Notice to Industry: Changes to PhonepayPlus' process used to obtain revenue data during an investigation
PhonepayPlus’ Investigations Team has recently carried out a review of the process used to obtain revenue figures in relation to services under investigation following an increasing number of recent cases being adjourned by Tribunals.
The Code Compliance Panel (“CCP”), which makes up PhonepayPlus Tribunals, has raised issues, including concerns around potentially inaccurate service revenue as a result of revenue figures being non-verifiable by parties further up the value-chain to the party being investigated. This issue specifically affected services under investigation where multiple services were being operated on a shared shortcode.
As a result of these issues, the Investigations Team has implemented a change to the current process used to gather revenue data, with the overall objective being to ensure that the CCP is presented with accurate and independently verifiable revenue figures for any service being adjudicated. Throughout the project period, the Executive has met with a number of industry stakeholders to gain an understanding of the technical capabilities and limitations of billing systems used by various parties within the premium rate value-chain.
As part of the new service verification process, the Executive is likely to request revenue figures at the preliminary stage of a formal investigation, and before questions are asked about the promotion and operation of the service. Examples of requests may include:
- Revenue generated on each individual service operating on a shared shortcode;
- A breakdown in relation to the revenue generated for each Mobile Network Operator;
- Call logs or message logs to support revenue data supplied; and
- Invoices and copy bank statements.
The Executive is likely to request revenue data from one or more parties in the value-chain, not just the party under investigation. We may also use any other available means to independently verify service revenue.
Although the level of information we may request is likely to be more than we typically requested in the past, we will only make requests which we believe are reasonable and proportionate to an investigation. It is important that all parties under investigation co-operate fully in respect of these requests for information. In supplying information, we expect all parties to be accurate and, where we discover evidence that revenue has been falsified or deliberately omitted, we may raise a breach of the PhonepayPlus Code of Practice.
The process will be reviewed on an ongoing basis and we would welcome feedback during our dealings with providers and Network Operators in respect of any investigations.