Citizens Advice Scotland – Response to Ofcom’s call for inputs: Review of measures to protect people in debt or at risk of disconnection

The day-to-day activities of citizens are becoming increasingly dependent on their ability to use telecommunications services, such as mobile phones, broadband or landlines. The COVID-19 pandemic has highlighted the essential nature of online connectivity and access to internet data, with many people relying on internet access for working from home, staying informed or interacting with welfare services.

Executive Summary

CAS generally supports the measures proposed by Ofcom. In summary:

• The voluntary measures to support consumers introduced by providers during the outset of the COVID-19 pandemic were welcomed by CAS, as an effective response that has assisted in reducing consumer detriment over the past year.
• With consumers facing potential economic uncertainty as furlough and support schemes taper and Universal Credit uplifts look likely to be reversed, we believe it is timely to reconsider whether the protections for people in debt or struggling to pay remain appropriate, or whether there is a case for strengthening them.
• CAS supports measures which allow consumers in debt or at risk of disconnection to be treated fairly and have every opportunity to resolve these issues before disconnection takes place or service restrictions are imposed.
• CAS welcomes proposals to improve how providers identify and communicate with vulnerable consumers.
• CAS agrees that there should be more consistency in the ways providers communicate regarding debt and the ways they seek to obtain payment from customers in debt.
• CAS would wish to see the Consumer Principles embedded within the development of future measures, guidance, and regulations.
• CAS remains concerned regarding affordability issues and would welcome an early engagement approach by providers which aims to prevent a build up of debt
• We believe that further work is required to encourage providers to not only provide but to actively encourage take up of social tariffs for consumers who may be at risk of falling into debt.