PhonepayPlus publishes discussion document on consumer vulnerability

Today we publish a discussion paper on vulnerability. The paper provides an opportunity to start a conversation with all market participants to discuss what a changing market means for vulnerable consumers and what we can do collectively to protect them in a healthy and innovative market.

The premium rate service market is changing. While some services are experiencing a challenging operating environment, services like giving, gaming and gambling are becoming increasingly prevalent. As a regulator, we have been thinking about what these changes mean for consumers, particularly those who are vulnerable. We recognise that protecting vulnerable consumers is not just about regulation but involves all market participants including industry and consumers.

We have also been thinking about what vulnerability now means. Traditional definitions of and solutions for vulnerable consumers increasingly feel static. What is becoming increasingly clear to us and other regulators, like the FCA, is that vulnerability is dynamic and broad. If we are to ensure that vulnerable consumers are protected from harm, we are going to have to think about more than just regulation.

The vulnerability discussion document published today provides a basis on which to start that conversation.

To read, Vulnerability: a PhonepayPlus Discussion Document click here.

We have also written a blog on the discussion paper which can be read here.

At this stage, we would welcome views from stakeholders as to the risks identified in this paper and the steps proposed to mitigate them. While we do not pose specific questions in this paper, the following may help respondents:

Have we identified the right risks?
If not, where should we focus our attention?
Is a coordinated approach to mitigating risk realistic and proportionate?

Responses would be welcomed within eight weeks of publication of this paper. Where possible, comments should be submitted in writing and sent by email to Jonathan Levack at JLevack@phonepayplus.org.uk by September 30th 2015.