The Commissioner for Complaints for Telecommunications Services (CCTS) has a problem – few people know it exists. In fact, a recent survey indicated that only 2% of Canadians who had an unresolved complaint with a company providing a telecommunications service could name the CCTS as the agency to approach to get the dispute resolved. As a consumer advocate, I wouldn’t care if the CCTS were selling widgets or sporting goods. However, because the CCTS is an industry-funded organization dedicated to working with Canadians and their telecommunications service provider (TSP) to resolve complaints relating to telecommunications services, I do care, and care deeply. I just wish the CCTS shared my passion to raise its public awareness among Canadians.
This is unfortunate. Compared to other industry dispute resolution models, the CCTS appears to do many things well. For instance, the agency seems very accessible, has a simple process for complaint handling, and attempts to provide resolution in a timely fashion. In fact, PIAC advocated for an organization similar to the present-day CCTS 10 to 15 years ago.  Apparently, what the CCTS does not wish to do is take any effective steps to measure awareness of itself – not now, and perhaps not ever.
This was not an easy conclusion to arrive at, but perhaps some history is in order. Back in 2011, the CRTC, which provides the CCTS with its marching orders, advised the CCTS that it expected measurements of public awareness and customer satisfaction in subsequent CCTS Annual Reports. The customer satisfaction figures were compiled and released by the CCTS. Meanwhile, in 2015, the CCTS advised the CRTC the collection of public awareness figures were not considered “closely related to its core mandate.” As a result, they were not collected by the CCTS from 2011 to 2015, and the CCTS appeared unconcerned about the expectation of the CRTC.
Other organizations with similar mandates, such as Australia’s Telecommunication Industry Ombudsman (TIO), have routinely conducted public awareness surveys.  As a result, the TIO was been able to determine that in 2012 more than 33% of Australians said they would contact the TIO if they could not resolve a complaint with their service provider (unaided awareness). However, 2012 was the fourth time in 8 years the TIO measured its level of public awareness. Meanwhile, the CCTS apparently remained uninterested if Canadians knew it existed or not.
Fortunately, the CRTC noticed the lack of public awareness measurement data during a review of the CCTS in 2015. Shortly before the review began, the CCTS promised to undertake a public awareness survey in 2016. This offer appeared to be made at the last minute to satisfy the CRTC.
The CRTC, to its credit, recognized the lack of public awareness monitoring measurement, and the CCTS’s reluctance to monitor promotional obligations imposed on telecommunication service providers. Canadian TSP’s are supposed to promote the CCTS in the following methods:

  • Providers are obligated to advise customers of CCTS when discussing a complaint that cannot be resolved to the customer’s satisfaction
  • Providers are to mention the CCTS on monthly statements at least 4 times a year
  • Providers are required to post a notice about the CCTS on their website

However, without any effective deterrents, and with the CCTS apparently not enforcing compliance, telecommunications service providers felt free to ignore the CRTC-imposed promotional obligations designed to raise awareness to the CCTS.
As a result, since 2011 there has been a perfect storm allowing the level of unprompted public awareness of the CCTS to remain practically zero. A telecom regulator eager to delegate oversight of consumer complaints, a complaint resolution body apparently concentrating solely on resolving the complaints in front of them, and an industry disinterested in consumer concerns.
One would hope the CCTS got the message when the CRTC used bold font directing them to file the results of its public awareness survey upon completion. As well, the CRTC again expects the CCTS to measure the effectiveness of its Awareness Plan on an ongoing basis. However, if the contents of the recent public awareness survey are any indication, the CCTS remains hesitant to promote itself and has yet to develop a plan to ensure Canadians know they exist.
The survey itself was only 8 questions long. There was little in the way of detailed analysis and the survey questionnaire forms an unstable base from which to build any kind of useful comparisons going forward. This is unfortunate since complaint resolution providers who diligently collect comprehensive public awareness data are able to channel subsequent promotion efforts.  For example, the Financial Ombudsman Service in the United Kingdom has noted, “We are very keen to work with groups of consumers who – according to research – are less likely to know about their rights to complain and about the free availability of the Financial Ombudsman Service.”
It was clear CCTS staff failed to consult with their counterparts from Australia who undoubtedly have gathered considerable experience after conducting multiple public awareness surveys during the past 15 years. For instance, the TIO awareness survey from 2006 produced over 30 pages of analysis, including results from small business customers, responses based upon ethnic groups, and response based on communications service. With only 8 questions, it is difficult to comprehend what, if any data collected will be useful for promoting the CCTS going forward.
The worst part is, the CCTS does a good job in helping Canadian consumers. PIAC likes what the CCTS does on a day-to-day basis and wishes more Canadians knew the CCTS was there for them. As a result, PIAC suggests the CCTS commission a third-party organization with considerable experience in survey compilation and analysis to undertake this public awareness research on their behalf on an annual basis. This solution liberates the CCTS from the burden of doing this research itself, while allowing it to be accountable and transparent in fulfilling in CRTC obligations. The CCTS may choose to spend some of its new-found free time enforcing compliance of TSP’s promotional obligations to raise greater awareness of the CCTS.
Without some sort of strategy, the CCTS will continue to be the Anti-Cheers – “Where Nobody Knows Your Name”
Jonathan Bishop is a Research Analyst at the Public Interest Advocacy Centre (PIAC)