7%), and also indicated that

they were bilingual. Additional languages also included those indicated by CEA

respondents as well as French, Portuguese, Shona and Venda.

Marital Status

CEA respondents comprised mainly of single (54.2%) and married (34.8%) people while

CCM respondents comprised of the inverse, with 63.7% married people and 23.9% single

people. These differences may be linked and attributed to the age structure – younger

populace is assumed to be unmarried compared to the older populace.

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Race

The most prevalent race amongst both sample populations is the Coloured group (45.2% and

38.1%). In 2014 there were more Black people who participated in the CEA questionnaire

(35.8%) compared to those who contacted consumer complaints (28.8%). Inversely, less

White people participated in the CEA questionnaire (18.8%) and more contacted customer

complaints (30.8%). This highlights areas of focus in future.

Employment Status

CEA respondents’ employment status had a wider variation compared to CCM respondents.

The sample population comprised of full time employees (33.5%), unemployed people

(21.8%) and students (21.3%). On the other hand, 61.7% of CCM respondents were

employed full time, 12.5% self-employed and 10.9% retired. These differences may be

attributed to the sample population’s income source and household income, which are

discussed below.

Income Source

Respondents from groups have salaries (65.2% and 81.8%) as their main source of income.

However, the rest of the CEA respondents sources their income from government grants

(17.2%) and wages (16.0%) while CCM respondents sourced from investments (6.7%) and

government grants (6.7%). These government grants were primarily for pensioners as well as

unemployed respondents with children. The above indicates differences in the income

groups. Additional income sources included: family members, disability grants and bursaries.

HH Income

The majority of CEA respondents take home R5,000 or less per month (50.6%) followed by

those who take between R5,001 –R10,000 (17.6%). On the other hand CCM respondents had

more household income ranging between R5,001 –R10,000 (34.4%) and R20,001 ore more

(25.0%). This may be attributed to the type of jobs and skills set respondents poses, and this

is illustrated in the next tab regarding education.

Education

Both sets of respondents’ highest level of education included tertiary (39.9% and 48.3%) as

well as matric (35.6% and 33.8%). However during engagement CEA respondents indicated

that their tertiary qualifications comprised mostly of short courses, certificate programmes

and national diplomas while CCM respondents indicated national diplomas, degrees and

short courses.

The demographic profile of CEA respondents shows the characteristics of a PDAs. When comparing

aspects such as employment status, income sources and household income it is evident that CEA

respondents were in a less advantageous position opposed to CCM counterparts. The impact

assessment below will be able to reveal whether the OCP’s interventions are achieving the CPA’s

mandate regarding consumer education and awareness as well as how effective, platforms such as

consumer complaints have been.

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5.2 Impact Assessment

This sub-section combines and analyses the data obtained from the department’s policies and

regulations, stakeholder interviews as well as CEA and CCM questionnaires administered to Western

Cape citizens. The analyses aims to provide an understanding of how both programmes have been

operating and whether stakeholders and citizens share a similar perspective about what is being

done and how. Sub-section 5.2.2 will then evaluate the impact of each objective.

5.2.1 Analysis of Findings

Objective One: Educate and create awareness amongst Western Cape citizens about their

consumer rights and the OCP

The CPA of 2008 outlines the importance of creating consumer education and awareness as well as

the roles and responsibilities of provincial consumer authorities to help achieve this mandate.

Platforms for educating Western Cape citizens include workshops and campaigns as well as

stakeholder engagement. The content includes educating citizens about their consumer rights and

all aspects relating to consumer protection as well as how the OCP can assist. In 2014, an estimated

230 workshops were held across the province. With regard to the CCM programme, 12,000

complaints where received and 9,000 complaints where resolved in the 2014/15 financial year,

although not all were necessarily investigated. The analysis below indicates whether consumers

are/were aware of their consumer rights and the OCP’s presence. As stated Chapter 2 of the report,

the CPA stipulates eight consumer rights, which are summarised below as follows:

1. The right to safety and equality in the consumer environment that enhances quality of life;

2. The right to privacy and protection against flaws or hidden dangers in products or services;

3. The right to fair and responsible marketing when sold an inferior good or service;

4. The right to disclosure and access to information which will empower consumers to make

informed choices;

5. The right to choice to products and goods that are competitively priced;

6. The right to honest dealing;

7. The right to fair, just and reasonable conditions;

8. Suppliers accountability to consumers

39 | P a g e

CEA Programme

The majority (77.2%) of sampled Western Cape citizens indicated that they were aware of their

consumer rights. Respondents indicated their awareness as indicated in the table below. Note: each

consumer right is calculated out of 100%.

Table 12: Consumers’ Level of Awareness about their Consumer Rights delineated per right (CEA respondents)

Respondents also stated that they knew more rights than others, such as the right to choice (97.3%)

and the right to privacy (96.9%). However they also emphasised on the inability to practice these

rights when faced with challenges from businesses. This was most prevalent amongst respondents

who reside in PDAs than those in affluent areas. They stated that they had more urgent priorities

such as sustaining their households than sparing time to learn more about their rights. They also

stated that they are deterred by the type of language used because they do not understand what

the rights really entail – as a result of poor literacy. On the other hand, respondents in affluent areas

have relatively easy access to platforms such as the internet or mainstream radio where issues about

consumer rights are discussed in detail. Their level of education and higher household income

affords them an opportunity to access search engines and do their own research. They are also more

aware about their rights in greater detail than respondents in PDAs. Similarly, respondents also

indicated that they were relatively aware of the laws that govern consumer protection, namely:

Consumer Protection Act, 2008 (91,9%)

Businesses Act, 1991 (87,4%)

Small Business Amendment Bill, (81,8%)

Western Cape Consumer Affairs (Unfair Business Practices) Act, 2002 (82,8%)

95.2%

96.9%

96.0%

95.0%

97.3%

95.7%

94.9%

94.9%

Safety and equality

Privacy

Fair and responsible marketing

Discloure and access to information

Choice

Honest dealing

Fair, just and reasonable conditions

Suppliers accountability to consumers

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Only 14.2% (CEA sample) of the respondents indicated that they were aware of the OCP and only

7.6% knew about the services provided2, of which the majority were respondents from affluent

areas. Some respondents’ professions ranged from municipal workers to law professionals as well as

small business owners. That professional bases allowed them to be more exposed about consumer

rights, how they can implement then and research organisations to approach. Their understanding

of the OCP’s operations ranged from “It fights for what is right and is beneficial to the consumers

rights” to “There to assure us by protecting our rights and giving us advice when needed” and

“Handles all enquires and complaints to retailer”. Respondents in PDAs were mostly aware of the

CPA only because it sounded familiar; not because they knew its contents.

When asked whether they were aware of other government departments and private companies

22.3% indicated that they were aware of the following: the Public Protector, CCMA, Legal Aid

(15.0%), Legal Wise and Scorpions. Respondents from PDAs were more aware of the

aforementioned because of their presence in peri-urban areas; door-to-door marketing of services

as well as promotions hosted at community gatherings or from local youth members recruited to

hand out pamphlets in the community. The affluent respondents (15.6% of the CEA respondents)

indicated they were aware of a consumer protector (46.7%) and provincial government but were not

sure whether it was the OCP specifically, until they had conducted their research. The implications

of this are that most of these respondents are aware that a consumer protector body exists,

however it was only after internet research that they became aware the Western Cape has such a

body.

Table 13: Consumer’s Awareness of interventions implemented by the OCP

2 It should be noted that the full name, namely Office of the Consumer Protector, was used when conducting

surveys and not the abbreviation.

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Very few respondents (4.7%) indicated that they attended any OCP workshops/ information sessions

in their community, heard about it on the radio (11.2%), read about them in the community

newspapers (10.8%) or were given any brochures (5.0%). Although 217 workshops out of a target of

230 were held by the OCP between Quarter one and three, more workshops are required in more

areas.

CCM Programme

Regarding consumer complaints, only 41.0% of respondents who used the consumer complaints

platform indicated that they knew about the OCP before lodging their complaints. The

geographical spread included respondents from both PDAs and affluent areas such as Mitchells

Plain, Grassy Park, Bellville, Park Lands. Constantia and the Cape Metro. Most of the respondents

were not aware of their consumer rights. Respondents were also asked to rate their level of

awareness which is expressed as follows:

No – Poor: respondent is not aware of consumer right; their knowledge is poor,

Yes-Excellent: respondent is aware of consumer right; their knowledge is excellent,

Yes – Good: respondent is aware of consumer right; their knowledge is good,

Yes – Fair: respondent is aware of consumer right, their knowledge is fair,

4.7%

11.2%

10.8%

5%

95.3%

88.3%

89.2%

95%

Attend workshops/info sessions

Heard about OCP on radio

Read in Community Newspaper

Read in Brochures

No Yes

The above analysis shows that despite the effort invested by the OCP to educate and create

awareness to citizens about their consumer rights and the presence of the OCP, there is still a lot

more to be done. Citizens have some knowledge about their rights but they do not know where

to go or who can assist when those rights are violated; they are not aware of the OCP and the

services offered.

However, the fact that some citizens are aware should be acknowledged. It shows that the OCP

managed to achieve their objective with the existing budget. The above information also affords

the OCP an opportunity to re-think their marketing campaigns and content.

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Yes – Poor: respondent is aware of consumer right, their knowledge is poor.

Table 14: Consumers’ Level of Awareness about their Consumer Rights (CCM Respondents)

No - Poor Yes-Excellent

Yes -

Good Yes - Fair Yes - Poor

Safety and equality 29,0% 5,2% 23,0% 35,1% 7,7%

Privacy 24,3% 7,0% 27,9% 33,1% 7,7%

Fair and responsible marketing 22,9% 6,5% 27,9% 36,3% 6,5%

Disclosure & access to information 26,5% 6,2% 25,3% 35,4% 6,6%

Choice 22,3% 6,3% 29,7% 35,3% 6,3%

Honest dealing 21,5% 7,4% 27,3% 36,3% 7,4%

Fair, just and reasonable conditions 23,5% 6,7% 25,5% 37,3% 7,1%

Suppliers accountability to consumers 25,8% 7,4% 25,0% 33,6% 8,2%

Respondents indicated that their level of awareness was generally fair particularly for rights such as

fair, just and reasonable terms and conditions (37.3%), fair and responsible marketing (36.3%) and

honest dealing (36.3%). This may be attributed to the nature of complaints that they lodged.

Respondents from PDAs were less aware of their rights at the time of lodging a complaint compared

to their affluent counterparts, who with the help of the internet, managed to do background

research prior to lodging their complaint. This may be attributed to the fact that when low income

citizens’ consumer rights are violated, they do not have the time or financial resources to conduct

prior research. Instead, they simply want to get the assistance they need as soon as possible so that

they can focus on other priorities.

Furthermore, respondents from the different areas indicated that they were more aware of the CPA,

2008 (60.2%) but did not know its contents in details. Through observation, respondents who

engaged in some form of business related activities were aware of the Business Act, 1991 and Unfair

Business Practices Act, 2002 mostly because they had to have an understanding of what they

include, particularly respondents from PDAs:

Consumer Protection Act, 2008 (60,2%)

Businesses Act, 1991 (22,5%)

Small Business Amendment Bill (19,1%)

Western Cape Consumer Affairs (Unfair Business Practices) Act, 2002 (25,6%)

43 | P a g e

This means that despite having received 12,000 complaints and resolved 9,000 respondents’

knowledge about their consumer rights is very limited and their knowledge about the OCP’s services

is also limited; leading to misunderstandings of how they can be assisted. Once again, factors such as

time and financial resources determine whether citizens can receive education and awareness and

include it their list of priorities.

Objective Two: Implement a cost-effective marketing strategy through various platforms

The OCP’s education and awareness programme implements the above objective by making use of

marketing platforms such as: radio, billboards, back of public transport such as busses and trains as

well as in-store adverts and mall activation. In an interview with the CEA programme manager, it

was mentioned that budget constraints limit the unit from including other platforms such as

television, web based marketing and mainstream radio. Existing marketing material varies in the

form of books and pamphlets either developed by the unit or attained through partnerships with

national consumer commissions or businesses. It was also mentioned that the content address

consumer protection in various industries such as finance and medical however, there seems to be

limited information marketing who the OCP is, what services they offer, who they assist and to what

extent that can happen.

Similarly, some of the material only offers two contact platforms for consumer complaints, namely:

the toll free call centre and the walk in centre. During a stakeholder interview, it was mentioned that

there are six other platforms which citizens can contact the OCP, namely: social media (Facebook,

Twitter and Youtube), please-call-me system, short message texts (SMS), snail mail, fax and e-mail.

With all these platforms, respondents indicated otherwise. The analysis below determines whether

these platforms are available and how effective they are.

CEA programme

As indicated in the sub-section above, 14.2% of respondents indicated their knowledge of the OCP

and they found out about it through the following platforms:

The above analysis shows that the number of workshops and information sessions conducted

needs to increase and cover more areas. Furthermore, the content in the print material available

at these workshops needs to cater to the reader’s literacy level especially for consumer rights.

This also impacts citizens who lodge complaints in the sense that they contact customer

complaints with very limited knowledge or background about what the OCP can do and an

understanding of their consumer rights. During the telephonic interviews complainants expressed

their frustration with the OCP but when asked whether they can relate the nature of their

complaint to their consumer rights, they stated that they were not clear about it. Limited

financial and human resources currently limit the OCP from doing more.

44 | P a g e

Figure 3: CEA – Marketing platforms known by respondents

Upon observation, respondents who

heard about the OCP via television

stated programmes such as “Speak

Out” and “Ilungelo Ngelako” on

SABC One as platforms they heard

consumer protection aspects being

discussed. These programmes are

aired between 18h00 and 21h00

when respondents return home

from work. They are easy to

understand and follow because of

the language used, the pitch and the

‘real-life’ stories which they can relate to. Furthermore, respondents stated that they are not

required to pay anything and the programmes accommodate their work schedule. Contrary to

platforms provided by the OCP, none of the above mentioned marketing in busses, trains, billboards

or shopping malls. This may be attributed to factors such as (1) high passenger volumes at peak time

thus respondents pay limited attention to the adverts and (2) consumer rights knowledge is not

considered as a priority unlike finding employment or providing for the family. Although this may be

regarded as one of the best ways to create awareness and educate citizens, further consideration

could be given to the content and graphic design so as to capture attention.

CCM Programme

Figure 4: CCM – Marketing platforms known by respondents

In 2014, 99.4% of the respondents

lodged a complaint against a

company (89.1%) and some

individuals (8.3%) although they

were not clear about the services

offered by the OCP. Respondents

residing in PDAs heard about the

OCP via word of mouth (35.7%)

from people who heard about

them as well. The internet (34.6%)

2.2%

34.6%

35.7%

16.4%

8.9%

Print media

Internet

Word of mouth

Referral

Radio

31.4%

14.3%

14.3%

12.9%

7.1%

14.3%

5.7%

Radio

TV

From a friend

Local Municipality

Social media

Print media

Workshop

45 | P a g e

was predominantly used by respondents in affluent areas where access to the platform was more

available and affordable. Very few through respondents across both areas indicated print media

(2.2%) because they had not read about it. Similarly these access platforms are quite different from

those used by the OCP to market themselves and their services. Respondents used platforms such as

the toll free call centre (37.0%), e-mail (35.2%) and walk-in centre (24.5%) to lodge their complaints

because those were the only platforms mentioned through word of mouth or found on the internet.

Objective Three: Ensure that PDAs are priority areas in which to educate and create awareness

The OCP is obliged to focus education and awareness programmes in previously disadvantaged areas

(PDAs) as outlined in the CPA, 2008. PDAs may be categorised as areas low income areas with

limited opportunities to access knowledge about consumer rights or resources to take such matters

to court. As discussed in the literature review, there is a need for more education and awareness

particularly in areas with low literacy rates and high poverty rates. The demographic profile of CEA

respondents showed characteristics of the aforementioned.

The CEA programme has regional co-ordinators who are responsible for educating the broader

public about the OCP and their consumer rights, administering workshops with citizens and

institutions as well as assist stakeholders with consumer related matters. There were three regional

co-ordinators operating in the Eden, Overberg and West Coast District however only two are

remaining (Eden and Overberg regional co-ordinators). Regional co-ordinators operate by

themselves and service various areas with specific emphasis on rural and small towns. Due to the

fact that they operate alone, they are faced with challenges when it comes to project

implementation. In an interview conducted with a co-ordinator in charge of the Eden District, some

of the following challenges were highlighted: difficulty to monitor and evaluate workshops before

and after each session, administrative activities such as ensuring that all attendees sign the register

and fill in evaluations forms, inability to conduct an effective workshop with a big group and poor

access to the internet, projectors, flip chart and telephone. This impacts on the frequency of

interaction between co-ordinators and the programme manager, which occurs twice a month in the

The current platforms used by the OCP to market themselves and their services are different from

what citizens are aware of and use. It could be argued that (1) previous studies had identified

those platforms because they are available where the masses are and (2) they were suitable for

the budget provided.

Further investigation is required to determine how platforms such as word of mouth can be

capitalised as well as the referral system and local municipalities. These platforms also present a

cost-effective method of marketing the OCP. This includes strengthening existing and identifying

additional stakeholder partnerships.

46 | P a g e

form of a progress report. Despite these challenges, the co-ordinator indicated that consumer

protection perceptions and awareness have increased in areas visited but can do more with more

resources. There are still quite a number of PDAs that need to be informed and educated.

Based on the above definition of PDAs, regional co-ordinators’ experiences as well as demographics

indicating lack of knowledge about the OCP, the following areas need to be focused on in greater

detail: Atlantis, Blue Downs, Bonteheuwel, Ceres, Dunoon, George, Gugulethu, Khayamandi; Lotus

River, Mbekweni, Montagu, Mossel Bay, Ocean View, Paarl, Wellington and Worcester. Respondents

in these areas illustrated high levels of matric (35.6%) and tertiary qualifications (39.9%) as did those

in affluent areas however; the type of education received was noted as a barrier to understanding

issues about consumer protection, e.g. the jargon used in marketing material limits their

understanding because they do not understand it and limited emphasis on how to avoid disputes

with businesses. Only 33.5% of respondents were employed full time and 21.8% were unemployed,

with a household income of R5, 000 or less (50.6%). These demographic profile shows that

respondents in PDAs are more vulnerable to consumer rights violation due to limited resources than

those in affluent areas. Table 10 below illustrates respondents’ interest in receiving education and

awareness about the OCP and how they can help.

Table 15: CEA Respondents' Consideration for Awareness and Complaints

Likely Neutral Unlikely

Attend workshops/ info sessions 53,2% 19,5% 27,3%

Complain through call centre 63,0% 18,5% 18,5%

Complain through walk-in centre 37,5% 20,2% 42,3%

As evident in the table above, respondents are likely to attend workshops and information sessions

(53.2%) as well as lodge a complaint through the call centre (63.0%) but not through the walk-in

centre because of distance and lack of awareness about regional offices. Observations from the face-

to-face and telephonic questionnaires, it was noted that elderly (61 and more) and youth (20 or less)

knew less about their consumer rights or the OCP compared to the actively employed age group

(between 21 and 60 years of age). The elderly and youth expressed the need for them to be more

informed and educated about all aspects relating to consumer protection. Suggestions were also

provided, such as having OCP officials at school assemblies, college open days and school governing

body meetings, as well as community meetings. These access points provide a platform to nurture

word of mouth and encourage greater awareness.

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Objective Four: Ensure that workshop content is complements challenges in targeted areas

Building on education and awareness as well as consumer complaints, the workshop content

administered is the same across all areas although it differs in terms of language and pitch. The

content is determined by assessing assessments that workshop attendees are required to fill in

before and after each workshop, recommendations from workshop administrator as well as reports

from complaints management. Based on the analysis of the aforementioned objectives, lack of

knowledge about the OCP and its service offerings or understanding of consumer rights is a

limitation. The plans and interventions state one thing but the data analysis states another.

CEA Programmes

Observations in townships and small towns across the province indicated that citizens were more

concerned about how their limited knowledge of consumer rights could assist then to deal with

foreign owned shops or local food kiosks (Spazas) which do not have a refund policy, price goods

higher than retail stores, are not accountable to consumers and do not practice honest dealing or

responsible marketing. They indicated that if workshops were to be held in their communities, they

would be interested to learn about their consumer rights and how the OCP can assist particularly

with this issue. Here a major challenge presents itself because there were very few retail stores in

these areas which abide by the laws governing consumer protection. Respondents have a limited

choice when purchasing items such as food and clothing and when encountered with a dishonest

dealing, limited knowledge and financial capacity retains them from taking action.

CCM Programmes

On the other hand, the most prevalent type of complaints indicate whether the content

administered at workshops and through marketing campaigns consider what respondents

experience daily.

Figure 5: Most Prevalent Types of Consumer Complaints

Limited education and awareness in the aforementioned areas may be attributed to limited

financial and human resources, which impacts service delivery. However, the fact that

respondents indicate willingness to attend workshops and potentially lodge a complaint when

necessary provides an opportunity for the OCP to do more and explore suggestions.

48 | P a g e

The majority of complaints lodged in 2014 were faulty goods (44.4%) and contract related (42.9%).

Regarding faulty goods, respondents stated that (1) they had purchased second-hand goods such as

vehicles, which required repairs and fixing and (2) not informed of damages before purchasing.

Contract related complaints included “poor delivery after payment”, “service warranty on vehicle

not adhered to” and “Company is forcing the client to pay for something he didn’t sign for”. This was

experienced across all income groups but at different magnitudes.

Objective Five: Ensure that programme design is unambiguous between programme managers

and citizens

Both the CEA and CCM programmes are designed by the management unit within the OCP. It

involved determining programmes’ outcome and performance indicators as well as implementation.

According to stakeholders some challenges with designing the programme relate to limited human

resources. Past evaluations indicate that despite these limitations staff members’ dedication has

encouraged satisfactory results amongst citizens. This objective mainly applies to CCM programme

and respondents had a different view compared to stakeholders.

5.4% 3.4%

44.4%

3.9%

42.9%

Advertising Appliances Contractual Counterfeit Faulty goods

When comparing this information with the workshop content, there seems to be limited

information education citizens about the steps to consider when a faulty good has been purchased

or areas to pay attention to before signing a contract. These are on-the-ground issues which need

to be elevated more in terms of workshop content to discuss so that citizens are aware before

conducting a business transaction.

However, this does not imply that the current workshop content is not sufficient; it only implies

that to be more effective, the content should be provided on issues that are of concern to

consumers. Instead, citizens will gain a better understanding and are likely to change their

behaviour in the consumer market. Citizens will also be more informed about the OCP and to what

extent it can assist, thus reducing their level of dissatisfaction.

49 | P a g e

CCM Programme

With regard to clear outline and articulation of complaints management processes to consumer,

respondents expressed their frustrations and indicated that it was not clear nor explained to them.

Figure 6: Status of Case

Although 52.5% stated that their cases were closed or resolved, a lot of emphasis was placed on the

fact that they (1) were not aware of criteria that deems a case to be closed, (2) did not receive clear

explanation regarding what investigators did and correspondence with businesses, (3) how the

complaints process is carried out and (4) were not aware to what extent the OCP can assist. This may

be attributed to respondents either not understanding the process from the beginning or poor

dissemination of information from the call centre agent to the CCM investigator. The process for

lodging a complaint is as follows: citizens’ first point of entry is the call centre. There their complaint

is assessed and gauged as valid for a case or not. Citizens with valid complaints are then sent the

necessary document required for their complaint to be investigated. The call centre agents follow up

on citizens to find out how soon the required documents can be sent back and this happens over

three to seven days after first contact. Once documents are received they are sent to OCP

investigators who then begin the investigation. With that in mind, the respondents’ level of

satisfaction is summarised in the table below:

Table 16: Customer Satisfaction

Excellent Good Fair Poor

Staff Knowledge 12,7% 17,5% 17,5% 52,4%

52.5%

7.0%

26.2%

14.3%

Case Closed / Resolved

Case Pending

Not Sure What Happened

Referred to Attorney

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Friendliness 12,1% 28,4% 15,8% 43,7%

Response time 11,3% 18,0% 14,9% 55,7%

Helpful Info 9,9% 18,8% 17,2% 54,2%

Overall Satisfaction 11,2% 19,0% 13,2% 56,6%

AVERAGE* 11,5% 20,3% 15,7% 52,5%

On average, 52.5% of respondents indicated their dissatisfaction with the services experienced,

followed by 20.3% who rated the services as good. Features such as ‘excellent, good and fair’ may be

deemed as positive thus the sum of all three provides a total satisfaction percentage of 47.5%.

Respondents indicated the following reasons as contributors to their level of satisfaction: (1) inability

to be assisted in a manner satisfactory to consumers, (2) lack of communication and (3) unclear

conduct between OCP and companies. Respondents also stated that they felt the OCP’s regulations

are too restricting and in favour of businesses because they were unable to assist due to the nature

of the complaint. However it should also be considered that respondents do not always have the

required information on hand before lodging the complaint, thus their case becomes invalid.

Although 55.7% of respondents rated response time as poor, respondents were informed of the case

closure within the timeframes listed below:

Within 7 working days (10,4%)

Within 14 working days (19,2%)

Within 28 working days (20,0%)

Within 2 Months (20,0%)

Within 3 months (9,6%)

More than 3 months (20,8%)

The feedback rate after first contact was also deemed as unsatisfactory. Very few respondents

indicated that they received feedback telephonically (40.8%) and via e-mail (63.0%) at least twice a

month. In cases where respondents received a notification informing them that their case has been

closed, they indicated that the ‘technical and legal jargon’ was unfavourable because it made it

difficult for them to understand why their case was being closed.

The above analysis indicates that the programme design lacks clearly defined terms and

explanations of how complaints are processed. Citizens thus contact the OCP with the hope that

their complaint will be resolved successfully, leading to aforementioned levels of dissatisfaction.

The link between existing activities and programme design need to be strengthened. Although the

current staff is able to achieve these objectives, having more staff can be beneficial.

It should however be noted that some of the level of frustration amongst respondents who have

not had their issues resolved; can often be due to unrealistic expectations with the level to which

the OCP is legally mandated to address the issue. This is illustrated by the low levels of awareness

of the existence of the OCP programme as well as what they are legally able to achieve within the

parameters of their mandate.

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Objective Six: Skilled and sufficient staff to implement marketing and manage consumer

complaints

South Africa’s population census in 2012 indicated that the Western Cape has 5.8 million

inhabitants, all of which the OCP aims to reach through their programmes. In order to do so,

sufficient and skilled human resources are required to implement various aspects of each

programme. The table below summarises the staff and skills capacity available to administer the

unit’s programmes:

Table 17: Staff Capacity

CEA CCM

Permanent Staff 3 7

Temporary

Employment

3 2

Skills required

Tertiary education in disciplines such

as marketing, project management,

public relations and communication.

Soft skills such as interpersonal and

writing skills.

Including but not limited to tertiary

education in a law.

Training Yes Yes

Type of training

Short courses to train in

Procurement and Legislation (make

use of dedicated budget for

training).

Training for: report writing,

negotiating, analytical and

administrative skills.

In total, there are nine permanent staff and five temporary staff to ensure successful

implementation of both programmes. It clearly indicates that there is a need for more human

resources to administer the programme on a wider scale and provide better complaints services to

citizens. Citizens indicated their level of satisfaction with complaints management as poor with

52 | P a g e

regard to aspects such as staff knowledge, helpful information and response time. This is

understandable because the number of complaints received, number of complaints to be resolved as

well as the travelling required to administer workshops can get overwhelming. Similarly, somewhere

amidst the implementation, staff members need to receive training however limited time does not

permit. This also contributes to further strain on the staff.

Objective Seven: Sufficient financial capacity to implement programmes

Building on the previous objectives, financial resources determine whether interventions can be

implemented and to what extent. The OCP sub-programme had an annual budget of R10.2 million in

2014, which has increased over the years but can only address a limited scope. A large portion is

dedicated towards education and awareness interventions and the remainder to consumer

management although this changed to accommodate the CCM’s call centre costs. Over 80% of the

CEA budget is spent on internal expenses such as staff salaries, pension funds, travelling, and general

operations. The CEA programme only utilised 5% of its budget (R800,000) to implement their

interventions in 2014, which was allocated based on the needs and challenges identified from

monitoring and evaluations.

Although the budget is limited, programme conveners attempt to find cost-effective methods to

implement interventions. This includes:

Radio coverage for free but from specific radio stations such as Eden FM,

Some coverage on the free television channel, Cape Town TV;

Shopping centres where no fees are charged and;

Campaigns in public hospitals and Government pay points

Joint programmes with other organisations willing to cover expenses.

Additional aspects which require funding include additional staff and marketing. This will likely to

have a greater impact on increasing citizens’ awareness and conducting more education

programmes. It is understandable that DEDAT has more demanding and urgent priorities to address

however additional funding would have a greater impact on achieving the department and units’

objectives.

5.2.2 Impact Assessment The purpose of the following section is to provide the results of the Evaluation Framework

Assessment (Table 10). The completed evaluation framework is provided as Annexure A to this

53 | P a g e

document. The evaluation framework is based on an assessment (informed by the score of the

objectives and indicator). The framework also provides for a motivation for the assessment

provided. The assessment is based on the following:

1. Very Poor: the indicator score is 0%. This means that the indicator has not been

addressed/achieved

2. Poor: the indicator score is between 1% and 25%. This means that the indicator has not

been addressed although some attempts were made in attempting to address the indicator

3. Acceptable: the indicator score is between 26% and 50%. This means that attempts are

made to achieve the indicator and although some of the aspects are being met there is

major room for improvement.

4. Good: the indicator score is between 51% and 75%. This means that the indicator is being

addressed; however with some minor changes the impact could be much higher.

5. Very Good: the indicator score is between 76% and 100%. This means that the indicator is

being addressed and the impact of the indicators in high.

Table 18: Impact Assessment of CEA and CCM objectives

Objective Indicator Assessment Objective

Score Assessment Motivation

1. Educate and create awareness amongst Western

Cape citizens about their consumer

rights and the OCP

1.Number of programmes and workshops conducted

Acceptable

7.5%

Given current Western Cape population, more areas can be covered. A large portion of randomly selected citizens are not aware of the OCP, its service offerings and have a limited understanding of their consumer rights. However the effort put in by the OCP with their existing budget is plausible.

2. Number of print material given out at each workshops

Acceptable

Print material distributed at workshops is currently sufficient. Most of it is obtained from various consumer related organisations and partnerships and it covers a range of disciplines where consumer rights can be violated.

3. Content variety of print material

Acceptable

The print material lacks content that educates citizens about the OCP and their service offerings, platforms to contact them and processes of lodging a complaint. The language in some material is not entirely accommodating particularly to citizens in PDAs. The current content is still relevant to distribute to citizens.

4. Level of awareness about consumer rights

Acceptable

Citizens’ level of awareness about their consumer rights is low. They are aware that they have consumer rights but do not know or understand them in detail. Citizens are also not aware of how they can practice their rights when violated, which is

54 | P a g e

Objective Indicator Assessment Objective

Score Assessment Motivation

an area where the OCP can focus on in future.

5. Number of complaints received

Acceptable

Although the number of complaints has increased over the past few years, it may not be entirely attributed to more people knowing about the OCP and its services but through marketing platforms such as word of mouth, referral and the internet.

6. Number of complaints resolved

Acceptable

Unless citizens have access to the internet, the other two platforms do not detail what the OCP can and cannot do, thus contributing to dissatisfied customer complaints citizens. Thus the number of complaints resolved does not necessarily mean that citizens are educated and aware of service offerings. The terms ‘resolved’ and ‘closed’ are not clear between the unit and citizens and this does not reflect the true number of complaints ‘resolved’; according to some citizens, their cases were not resolved satisfactorily.

2. Implement a cost-effective marketing

strategy through various platforms

1. Available marketing platforms

Acceptable

7,5%

Existing marketing platforms are acceptable due to budget constraints and limited human resources. However, there is room for improvement, which requires investigating innovative and cost effective methods.

2. Number of complaints received

Acceptable

As indicated throughout this sub-section, marketing platforms such as word of mouth, referral, radio and the internet are most prevalent. These may be attributed to the increased number of complaints received.

3. Number of complaints resolved

Acceptable

The number of complaints resolved is meaningless if resolved unsatisfactorily. The marketing platforms lack content that informs citizens beforehand, procedures to follow and what to expect when lodging a complaint. This type of information impacts on the quality of cases resolved. Citizens retain an unhappy experience.

3. Ensure that PDAs are priority areas in

which to educate and create awareness

1. Target Previously Disadvantaged Areas

Good 11,3%

PDAs areas are priority areas although financial and human resources limit geographical coverage. In addition, focus can be given to the youth and elderly, who may be considered to be more vulnerable due to limited knowledge.

4. Ensure that workshop content

complements challenges in

targeted areas

1. Conduct a needs assessment to determine consumer related challenges and awareness in PDA

Poor 7,5%

The OCP’s programme design is based on feedback from workshop assessments and reports as well as customer complaints reports. Additional research is required to understand from consumer’s perspective (1) the situations and challenges they experience, (2) what they know about their consumer rights and (3) determine additional methods of how best the OCP can engage with

55 | P a g e

Objective Indicator Assessment Objective

Score Assessment Motivation

citizens.

2. Content is informative and easy to understand for citizens

Good

Disbursing print material is one thing but disbursing material that citizens are not able to read and understand is another. The fact that pitch and language are considered from one workshop to another is favourable because it contributes towards citizens’ understanding.

5. Ensure that programme design is

unambiguous between

programme managers and

citizens

1. Clearly defined terms and phrases such as 'case closed'

Poor

3,5%

Part of the programme design does not include a clear definition of terms such as ‘case closed’ or ‘case resolved’. Citizens indicated their dissatisfaction because their understanding of those terms is different from the OCP. This has a big but negative impact on the unit’s functionality because citizens think that the OCP does not want to help them.

2. Clear outline and articulation of complaints management process to consumers

Poor

Citizens lodging a complaint are not aware of what the process entails and how it can differ based on the result of each step, for example: explaining to citizens what the processes are from the moment complaints forms are sent out, explaining at which point citizens are referred to an attorney or other consumer bodies and provide relevant contact details.

3. Design interventions based on needs assessment conducted

Acceptable

Existing interventions are able to address consumer related challenges although financial and human resources limit a greater impact. There is room for further improvement, particularly how consumers practice their rights against corner kiosks and foreign owned stores.

4. Level of satisfaction with complaints management

Acceptable

Overall citizens indicated their dissatisfaction however, elements such as staff friendliness and helpful information was satisfactory. These satisfaction levels can be improved but they are hindered by two main things: additional staff at the consumer complaints department and more information about how the complaints processes work.

6. Skilled and sufficient staff to

implement marketing and

manage consumer complaints

1. Identify relevant and supporting skills suitable to achieve programme

Good

6,8%

Existing skills are favourable however there is no clear-cut knowledge of the most desired disciplines. The nature of CEA co-coordinators and CCM investigators requires them to be diverse to as to relate better to citizens’ varying complaints and challenges.

2. Sufficient staff to address Western Cape population (on and off

Very Poor Existing staff capacity is not sufficient to successful and satisfactorily achieve programme objectives – the geographical coverage is too wide, addressing

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Objective Indicator Assessment Objective

Score Assessment Motivation

the ground) consumer complaints requires enough time to address properly; administrative and logistical activities need to be carried out, travelling from one point to another also needs to happen and internal programme monitoring also needs to happen.

3. Capitalise on departmental training programmes

Good

The unit capitalises on DEDAT’s training programmes, which is good and ensures that staff’s skills are up-to-date.

7. Sufficient financial capacity to implement

programmes

1. Budget for marketing material and workshop administration

Poor

6,0%

Given that majority of the budget assigned to the unit covers internal expenses such as salaries, the remainder is not sufficient to achieve the mandate as stated in the CPA, 2008. Additional finances could afford the unit some time on mainstream radio, which is likely to have a massive positive impact to conscientize citizens about the OCP. More workshops and print material can be provided with more financial resources.

2. Budget for staffing (and training) Good

The budget is catered for through DEDAT’s initiative to train and upskill staff.

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Chapter 6: Recommendations

This section identified some of the most prevalent issues identified in across the report and provides

recommendations for each programme. In some cases, the recommendations overlap due to the

fact that both programmes are interlinked as some stage.

6.1 Programme Design Building on the previous chapters, the table below provides insight for the design features.

Table 19: Recommendations for Programme Features

Strategic Plan 2010-2015 Draft Strategic Plan 2015-2020 Insight

Stra

tegi

c O

bje

ctiv

e

A business environment that

reflects high levels of consumer

rights awareness by a majority

of the Western Cape

population and business

community supported by

effective complaints

management and resolution

mechanisms.

To provide an effective and

efficient consumer protection

service within the province

which is aligned to the

objectives and functions

prescribed by provincial and

national consumer protection

legislation.

The strategic objective is

plausible and sets a good

foundation for the OCP. It

indicates alignment with

provincial and national legislation

but does not consider

incorporating an understanding

of ‘consumer realities’.

Legislation and function is best

capitalised if those features are

taken into consideration. For

example: expanding on content

relating to ‘guidelines for

purchasing second-hand goods’

could also be included as part of

legislation and functions

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Strategic Plan 2010-2015 Draft Strategic Plan 2015-2020 Insight

Ob

ject

ive

Sta

tem

en

t

Through various education and

awareness initiatives ensure

that at least 60% of public in

the Province are aware of the

OCP and services it offers and

the establishment of 25

Consumer NGO’s partnerships.

To ensure that the WCG

Provincial Strategic Objective of

making the Western Cape a

destination of choice in which

to do business is achieved

through the provision of an

effective complaints resolution

service, ensuring that a

minimum of 20 000 complaints

are dealt with over five years,

resulting in a financial saving to

consumers of at least R15

million.

Achieving this statement is

predominantly based on financial

and human resources. It is

recommended that the

percentage allocation could take

those factors into consideration

because only a certain amount of

initiatives can be implemented

with a specific amount of

resources.

Bas

elin

e

Low levels of awareness, where

only approximately 3 in 10

consumers are aware of basic

consumer rights. A highly

effective complaints

management and resolution

mechanism at head office with

low level service delivery

through NGO structures in rural

areas.

2013/2014 financial year:

Complaints received =10 554;

Complaints resolved = 10 063;

Financial saving of R4 million.

The OCP could consider

infiltrating other areas and

assessing their challenges and

needs (as identified in Chapter 5).

The geographical spread

indicated that there is a need for

more education and awareness in

the province. The 2015-2020 plan

indicates CCM figures attained in

2013/2014 but does not indicate

prospects/ goals for 2015 going

forward. The baseline also lacks

for the CEA programme.

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Strategic Plan 2010-2015 Draft Strategic Plan 2015-2020 Insight

Ou

tco

me

s

1.A reduction in the number of

regulatory barriers that inhibit

business growth and

development; and

2. An enhanced governance

structure and protocol within

the programme.

1.Enhanced protection of

consumers in the Western Cape

culminating in a value saving of

R30 million for consumers by

virtue of the assistance

provided by the OCP during the

five-year period.

2.Ensuring that 200 SMMEs in

the Western Cape implement

administrative and policy

procedures which comply with

consumer protection

legislation.

3. Ensuring that the service

satisfaction level among

consumers using the OCP's

services is enhanced by 20 per

cent over the five-year period.

1. Determining how the number

of regulatory barriers has

reduced over time is difficult

unless businesses participate or

the unit is able to assess from the

number of cases resolved

successfully. Between 2015-2020

period, enhancing consumer

protection can be enhanced by

addressing CEA and CCM

challenges noted in the 2014

findings e.g. clearly defining

complaints protocols and

consumer satisfaction.

2. Increasing awareness and

participation levels would depend

on implementing

recommendations below and

strengthening intergovernmental

support. The OCP should also

work with other government

units’ responsible for SMME

support, so as to curb any

expenses and redundancies

3. The primary findings in this

report provide a platform on

which the OCP can understand

why citizens are dissatisfied as

well as to explore interventions

that can be implemented to

improve satisfaction levels. The

proposed 20% increase in service

satisfaction should not be

considered in isolation of the

realities.

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Regarding performance indicators, they appeared to be stagnant between 2012/13 and 2014/15.

The evaluation and impact assessment investigate why this is the case.

Table 20: Recommendations for Performance Indicators

2012/13 2013/14 2014/15

Number of consumer

education programmes

conducted

Number of consumer education

workshops/ information programmes

conducted

Number of consumer education

programmes conducted

Number of complaints

received

Number of complaints

received

Number of complaints

Received

Number of complaints

resolved

Number of complaints

resolved

Number of complaints resolved

Number of consumer

Protection information

sheets/booklets developed and

distributed to citizens and

business

The performance indicators could to be expanded. The number of programmes conducted cannot be

the only indicator because not all citizens are able to attend workshops and potentially understand

their consumer rights or know about the OCP right after the workshop. Indicators such as the

number of print material distributed and type of content in each region should be considered

because citizens can take the material home and keep it for future reference and the type of content

caters to their needs (as per needs assessment). Further investigation is required to determine how

platforms such as word of mouth can be capitalised as well as the referral system and local

municipalities. These platforms also present a cost-effective method of marketing the OCP and

indirectly contribute to ‘the number of programmes administered/ work-shopped’; alternative

access platforms.

The number of complaints received can either indicate that citizens are more aware of the OCP or

there are more consumer rights been violated. However it does not consider softer aspects such as

quality of service received and the number of complaints resolved successfully. This could be

achieved by asking citizens to rate the service received after the case is resolved.

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Therefore the aforementioned indicators are deemed plausible and testable and partially SMART

although they require further expansion and clarity.

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6.2 Recommendations for CEA programme This sub-section provides detailed recommendations for the CEA programme. It incorporates the

challenges and opportunities identified in the impact assessment.

Table 21: Recommendations for CEA Programme

Issue Recommendation

Revise the way workshops

are administered

In order to cover ground with education and awareness, regional co-

ordinators are encouraged to capitalise on ward councillors, community

based workers and community meetings more often; where the

previously disadvantaged reside. Information dissemination is likely to

cover a wider area because the most vulnerable citizens are not always

able to access facilities in city centres.

Furthermore, citizens are typically at work between 07h00 and 17h00

and due to their priorities, they are likely to attend workshops or

meetings in the evenings. If citizens are not able to attend, their

neighbours will be able to share information through word of mouth

and/or brochures. As indicated earlier in the report, low income citizens

do not have the time or financial resources to conduct prior research.

Instead, they simply want to get the assistance they need as soon as

possible so that they can focus on other priorities.

Additional financial and human resources to assist current regional co-

ordinators should be included in future budgets so as to establish and

market regional offices.

Include Customer

Complaints contact details

and service offering as

well as a wider variety of

marketing platforms

In addition to current marketing content (workshops, brochures, in

store, etc.) contact details regarding consumer complaints contact

details and contact platforms as well as a brief explanation regarding the

services rendered should be provided in the marketing material. Further

information to administer to citizens should also include (1) the type of

documentation required from prospective complainants, (2) the protocol

channels and average time it takes to resolve a case and (3) what is

defined as a valid case. Contact details for organisations such as the

Small Claims Court and various ombudsmen can be considered as an

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Issue Recommendation

option. Inexpensive marketing platforms such as social media (Facebook,

Twitter and Youtube), please-call-me system, short message texts (SMS),

snail mail, fax and e-mail should be enhanced.

It has been noted that funding for marketing is limited so adding further

content to marketing material might be expensive. This can be

addressed by capitalising on the department’s marketing department

and platforms, so as not to exhaust the unit’s budget. Although the OCP

will not be advertised as an independent entity but as the Western Cape

Government, the signage and wording can be adjusted to place more

focus on the OCP e.g. have the OCP’s content in bigger and brighter font

while the wording and logo of the Western Cape is made smaller and

placed towards the bottom. As an example it may read as follows “a unit

of the Western Cape Government”.

Additional content design:

factors to consider before

buying second hand

goods.

The CEA programme aspires to focus on financial literacy in the next five

years. In addition to this, the department should consider focusing on

aspects to consider before buying second hand goods such as vehicles

and appliances. Citizens will then be informed beforehand what to

expect, prepare and question when purchasing such goods.

Improve inter-

departmental

communication regarding

programme design and

features

The programme designs and features should be identified, discussed and

concluded amongst all government departments involved. This is a

critical step which will guide stakeholders where setting targets is

concerned. These targets should also be guided by the proposed needs

assessment so that challenges and opportunities are taken into

consideration – ensuring more realistic and achievable targets.

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6.3 Recommendations for CCM programme Sub-section 6.3 provides detailed recommendations for the CCM programme. It also incorporates

the challenges and opportunities identified in the impact assessment.

Table 22: Recommendations for CCM Programme

Issue Recommendation

Outline the extent to

which OCP can and cannot

assist citizens

At the end of workshops and campaigns as well as marketing material

such as brochures, webpage and social networks, additional information

stating exactly the type of complaints and how the OCP can assist. It will

inform citizens about what they can expect and assess whether their

complaint is suitable for the OCP or other bodies such as ombudsmen

and lawyers. It was noted that the CCM employs interns to assist with

administrative matters, thus as part of their job description they could

also assist with the marketing.

Investigators are

considered to be rude and

lack empathy. Their

response time and

feedback is poor.

It was noted in the report that the number of complaints received,

number of complaints to be resolved as well as the travelling required to

administer workshops can get overwhelming.

The OCP should capitalise on the department’s funding that is dedicated

to professional development for courses such as law (contract law,

commercial law, international trade law, tax law, mercantile law) and

forensics. The training should include features such as empathy and

communication management which are vital to customer satisfaction.

Redefine the term

“closed” and redress the

letter indicating that a

complainant’s case has

been closed.

Previously disadvantaged areas are the target areas and due to socio-

economic conditions, there are high literacy levels. It was evident from

engaging with complainants that their understanding of a closed case is

different from the OCP’s explanation. Thus when complainants are

informed that their case has been closed, the letter should explain (1)

why the case was closed, (2) the steps investigators took to determining

closure and (3) use less technical jargon as it may deter understanding.

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Chapter 7: Reference List

Brown, R. (2012). The UN Guidelines for Consumer Protection: Making them work in Developing

Countries. London: Consumers International.

Connell, J., & Kubisch, A. (1998). Applying a Theory of Change Approach to the Evaluation of

Comprehensive Community Initiatives: Progress, Prospects, and Problems. Washington DC:

The Aspen Institute.

Consumers International. (2013). The State of Consumer Protection Around the World. London:

Consumers International.

Devnomics Developmentnomics Pty (Ltd). (2014). Evaluation of the Office of the Consumer

Protector's Consumer Awareness and Complaints Management Programmes. Cape Town:

Devnomics Developmentnomics Pty (Ltd).

Financial Services Board. (2014, December 14). Financial Services Board. Retrieved from Provincial

Consumer Affairs Offices:

https://www.fsb.co.za/feedback/Documents/Provincial%20Consumer%20Affairs%20Offices.

pdf

International Consumer Protection Network. (2014, December 14). African Consumer Protection

Dialogue. Retrieved from International Consumer Protection Network: http://icpen.org/for-

consumer-experts/consumer-protection-around-the-world/african-consumer-protection-

dialogue

Princeton. (2014, December 14). Stratified Sampling. Retrieved from Princeton University:

http://www.princeton.edu/~achaney/tmve/wiki100k/docs/Stratified_sampling.html