Citizens Advice Scotland – Response to Ofcom’s proposed amendments to the Treating vulnerable customers fairly guide

Executive Summary

CAS generally supports the proposed revised guidance. In summary:

• We welcome Ofcom’s continued support for social tariffs; these are a valuable measure to provide support for consumers who are in debt or struggling to pay. CAS would welcome more support for advice agencies who are assisting financially vulnerable clients to access affordable or social tariffs. We would also urge Ofcom to consider what support should be available to consumers who come to the end of any social or affordable tariff which has a fixed period. 

• We welcome Ofcom’s proposed additions to the guidance in relation to communication channels. Offering consumers a wide range of channels to communicate with their provider is essential to treating consumers fairly.

• We welcome measures to ensure providers should, where possible, use a phased approach to introducing any service restriction, as this allows consumers to maintain access to free advice services and treats disconnection as a last resort.

• We share Ofcom’s view that it is good practice for providers to signpost consumers to debt advice organisations. We also welcome Ofcom taking steps to make it easier for advice agencies to communicate with providers on a client’s behalf.