Your view: no to 0845 and 0870 helplines

As it will become illegal for businesses to promote an 084, 087 or 09 number for customer services, presumably it will also be illegal for third party websites and publications to promote them too?

However, Which? could easily take the lead by introducing this requirement before the June 2014 deadline. Indeed, someone should be auditing web site content at the earliest opportunity and identifying everything that requires updating.

The law applies from June 2014. This isn’t the date when people should start making changes. This is the date when all of the changes should already be in place.

Paper-based phone directories should have started months ago. They will obviously miss the June 2014 deadline in many areas of the country.

Financial services are covered by different legislation to that covering other businesses. Maybe these provisions would have to be incorporated within a different law in order to be applied to financial organisations?

The exclusion of transport services is nonsensical. They’re some of the worst offenders for using these numbers, and possibly one of the sectors most likely to be called from a mobile phone, currently at an extortionate rate, after a purchase is made.

Why would the provisions of Article 21 need to be incorporated into separate legislation specific to financial services? You’ll find that almost every sector has sector-specific legislation of some sort and it would be nonsensical to add the provisions of Article 21 to each sector-specific law. Why can’t there be one piece of legislation, relating to the provisions of Article 21, that applies across all sectors?

I still don’t understand why Article 21 shouldn’t apply across all sectors.Regulation 6(1)(c) of the Electronic Commerce (EC Directive) Regulations 2002 requires businesses to provide an e-mail address in order to be contacted by customers; there is no exemption for financial services or passenger transport sectors. In view of this precedent regarding other communication methods, why should the UK’s implementation of Article 21 of the Consumer Rights Directive 2011/83/EU exempt any type of business from complying?

The widespread abuse of 084 and 087 prefixes by the financial services and passenger transport sectors should be curtailed as soon as possible.

I have already made the necessary comments in my response to the consultation in September 2012. After BIS told me “When implementing European legislation, the Government starts from the principle that we do not extend the application of the directive unless we see a pressing need. We are not aware that premium rate phone calls are a pressing problem in the passenger transport sector. If consultees provide evidence that there is a problem in this sector, we would, of course be prepared to reconsider this. Again, with the financial services sector, we are not aware that premium rate calls are a problem in this area. In addition, financial services are excluded from the scope of the Consumer Rights Directive, because it is considered that industry specific legislation is more appropriate to deal with this area, rather than legislation on consumer rights“, I wrote in response “Article 3 of the Directive exempts certain industries from complying with Article 21, specifically social services, healthcare, gambling, financial services, construction, package travel, timeshare, regular food/drink deliveries and passenger transport services. BIS proposes to extend the scope to cover social services, healthcare, package travel and timeshare, but has chosen to preserve the exemption for the other industries. I understand that BIS takes the view that other legislation covers these industries; however no industry-specific legislation contains similar provisions to Article 21“. I also gave several examples of abuse of 084 and 087 numbers by businesses in both sectors. BIS appears to have ignored my comments. What is the point of a consultation if BIS ignores the opinion of the majority of consumers?

The original consultation about implementing the Consumer Rights Directive ran from 20 August 2012 to 1 November 2012.

Now that the draft legislation has been produced, BIS want comments on the proposed wording of that legislation. They want to uncover anomalies and loopholes before this becomes law. They’ll also take comments about the proposed exemptions.

As it says here:
https://www.gov.uk/government/consultations/consultation-on-the-implementation-of-the-consumer-rights-directive-2011-83-eu
“Use the proforma to provide feedback on the related draft regulations by 11 October 2013.”

The requirement to use 01, 02, 03, 080 or mobile numbers is unambuous (although it does rely on Ofcom updating several of those definitions in the UK Telephone Number Plan).

I made my comments yesterday about the exclusions. I hope others do the same. It is supposed to be a consumer rights directive so why on earth should financial services and transport services be excluded. Are we to have less rights in those sectors or do they donate more money to political parties so get excluded as a result.