NEW UK CONSUMER CONTRACT REGULATIONCHANGES AFFECTING POST-CONTRACT TELEPHONY CHARGES

+ Known as “The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013”+ Dept of Business, Innovation and Skills (BIS) has responsibility for bringing EU Directive into UK law

+ Key Measures included in the new EU Consumer Rights Directive+ increasing the time limit for returning goods purchased online or by phone from 7 days to 14 + banning pre-ticked tick boxes for extras that the consumer may not want or need + setting out key information consumers should be given before agreeing to purchase

+ Post-contract customer help lines be charged at no more than “Basic” rate.

+ Implementation date 13th June 2014+ Regulations will apply to contracts concluded on or after above date

WHAT IS THE NEW LEGISLATION?

+ If you are a trader selling goods and services (including digital content) to a consumer – these regulations apply to you

+ These will apply to contracts concluded after 13th June 14.+ On this date the distance selling regulations 2000 and off-premises

(doorstep) regulations 2008 will be revoked+ Does not impact Business to Business transactions

+ There are some exemptions typically where other sector specific regulation applies as follows….

WHO IS AFFECTED?

Certain business types or services may be exempt or partially exempt from the provisions of the regulation:

EXEMPTIONS TO REGULATION

Contracts only partly covered by regulation + Passenger transport are except from

cancellation rights and most of the information requirements.

+ Low value off-premise contracts <£42+ Items dispensed on prescription

Financial servicesNOTE: Warranties, credit agreements and insurance products which are offered in conjunction with the sale of non- financial goods will still need to meet the regulations. The Government has asked the Financial Services Conduct Authority to consider equivalent regulation

Contracts Exempt+ Gambling as covered by the

Gambling Act 2005+ Construction & Sale of immovable

property+ Residential letting contracts+ Package travel contracts+ Timeshare contracts+ Vending machines and other goods

intended for current consumptions+ Single connections for use by

telephone, fax or internet

+ Regulation applies to POST SALE calls only+ New numbers must be in place by 13th June 2014+ “Basic Rate” mean numbers must be Geographic, Mobile, or, if NGN must be ‘Free to call’+ OFCOM making 0800/0808 numbers free from mobiles in mid 2015 (but may cost more)+ Numbers must be given equal prominence on advertising, letterheads, website etc

+ Sole use of Premium rate (09xx) and other revenue sharing ranges (e.g. 0844, 0871) for post contract calls will no longer be acceptable+ But it’s perfectly OK to still use them for pre-sales!

+ 0870 may be acceptable but is often charged at more than geographic. OFCOM plan to make it a revenue generating number again in 2015 so is best avoided

HOW WILL I BE AFFECTED?

+Have you have already decided what number to use?Yes you haveNo you haven’t

WEBINAR ATTENDEE POLL

WHAT OPTIONS DO I HAVE?

Could use 01/02 no’sNot a simple substitution, Geographic significance may not be desirable for some organisations or require multiple numbers

Take an 03xx numberSimple substitution of one numberTTB can supply an 03XX version of your 08XX number (or request it from another operator)

Change 08XX numberComplex exercise requiring significant effort, expense and lead-times Would you be ready for June 13th?

Parallel run numbersContinue using existing 08XX but provide messages to callers about new 03XX numberAdvertise on websites/email footers

Do nothingCustomer can demand reimbursement of additional chargesBrand damage/bad pressAction taken by Trading Standards

BENEFITS OF USING AN 03 NUMBER

Consistent chargesCallers will pay same charge as call to 01/02 – even from mobiles

Often included03 included in many call packages so would effectively be ‘free’ from landlines and mobiles.

Number unityTTB can supply 03XX version of 08xx.Simple substitution of one number.

Built on reputationWidely used by charities/public bodies – 03 becoming a ‘trusted’ number.

Part of a growing club03 is used by BBC for all listener/viewer contact. Increasingly adopted by government and pseudo government organisations e.g. DVLA, Blood transfusion etc

Network Services03 can be used with all TTB inbound products including IVR, Host Contact Centre etc.

IMPACT OF NOT COMPLYING WITH REGULATION?

+ Regulation will be enforced by the Competition and Markets Authority+ Enforcement through Local Trading Standard (Weights & Measures)+ Department of Enterprise, Trade & Investments in Northern Ireland

+ What is the penalty for non-compliance?+ Customers can demand a refund on the difference in cost from that of a basic rate call.+ Enforcement authority may apply for injunction to secure compliance

+ Brand & Reputational Damage + It is very likely consumer groups e.g. Which etc and the national press will take an

interest. Companies flouting the regulation or acting in such a manner that is clearly against the spirit of the regulation can expect to find themselves in the public eye and suffer the resultant potential bad press and brand damage.

THE TALKTALK BUSINESS 6 POINT PLAN

Telling your customersDon’t wait for June 13th - Start telling your customers now.Post new number on website/invoices/email footers etc.Update directories

Review affected numbers/servicesConfirm numbers in use, who supplied them and any network services which are included. Are any services paid through revenue share?

Review options1. Do nothing!2. Order your 03xx numbers now3. Run new numbers in parallel4. Use network services to split

traffic

TimelinesChanging numbers take time e.g. BT Directory, Van signageCall handling systems or network service changes may be needed.New processes/staff training

Managing financial impactCan you continue to provide the same service post June? Maybe it’s time to review call handling strategy.Consolidate services/providers

Is your business in scope?Check if your company exempt from this?

1 2 3

4 5 6

Welcome

Customer servicesPre-salesGeneral

Enquiries

0844 XXX XXXX

Some sectors exempt e.g.

Financial Services

CURRENT SOLUTIONNon-

Compliant after 13th

June

Welcome – Note 1

Customer servicesPre-salesGeneral

Enquiries

0844 XXX XXXX 0344 XXX XXXX

Note: Message should tell callers if they used the 08XX number there is a cheaper 03xx number for post sales calls

Partner can supply complimentary 03XX Number

EXAMPLE SOLUTIONS – PARALLEL RUN

Compliant

Pre-sales

0844 XXX XXXX 0344 XXX XXXX

Post Sales Welcome

Welcome

General Enquiries

Customer services

0800 XXX XXXX

01204 XXX XXXX

Alternative numbers

EXAMPLE SOLUTION – HYBRID

Tell customers that select a post sales option to call the basic rate numberCustomer may continue to call 08XX number so preserving some post sale revenue

Compliant

Pre-sales

0844 XXX XXXX 0344 XXX XXXX

WelcomeWelcome

General Enquiries

Customer services

IDEAL SOLUTION

0800 XXX XXXX

01204 XXX XXXX

Alternative numbers

Note: 0800 not ‘free to caller’ at present- June 2015

Compliant

HOW WE CAN HELP

Technical supportTTB Business experts are on hand to review your services and to advise on the best course of action for your business (whether you are already with us or not)

Flexible NumbersOur inbound numbers can be used with any service type – geographic or non geographic. We also provide an extensive range of cloud-based call handling products for all sizes of business

03XX numbersIf you are using 08xx numbers (whether supplied by TTB or not) we can supply the equivalent 03xx number for use on post contract lines.

Business numbersTTB offer one of the widest ranges of business numbers (08XX, 09XX, 03XX, 01xx/02XX etc.) in the UK. We can also port numbers in from all the major carriers.

Designed for youMany customers use our off-the-shelf products but TTB can also supply customised solutions to meet a wide variety of different business and commercial needs.

Free to caller“free to caller” Number Announcement services are available for larger Customers/Partners if changing numbers.

Questions?(Online only)

SOURCES OF FURTHER INFORMATION

+ Department for Business, Innovation & Skills + https://www.gov.uk/government/policies/providing-better-information-and-protection-for-consum

ers/supporting-pages/implementing-the-consumer-rights-directive-2011-83-eu

+ UK Consumer Contract Regulation https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265898/consumer-contracts-information-cancellation-and-additional-payments-regulations-2013.pdf

+ Guidance on the regulations https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/266525/bis-13-1368-consumer-contracts-information-cancellation-and-additional-payments-regulations-guidance.pdf

Thank you