Rapid Response Team
Formation of a joint industry & regulator team to respond to emerging issues
The RRT is made up of people with the relevant expertise to be able to review the reported issue and advise on the next steps to be taken. The RRT members for the first meeting of any issue should not be the companies or individuals that may be deliberately or inadvertently creating the issue under examination. In most situations, the next steps may include consultation with the companies affected to draw on their expertise.
For example, in a situation such as malware or advertising hacks, where it is clear that the malware / hack is designed to create consumer and industry damage, the RRT would be made out of the people who can identify the problem and recommend the next steps. The malware beneficiary value chain, the advertising agencies and potentially the advertisers may not be involved in the first meeting due to potential conflict of interest.
In the case of a wide scale consumer issue emerging due to a particular service type or method of promotion, the RRT would be made up from expertise in the service type or promotion methods but wherever possible, without conflict of interest.
Industry Trade Body representatives will be invited to be part of the RRT if relevant.
At this moment in time, a list of people is being created, who are willing to be part of any future RRT and have an area (or areas) of expertise to contribute. This will also include people from outside the industry.
What are the primary objectives?
To form an industry / regulator collaborative group to address key issues as they emerge or as the threat is perceived, to ensure the issue is dealt with effectively, efficiently and pragmatically so that the industry can grow. Specifically:
Identify threats or risks faster
Ensure Industry buy-in to Rapid Response Team proposals is swifter and less liable for challenges due to Industry input from outset
Reduce the number and impact of serious scams which can infiltrate the sector
Eliminate scams which do arise, by communicating with industry more efficiently and reduce timescales for resolution
Reduce consumer harm by dealing with emerging issues in a more effective way
If relevant, plan updates to Code and Guidance to build on lessons learned
If relevant, create communications to industry to assist with their understanding of how to eliminate the identified issue
Maintain industry stability
By providing an opportunity to understand the issues quickly, discuss, and ultimately change a sector’s approach to phone-paid services, this will allow the Phone-paid Services Authority to respond pragmatically to compliance issues in the market (without affecting its ability to take enforcement action as necessary) whilst balancing industry growth.
A key function of each RRT will be to assess each perceived threat to determine what aspect of the user experience needs to be tuned, what urgent industry response (if any) is appropriate given the threat and to provide comprehensive analysis to inform and support the next steps.
The RRT can also identify trends in services where new service categories emerge that fall into gaps in policies. The recent examples being Q&A services and subscription verification messages, thus ensuring that informed changes can be made around policies which have the support of industry from the outset.
Who requests a Rapid Response Meeting?
Members of the Phone-paid Services Authority Industry Liaison Panel which includes Trade Bodies, Sector Representatives, Networks, Ofcom and the Phone-paid Services Authority can request a Rapid Response Team Meeting at any time. The issue should be directed to the Phone-paid Services Authority setting out the scale and nature of the problem.
The issue to be examined is debated between the Phone-paid Services Authority and the requester or, if the requester is the Phone-paid Services Authority, between the Phone-paid Services Authority and the most relevant trade body or sector representative for the issue.
These two parties will determine what additional information is required to ensure the proposed meeting is meaningful and productive for the attendees and which potential expertise is required to ensure the proposed meeting is as fully informed as possible. The expertise selected must not be conflicted by the issue being examined and should not be put into a position of assessing its own or a competitors services.
The two parties will also agree the Chair of the meeting (to ensure it is focused), a minute taker to ensure agreed actions are recorded plus the potential date and location for the meeting. The Phone-paid Services Authority will normally be able to offer facilities for hosting meetings, including at short notice. The Chair of the RRT is charged with ensuring the team is focused to deliver a rapid response and all possible avenues to maintain momentum are being followed.
The Phone-paid Services Authority Industry Liaison Panel will discuss and implement additional measures that could facilitate the smooth operation of the Rapid Response Team. This should also include the mechanism by which persons other than members of the Phone-paid Services Authority ILP could request an RRT meeting.
How is the RRT meeting conducted?
The members of each RRT are provided with the relevant information as far as possible in advance of the meeting, are invited to the meeting and are advised why their expertise is required. If they are unable to attend the meeting, the two parties as above must decide if the meeting can be effective without certain parties and if not, then the meeting may need to be rescheduled to accommodate the commitments of the relevant expertise.
The Chair should ensure everyone in the meeting is clear on the reasons for the meeting, is aware of everyone’s role and has had an opportunity to digest any advance information. A template meeting agenda is available. The information is then debated in an open forum under the Chatham House Rule and decisions are then made on the next steps. These decisions are recorded.
The next steps may involve deeper analysis, the addition of further expertise at a follow up meeting or a sub-group formed to work on a set of actions. It is vital that the next steps are implemented as soon as possible to ensure momentum and that any additional expertise required is fully briefed by a member of the RRT prior to the next meeting.
It may be possible that the resolution plan does not need the Phone-paid Services Authority involvement, in which case the steps taken are recorded and detailed back to the Phone-paid Services Authority for information.
Each meeting is summarised back to ILP to demonstrate progress.
There is no objective to continue meetings if the resolution plan can demonstrate a successful handling of the issue through measurable data.
What is reported?
The reason for meeting and the objectives of each RRT are reported to ILP unless by doing so, it may compromise any investigation into an issue for criminal or regulatory intervention.
The report should detail the analysis of the issue undertaken at each meeting, the next steps proposed, the next meeting date and the proposed invitees.
When does each RRT team finish?
As each RRT is formed to examine an issue based on the relevant expertise needed, each meeting should decide which relevant expertise is needed for subsequent discussions. If a member of the RRT is no longer needed, they are advised or they may decide for themselves that no further involvement is needed unless called.
Each RRT is disbanded once the identified issue is resolved or has a resolution plan. The RRT will report to the ILP that it has done so.