ICSS alerts upon connection compliance update

Our findings from recent ICSS data submitted to the PSA by ICSS providers have brought to our attention multiple issues relating to the transparency, fairness, and clarity of the alerts callers hear upon connection to the ICSS. This update reminds providers of their obligations under the 15^th edition of the PSA Code of Practice (the Code) and highlights our areas of concern. 

Code Requirement 3.2.10 and Annex 1: Specified service charges and duration of calls

Transparency Requirement 3.2.10 requires:

Where a voice service connects the consumer to another organisation, the cost of continuing the call, including information about access charges and any additional chargeable element of the service such as a premium SMS, must be clearly stated in an alert before onward connection. Where the service is an Information, Connection, and Signposting Service the alert upon connection must: 

• (a) state the cost of the call per minute and/or per call
• (b) state that the organisation to which the service connects can be contacted directly no or lower cost and provide the organisation’s direct contact number
• (c) state the maximum call charge
• (d) obtain positive opt-in from the consumer to: 
     i. continue the call; and 
     ii. connect to the organisation referred to in b) above or referred to within the alert 
• (e) where the service provides any additional chargeable element, such as a premium SMS, obtain separate positive opt-in from the consumer for that element of the service.

For ICSS that charge on a per-minute basis Annex 1, paragraph 1.12 of the Code specifies a maximum service charge of £40 and Annex 1, paragraph 1.13 requires the alert upon connection to inform consumers that the call will be terminated once the maximum service charge of £40 is reached.

Key issues identified across various ICSS IVRs submitted to the PSA

1. A number of IVRs omitted the following key information and action required by Code requirement 3.2.10 and Annex 1 of the Code: 

• state that the organisation being connected to can be contacted directly for no or lower cost 
• provide the direct contact number for the organisation it connects to
• ensure a maximum service charge of £40 where the ICSS charges on a per minute basis
• provide a warning that the call will be disconnected once the maximum service charge is reached where the ICSS charges on a per minute basis
• obtain positive opt-in to be connected to the sought after organisation 
• ensure positive opt-in is made available before the required information is provided.

2. The wording used and the ordering of the wording of some IVRs submitted may confuse/mislead consumers into thinking the service is associated with the organisation that the ICSS connects to, including the:

• repeated use of terms such as “customer services”
• lack of clear identification of which organisation the ICSS connects to
• lack of the ICSS provider name, as recommended in Transparency guidance.

3. Clarity and audibility of alerts:
We have concerns that the alert or part of the alert (spoken) is given too quickly making understanding difficult.

Next steps
Providers must ensure that all elements of Code Requirement 3.2.10 are complied with in their IVR messages. Where an ICSS is charged on a per minute basis, providers must ensure they are also complying with the requirements of Annex 1 of the Code.

The Transparency Standard guidance sets out very clear examples of compliant IVR messages and we strongly recommend that the guidance is followed.