CONSULTATION

Consultation summary

Introduction

The One Touch Switching Company Ltd (“TOTSCo”) is consulting with industry on a proposed change to the One Touch Switch (“OTS”) Industry Process.

The change concerns a Service Level Agreement (“SLA”) for the dispatch of switching information to the Switching Customer.

Terms used in this consultation are defined in the April 2023 General Conditions and/or the OTS Industry Process V4.1.

 

The proposal

It is proposed that the following SLA is added to the One Touch Switch Industry Process:

Appendix 1: SLAs and response times.

“Dispatch of impacts of switching.

For an LRCP with access to a consumer e-mail address or mobile number, switching information is to be sent by one or both of these means:

• within 60 seconds of the receipt of a matching request from the GRCP in 99% of cases
• within 1 hour of the receipt of a matching request in 100% of cases.

In other cases, or where the consumer has indicated that communication is to be via surface mail, the LRCP is to send a letter by first class post:

• where the matching request is received before 4pm on a working day, by 5pm on the same day in 99% of cases, and by 12pm the following day in 100% of cases.
• where the matching request is received at any other time, by 12pm on the next working day in 99% of cases, and by 5pm on the following working day in 100% of cases.”

Background to the proposed change

The April 2023 General Conditions require Communications Providers (“CPs”) to implement and operate the switching process known as One Touch Switch (“OTS”) for residential customers who are switching Fixed Communications Services at the same location.

OTS requires the Losing Provider to send certain information to the Switching Customer including any early termination charges. The information to be provided to the Switching Customer by the Losing Provider is detailed in the General Conditions C7.12. For the purposes of this consultation this is referred to as the “Switching Information” or “SI”.

Condition C7.27 of the General Conditions obliges the Losing Provider to make the SI available “promptly in accordance with any applicable industry agreed processes and via the quickest communication method, unless the Fixed Switching Customer requests an alternative switching method.” Condition C7.4 requires CPs to maintain “simple and efficient processes” for switching, and further requires that CPs do not delay or abuse the process.

In an open letter to the OTS Steering Group and fixed voice and broadband providers, dated 3 March 2022, Ofcom restated their policy objective of a “quick, easy and reliable” OTS process, and set a target expectation of a 60 second response to a matching request.

TOTSCo believes that an SLA should be defined for the time taken for the Losing Provider to provide Switching Information to customers after receipt of a matching request. This will bring clarity to CPs and to users of the process. Without an SLA, CPs may implement a range of service levels, leading to confusion in the industry and to a variable customer experience.

So that a switching order can take place within the reasonable parameters of a sales discussion or online customer journey, TOTSCo proposes that the SI should be sent within 60 seconds of the receipt of a matching request. This will:

• give the Switching Customer the best experience, as receiving the Switching Information during the sales discussion or online customer journey will allow while not requiring a repeat call or pausing the switching journey
• give effect to the GC requirement for the LP to supply the SI “promptly”.

 

Respond to consultation

TOTSCo welcomes views on all matters related to the proposal, including but not limited to:

• Impact on customer experience
• Challenges in complying with the proposed SLA
• Time to implement any necessary changes to comply with the proposed SLA.

The consultation is in particular seeking the views of:

• Communication Providers serving residential customers
• Trade associations representing the above.

Other industry participants are also welcome to respond, including:

• Communications Providers with business customers, as they may use parts of the OTS process in the future
• Providers of IT services which may be used by Communications Providers in generating and despatching Switching Information.

To take part in the consultation, please send your submissions by any of the following methods:

• e-mail admin@totsco.org.uk quoting “SI SLA Consultation” in the subject line
• complete the submission form below
• by post to our registered office: F.A.O TOTSCo  “SLA Consultation”, 10 Fitzroy Square, London, W1T 5HP

In all cases, please include in your response:

• your own name and position within the organisation
• the name of the entity on whose behalf you are responding (only one response per entity should be submitted)
• the nature of the entity (e.g. CP, other body) and its interest in the generation and dispatch of Switching Information
• where the entity is a CP providing fixed voice and /or broadband services, whether it has residential customers.
• please indicate clearly if any part of the response is confidential.

Submissions must be received by Friday 13 January. Responses are in confidence and will not be published although points made may be used in open discussions where doing so does not allow the source to be identified. By responding, you confirm that you have the authority to act on behalf of the organisation.

A decision on whether the proposed change is to be incorporated in the OTS Industry Process will be made in due course and will be notified to all who participate in the consultation and communicated widely within the industry as a whole.