CCTS: Why Does No One Know Your Name? The Story of Service Provider Compliance

Recently, the Commissioner for Complaints for Telecommunications Services (CCTS) released survey data indicating only 2% of survey respondents who thought they had options could identify the CCTS as a recourse avenue if they experienced an unresolved compliant with their communication service provider. These services include home phone, wireless service, home internet or cable and satellite television service. The same survey data indicates 20% of respondents have heard of the CCTS. While it would be simple to blame the hard-working staff at the CCTS for this lack of awareness, it would also be unfair. Clearly, there is more to this low level of public awareness of the CCTS than meets the eye. PIAC would like to take a moment to partially unravel this unfortunate mystery.
Shortly after the CCTS was established, a public awareness plan was put in place committing participating telecommunications service providers to undertaking activities to ensure customers were made aware of CCTS and the independent dispute resolution service they offer. In 2012, the plan was amended and currently includes the following undertakings by service providers:

Service providers are required to place on their web sites a notice about CCTS and a link to the CCTS web site.
Service providers are required to place notices about CCTS on customers’ bills four times per year. They are also required to provide notice to customers who do not receive bills, such as pre-paid wireless customers.
Service providers are required to notify the customer about the right of recourse to CCTS following the second level of escalation in the company’s complaints process.

According to the CCTS, the awareness plan is built on the strategy of ensuring information about CCTS is readily available to customers at the time they experience a problem. PIAC has previously been critical of this approach, stating part of the role of the CCTS is to promote to the public at large that an avenue is present for Canadians with unresolved telecommunications service issues. Quite simply, if more Canadians knew the CCTS existed, the CCTS would be more effective in fulfilling its mandate to assist those Canadians with unresolved complaints.
However, at the present time, the task of promoting the CCTS falls to participating telecommunications service providers. The job of Rogers, Bell, TELUS et al. is to provide notices on their websites about the CCTS, place notices on their bills 4 times a year and notify their customers if a complaint remains unresolved after review, among other activities. But who makes sure this happens? Does it happen?
The CCTS has noted publicly it does not have the mandate or the resources to do formal auditing of compliance with aspects of its public awareness plan. However, according to unofficial data collected by the CCTS and submitted to the CRTC in 2015, there is evidence service providers may not be very diligent in their promotion of the CCTS.
For instance, CCTS sent compliance surveys to 133 participating telecommunications service providers (PSPs) and received 47 replies, for a response rate of 35%. With those 47 replies, this is what was found:

38 of 47 respondents have web sites that contain the required notice and link, and the text of the notice as required. This is a compliance rate of 81% of respondents.
However, the CCTS Public Awareness Plan also requires that if a PSP’s web site has a search function, seven prescribed terms (“complaint”, “dispute”, “agency”, “CRTC”, “CCTS”, “commission” and “ombudsman”) should return a link to the page with the CCTS notice and web site link. Only 2/26 were actually fully compliant (i.e. all seven search terms returned the CCTS web page). This is a compliance rate of 8% of respondents.
31 of 47 of respondents self-report that they are compliant with the requirement to place notices about CCTS on customers’ bills four times per year, a compliance rate of 66% of respondents.
7 of 20 respondents reported compliance with having a process for delivering notices about CCTS to customers not receiving a monthly bill.
CCTS considers customer notification during a complaint process the most important feature of the Public Awareness Plan, yet admits the CCTS has no real ability to monitor PSP compliance with this provision. CCTS concluded that 15 or 47 respondents report a customer notification process that appears to be compliant with the Plan. This is a compliance rate of 32% of respondents.

In our view, the argument of the CCTS – that awareness of its existence is readily available to customers at the time when they need it – is only viable if service providers are diligent in providing the information. However, it is clear not all telecommunications service providers are fulfilling their obligations to the CCTS or to Canadians.
As an outside observer, this begs a number of questions:

Does the CCTS intend to measure the compliance of service providers going forward?
At what point is the CRTC partially responsible for allowing this chronic non-compliance with the CCTS participation agreement?
Will the CRTC provide the deterrents required to ensure telecommunications service providers fulfill their public awareness obligations regarding the CCTS?

PIAC believes that until a substantial proportion of the Canadian public is aware the CCTS exists, attempting to determine its effectiveness in fulfilling its mandate remains elusive. The degree of public awareness of the CCTS is crucial to its effectiveness—consumers will not seek recourse with the CCTS if they are not aware that it exists or of how it might help them.
Thus far, the blame for a low number of Canadians being aware of the CCTS as a recourse avenue can be fairly placed equally at the feet of the CCTS, Canada’s telecommunications service providers and the CRTC. However, it does not have to remain this way. The CCTS can routinely monitor service provider compliance with the elements of their public awareness plan outlined above, as they did in 2015. The service providers can simply do what they have agreed to do, and do it better. Meanwhile, the CRTC could be imposing enforcement deterrents for those instances where service provider non-compliance of the CCTS has become habitual.
For PIAC, ensuring more consumers are aware there’s a way to resolve their communications complaints is the objective. Taking action to ensure Canada’s telecommunication service providers fulfill their awareness obligations consistently would be an ideal first step.

Jonathan Bishop is a Research Analyst with the Public Interest Advocacy Centre (PIAC)

CCTS Survey Highlights Public Awareness Challenge

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)

CRTC Misses Opportunity to Create Future for Community TV

OTTAWA, June 15, 2016 – The Public Interest Advocacy Centre (PIAC) expressed disappointment in the Canadian Radio-Television and Telecommunications Commission’s (CRTC) new policy framework for local and community television issued today.
In Broadcasting Regulatory Policy 2016-224, the CRTC will ensure that local over-the-air stations will continue to air local news and local programming. However, community channels will be primarily operated by cable and IPTV providers with no funding set aside for independent community stations. Television providers will also be permitted to redirect funding from community channels to their private local stations.
“While the CRTC reinforced the importance of local news and local programming in Canada, they took funding for that programming from community TV,” said John Lawford, Executive Director and General Counsel to PIAC. “The CRTC has robbed the poor community channels to feed the rich, large, national private broadcasters – who should have paid to provide local news themselves.”
At a public hearing in January, PIAC and the Council of Senior Citizens’ Organizations of B.C. advocated for the importance of local news and independent community television. The groups supported earmarking a portion of community TV funding for independent community stations and local community media centres.
“The Commission had an opportunity to create space and growth for communities – especially marginalized communities – who wanted to operate stations which would reflect their needs and values,” said Alysia Lau, Legal Counsel at PIAC. “Instead, this decision has made it harder for any independent community group to find its footing in a system dominated by the television providers. We’re going to see less ‘community’ in community TV.”
For more information please contact:
Alysia Lau
Legal Counsel
Public Interest Advocacy Centre (PIAC)
(613) 562-4002 ×38
alau@piac.ca
www.piac.ca

It’s Time to Make the Internet Affordable for All

Recently, we wrote an article about the Ontario Electricity Support Program, a credit for low income households on their monthly energy bill. The subsidy is financed at a very small rate (fractions of a cent per kilowatt) by other ratepayers, but makes a huge difference for people who are having trouble keeping up with their monthly bills.
Giving affordable access to essential services is one of the cornerstones to building opportunity for low income Canadians. Currently, there is a question about whether broadband internet is an essential service, like electricity and heat. The CRTC is holding a “Review of Basic Telecommunications Service” proceeding (which we here at PIAC call the “Basic Service” hearing) to decide this question.
In the 90’s, there was a similar debate over the telephone. Prices were too expensive for lower-income Canadians and some other groups and it begged the question, do people really need telephone service, or is it just an ‘entertainment’ device with some helpful aspects? Of course, people use their telephone to chat with friends, catch up with grandma, etc., but it also made access to government services much easier, it made communication for work or job interviews practical, and allowed people to stay connected with their communities. In the end, although there was an entertainment aspect, the CRTC decided in 1996 and in another decision in 1999 that the service was more than just those elements; it enabled people to fully participate in society; it was indeed essential.
However, in the same decision in 1996, the CRTC declared that telephone service was “affordable” simply because the “penetration rate” (the overall number of households with telephone service) was high. The CRTC used this sole measure despite suggested definitions of affordability from PIAC and other low-income and consumer groups that percentage of household income; a combination of price, income, spending priorities and consumer choice; and ability to maintain a service over time were all better indicators of affordability for low-income Canadians and other particular groups such as Canadians with disabilities. The CRTC only proposed minor “bill management tools” regarding deposits, disconnections and controls on long distance calls, as a way to control costs – as well as requiring the companies to monitor affordability for a number of years. This unfortunate decision meant that a discussion of subsidies to support low-income telephone access (and subsequently of wireless and broadband) disappeared for 20 years.
Now, at long last, we are having a very similar discussion about the internet. As we covered in a blog in December, some have tried to say that the barrier to internet access is not affordability, but any number of other reasons, from disinterest to lack of expert knowledge. And once again, in the Basic Service proceeding at the CRTC, certain companies are arguing that only the penetration rate of internet service matters, and since it is rising, there is no affordability problem.
PIAC, in its work with ACORN Canada, looked at the barriers to internet access for low-income users specifically, and found that many users were sacrificing essentials in order to keep access to the internet. This, we believe, is the proper measure of affordability today: can you purchase telecommunications (especially broadband) at a price that does not require you to eat less, turn down the heat, or skip buying the kids new shoes? We at PIAC believe broadband service is a natural successor to the telephone in terms of connection to society and access to information. We also believe that the conversation about affordability must change so that we do not shut out many Canadians from the telecommunications system again.
The Basic Service hearing will begin on April 11, 2016 and the CRTC will hear from stakeholders and the public in order to decide if broadband is essential for Canadians and, if so, at what speeds and if, and if so, how will it be subsidized. PIAC, as a part of the Affordable Access Coalition (AAC), introduced its ideas in its Phase 1 intervention sent to the CRTC in July 2015. We followed up with more evidence including a poll of low-income internet users in February 2016. You can find all our documents here. The CRTC subsequently commissioned its own poll about telecommunications affordability. You can view more information about it here, and also view other news about the upcoming hearing.
Because it’s 2016, we shouldn’t be letting any Canadians fall behind in the digital economy. Everyone deserves a basic level of access to the internet so that they can pay their bills, download government forms for services, look for work, have access to educational materials, or, yes, enjoy entertainment delivered via the internet. The internet is a powerful tool that can help improve lives; it is undoubtedly an essential service, and we should ensure that access is affordable for all.

Time to Check-Out of Loyalty Program Rewards?

It has been taken for granted that Canadians love their loyalty rewards. 89% of Canadians are members of a loyalty program and the average Canadian participates in 8 different loyalty schemes. However, not all may be as rosy as loyalty program marketers may have you believe.
A recent survey released by loyalty program provider Aimia reveals Canadians are becoming increasingly concerned with the data companies are collecting about them. For instance, 83% of Canadians surveyed said they want more control over what data companies hold about them, while 20% have closed accounts or subscriptions over concerns about how their personal information was being managed. Surprisingly, only 8% of Canadians surveyed feel they are actually receiving better offers as a result of sharing their details.
Part of the reason for this apparent consumer frustration is a sense that it simply is not worth it anymore. For some Canadians, the benefit of obtaining a reward in exchange for their data is no longer as apparent. No doubt, some of this frustration has been caused by loyalty program providers themselves.
For instance, the popular SCENE program offered by Cineplex recently amended their terms and conditions. After November 4, 2015, general admission movies will still cost 1,000 SCENE points, but premium movies such as 3D or Imax, will cost 1,500 points, and VIP tickets will cost 2,000 SCENE points. Until now, SCENE members can gain free tickets to any general admission, premium or VIP movie if they have saved 1,000 points. Cineplex also plans to boost the number of SCENE points awarded for each premium movie ticket purchased to 150 points and for VIP movies to 200 points.
The result is that current SCENE members who have been saving their points for a VIP ticket are about to have the value of their loyalty currency cut by 50%. PIAC, as outlined in a 2013 report entitled “Customer Loyalty Programs: Are Rules Needed?”, believes the devaluation of loyalty currency is an ongoing issue for consumers.
Canadians live in an era where one can pay a portion of their student loan with loyalty points. Some Canadians will soon be able to earn loyalty points from the government for joining a gym or getting a flu shot. Since governments are beginning to get involved in the distribution of loyalty currency, perhaps it’s time for decision-makers to consider protecting Canadians from drastic cuts to the value of their hard-earned loyalty currency.
Perhaps now, rules are needed.

What is ‘Affordability’?

Written by Gina Roberts

Affordability is perceived of differently depending on who you are – and more importantly, where you are. Not where in space, but where on the economic ladder. It’s not easily defined, but PIAC has made the effort to identify what ‘affordability’ can mean to Canadians. (more…)

PIAC refiles Part I application against shomi

OTTAWA, April 27, 2015 – The Public Interest Advocacy Centre (PIAC) today refiled an application to the Canadian Radio-television and Telecommunications Commission (CRTC) asking that the regulator stop the “shomi” over the top TV service from being offered only to Rogers or Shaw internet customers.
“Shomi cannot tie internet access to Shaw or Rogers without hurting other internet providers and their customers,” said John Lawford, Executive Director and Counsel to PIAC. “We have called on the CRTC to stop this unduly preferential offering.”
The CRTC’s latest Let’s Talk TV decision initiated an inquiry into a potential regulatory fix for “hybrid video on demand” (HVOD) services that tie “over-the-top” (OTT) delivered programming to conventional broadcasting subscriptions. While PIAC is commenting on that process to deal with potential preferences in the broadcasting distribution field it had to address lingering problems with the shomi service that likely would not be addressed in the CRTC’s HVOD hearing.
“Canadian consumers watch more and more over-the-top programming,” said Geoff White, Legal Counsel to PIAC. “We want the rules to be clear so that all internet users can benefit equally from new offerings in this market.”
PIAC had previously filed two complaints, against shomi and Bell-led OTT service CraveTV – which the CRTC had returned – with an invitation to refile in the event that the proposals made by the CRTC were not adequate to address any perceived problems of undue preference.
For more information please contact:
John Lawford
Executive Director and General Counsel
Public Interest Advocacy Centre (PIAC)
(613) 562-4002 ×25
Mobile: (613) 447-8125
jlawford@piac.ca

Geoff White
Counsel to PIAC
(613) 562-4002 ×24
Mobile: (613) 612-1190
gwhite@piac.ca
www.piac.ca

The Cost of Loyalty Programs

Written By Gina Roberts

Many Canadians are signed up for loyalty programs because being rewarded for everyday purchases seems beneficial. They add to the ‘shopping experience’. Just swipe for points and savings; but there is a danger to this simple method.
PIAC’s “Customer Loyalty Programs: Are Rules Needed?” report shows that ease of use is a determining factor in how much consumers enjoy a loyalty program. In response to this, some businesses have tied their programs to credit cards so consumers can gain points easier and faster to spend on rewards.
Rewards vary depending on the program: some exchange points for discounts and some for items or services. Because points are redeemable, many consumers using these programs view points as a currency interchangeable with money. In reality, the value of these rewards in relation to consumer expenses can be less than 2%, which means consumers must spend far more than the reward’s worth to see them.
By attaching loyalty programs to credit cards consumers may be spending money they don’t have to get these rewards.
The report identified that consumers with loyalty programs usually spend money at particular stores to gain points and are encouraged to use their program card. When it’s is attached to a credit card it’s easier to use and consumers can pay at the same time. This becomes dangerous as people will make more purchases with credit, which garners interest, and have to pay off a debt. On top of this, special offers and promotions associated with loyalty programs encourage consumers to make additional purchases with their cards in order to get more points. This can lead to substantial credit card debt, just to gain points and rewards at a rate of 2% or less.
Younger (ages 19 – 29) credit card users with loyalty programs may be particularly exposed to credit debt because they’re more receptive to receiving information on promotions, special offers, and deals, as well as make purchases, than other users. Furthermore, this age group is more connected with social media and networking technologies which businesses are utilizing more and more to reach consumers, giving this group easier access to deals and offers wherever they go.
Consumers should be aware of their spending habits, but those with loyalty program affiliated credit cards should pay particular attention. The point totals may not add up to the costs.
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