Have you read through all of OFCOM’s ‘One Touch Switch’ documentation? No? You’re not alone. It’s contradictory, heavily redacted and incomplete; in addition to being extremely dense and technical. The apparent goal of the regulation is to ensure switching internet service providers is a seamless process for consumers. However, its implementation has raised several concerns and created far more confusion than clarity… and we’re only just getting started. In this article we will delve into a few of the issues and concerns we have raised around Ofcom’s ‘One Touch Switch’ regulation.
Complexity of Switching Mechanism:
One of the primary issues with the ‘One Touch Switch’ regulation is its complexity. The goal was to simplify the process of switching service providers, but the plethora of technicalities and administrative requirements might have backfired. Consumers may find it daunting to navigate through the intricate switching mechanism, leading to hesitation and confusion. As OTS will become the primary route for new customers, ensuring that it is fully integrated into your existing OSS/BSS and creating an organic and seamless process for customers is essential for success in a competitive market.
Disparities Among Service Providers:
While Ofcom intended to level the playing field, ‘One Touch Switch’ seems to have created disparities among service providers. The ‘Big Six’ have collaborated together to create TOTSCo and the associated TOTSCo Hub. As the vast majority of customers sit with these providers, smaller Alt-Nets have little option but to use it. Many of them lack the same level of resources of their larger counterparts, and may struggle to meet the stringent requirements, leading to an uneven competitive landscape.
Abusing the System
The promise of a seamless switching process is enforced by tight SLAs. Ofcom requires losing providers to respond to a match request and provide a conditions letter within 60 seconds. However, if a customer’s preferred method of communication is via ‘post’, this 60 second SLA becomes 24 hours for the conditions letter. It’s not a big leap to imagine organisations abusing this fact and ensuring ‘post’ is the primary method of communication for their customers, therefore delaying the switch and allowing more time for retention processes to kick in.
Data Privacy and Security Concerns:
With the ‘One Touch Switch’ regulation, consumers are required to provide sensitive personal information to facilitate the switch. This raises concerns about data privacy and security, especially when leveraging hosted solutions outside of your own business. Solution providers might have access to more personal data than necessary, potentially leading to misuse or unauthorised access.
Customer Lock-in and Early Termination Fees:
The contradiction arises when the ‘One Touch Switch’ regulation attempts to offer consumers more freedom while they remain bound by lock-in periods and early termination fees. Providers might resort to increasing these fees to discourage customers from switching, limiting the effectiveness of the regulation and trapping consumers in unfavorable contracts.
Lack of Clear Communication:
The introduction of ‘One Touch Switch’ has seen service providers scrambling to comply with the new rules. The documentation released by Ofcom has changed significantly over the past 12 months and continues to be a moving target. This lack of clear communication and ambiguous terms and conditions have led to misunderstandings, leaving organisations with an unclear picture of the implications.
Losing Providers with Poor Implementation
One foreseeable issue with ‘One Touch Switch’ may arise when a losing provider has poor or inaccessible customer data, e.g. UPRN is not matched to an address. Losing providers may still adhere to the 60 second response time, but continue to reject switch matching indefinitely because they cannot find the customer based on the four required data points. Additionally, losing providers who are leveraging an ineffective hosted solution are subject to potential downtime or delays in responses that are outside of their control.
Lack of Contingency Planning:
The regulation appears to lack a comprehensive contingency plan for potential issues or disputes that may arise during the switching process. A full reliance on the TOTSCo Hub creates a single point of failure and the absence of clear guidelines for consumers and service providers may cause difficulties in resolving conflicts.
Consumer Education:
The long term success of ‘One Touch Switch’ hinges on consumer awareness and understanding. However, there is a lack of sufficient efforts by Ofcom to educate consumers about the regulation and its implications, potentially leaving them vulnerable to exploitation. With a firm go-live date now in place and OTS set to be the primary route to new business for organisations, this needs to be addressed sooner rather than later.
Ofcom’s ‘One Touch Switch’ regulation offers the promise of greater consumer choice and competitive services. However, its implementation has brought forth a myriad of issues, unknowns, and contradictions. ThirdEye Consulting have built an ‘Out of the Box’ One Touch Switch solution to take the pain away from service providers. This fully managed solution will adapt to any new changes to the regulation and fosters an environment where consumers truly have the power to switch seamlessly and make informed decisions about their services.
Come and meet the ThirdEye team at Connected Britain on September 20th & 21st to hear more about our OTS solution.
