A MUCH NEEDED CHANGE
The NCF welcomes action to make a much needed change in the current consumer advocacy arrangements in the telecommunications sector.
NCF agrees with the remit proposed in the consultation paper and supports appointing the Citizens Advice to assume the consumer advocacy role.
CO-OPERATION WITH CONSUMERS AND CONSUMER ORGANISATIONS
However, it should be noted that the advocate will need to access a diversity of analysis by external consumers/consumer organisations who may be, on occasion, better placed to initiate investigations and conduct research. A co-operative approach can lead the way on particular issues and make a strong contribution to better regulation. NCF for one is ready to work with Citizens Advice and the Advocate and looks forward to making continuing contributions to their work.
Research into the consumer experience will be vital. A number of recent initiatives taken by Ofcom are listed in the DCMS Consultation. The advocate will have a role in signposting these (and similar) initiatives for consumers, monitoring their impact on the consumer experience and suggesting improvements where necessary.
The scale of activity could be similar to that involving energy and could be funded in the same way as existing work in relation to energy. While the scale of activity could be similar to that involving energy, we should recognise that compared to energy, telecoms involves more complex consumer/supplier relationships, often with multiple suppliers. Advocacy in these markets could be more rather than less costly.