I C S T I S


Virtual Chat and Live Premium Rate Services

Statement


August 1997







Contents

PART ONE - INTRODUCTION AND UPDATE PAGE

1. INTRODUCTION 1

2. SIZE OF SECTOR - UPDATE 1

3. COMPLAINTS STATISTICS - UPDATE 1

4. VIRTUAL CHAT DEFINITION

PART TWO - VIRTUAL CHAT SERVICES

4. UNAUTHORISED USE AND HIGH BILLS 2

5. BARRING UNDER-18 ACCESS TO VIRTUAL CHAT SERVICES 8

6. EMPLOYEES ON-LINE 8

7. DELAY 9

8. TRAINING 9

PART THREE - LIVE SERVICES

9. UNAUTHORISED USE AND HIGH BILLS 10

PART FOUR - OVERALL CONCLUSIONS 11

APPENDIX I - SUMMARY LIST OF CONCLUSIONS 12

APPENDIX II - LIST OF CONSULTATION 15









ICSTIS' STATEMENT ON THE FUTURE REGULATION OF VIRTUAL CHAT AND LIVE PREMIUM RATE SERVICES

PART ONE - INTRODUCTION AND UPDATE

1. INTRODUCTION

1.1 This document sets out ICSTIS' proposals for the future regulation of virtual chat and live premium rate telephone services. These proposals have been developed and informed by the responses to the consultation document, Virtual Chat and Live Premium Rate Services, published in March 1997. ICSTIS received 28 replies and is extremely grateful for the time and effort made in compiling these responses which have greatly aided the Committee's work.

1.2 Responses to this statement should be received by ICSTIS by Friday 10 October 1997. Changes to the Code will be incorporated in the eighth edition which is being consulted on in parallel with this document. Draft Code provisions throughout this document mirror provisions in the draft eighth Code and are numbered accordingly.

2. SIZE OF SECTOR - UPDATE

2.1 In the consultation document (section 3.1) approximate figures (based on industry estimates) from early 1996 were given for the size of the virtual chat sector. ICSTIS estimated that some 7.8 million calls are made to virtual chat services each year, amounting to approximately £28 million spent by callers.

  1. Comments made by virtual chat service providers indicate that these figures underestimate the current size of the market. Figures of 15 to 18 million calls per year were put forward as being a more realistic estimate of the number of calls now being made to virtual chat services. The continuing growth in the number and popularity of virtual chat services is reflected in the number of advertisements for these services. The number of complaints in relation to the number of calls continues to be low.

3. COMPLAINTS STATISTICS - UPDATE

3.1 ICSTIS has directly handled 210 complaints about virtual chat services in the first six months of this year. Thirty-three of these concerned high bills caused by calls to virtual chat services. Non-billing complaints concerned pricing information, misleading advertising, delay, offensive messages and difficulties in accessing or using a particular service.

3.2 Comparing the first six months of this year with the last six months of 1996, it appears that the number of complaints about high bills remains constant but the amounts complained about are falling. Complaints about breaches of the Code also appear to be level with the previous six months. The fall in the amount of money claimed in high bill complaints is difficult to explain but is to be welcomed.

4. VIRTUAL CHAT DEFINITION

4.1 It is important to differentiate between virtual chat and live services. Virtual chat services are characterised by a number of elements: callers send and receive separately recorded messages and cannot make direct contact or hear what is being said to them immediately. A new Code provision is therefore necessary to define virtual chat services.

4.2 Some virtual chat services allow dating to take place. For the sake of clarity, services which allow contact details to be exchanged between participants must also comply with all the rules in the contact and dating section of the Code.

Virtual Chat definition - conclusion

The Committee proposes to introduce the following requirement into the Code of Practice:

4.3.1 Virtual chat services are services in which callers send and receive separate recorded messages. There is no element of simultaneous conversation during which callers can be in direct contact with each other or can instantly hear or respond to each other - such services are classed as live conversation services and are subject to the provisions of the ICSTIS Live Conversation Services Code of Practice.

4.3.2 Virtual chat services which are promoted as contact and dating services or which allow contact details to be exchanged between participants are also subject to the dating provisions where it is reasonable and applicable.

PART TWO - VIRTUAL CHAT SERVICES

4. UNAUTHORISED USE AND HIGH BILLS

4.1 In the consultation document the Committee set out three proposals for dealing with the problems of unauthorised use and high bills caused by calls to virtual chat services. The first was the fixing of a maximum call cost. The second was the use of call cost warning messages during calls, in addition to any information contained on promotional material. The third was the setting up of a system of redress for telephone subscribers who had suffered unauthorised use. ICSTIS remains concerned that these services are intrinsically likely to cause some unauthorised use and/or high bills.

Preventing unauthorised use and high bills

4.2 The advertising for virtual chat services clearly stimulates a high level of demand and the majority of callers are comfortable with the amount of money they spend on these services. But, as long as virtual chat and similar services exist and are widely promoted, there will be people who are sufficiently tempted to use other people's telephones to call them. This may be without the subscriber's actual or implied permission. There are clearly callers who simply have difficulty in controlling their own, or their families' and acquaintances', use of such services. This can occur for a variety of reasons. The industry must recognise that such callers, although few in number, do exist.

4.3 Callers who become, in effect, addicted to the use of such services are not going to be greatly helped by preventative measures. The extent of their addiction or the attraction of the services may cause them to seek to get round any preventative measures which stop short of a total bar on them using such services. Call-barring is often suggested by telephone companies to subscribers who have difficulty in paying their bills as a result of calls to premium rate services.

4.4 Given the number and variety of premium rate services available and the number of service providers involved in the industry, the most effective way to try and deal with these problems is by improving contact between telephone subscribers and their telephone companies. It is at this point that overall spending on telecommunications services in general, and premium rate services in particular, can be monitored. Subscribers can be alerted to a noticeable increase in spend. This will warn them that someone else is using their telephone, possibly without their permission, to an extent that probably requires investigation. Alternatively, it will serve to inform subscribers of their own spending levels. In either case, the subscriber can take appropriate action. ICSTIS requests that network operators increase the use of early warning systems.

4.5 Further comment was requested in the consultation document on the subject of credit limits and selective call barring. Network operator-imposed credit limits were seen as a good idea by service providers, but no support was forthcoming from the network operators. They questioned the need for such limits, as most subscribers do not have problems in controlling use of their telephones and recent subscribers, traditionally a problem group as regards billing disputes, now have credit limits set. Service provider credit limits are an interesting idea, but it is difficult to see how they could work effectively in practice. Even using Calling Line Identification (CLI) is less than satisfactory in this respect as it may be withheld and is not yet universally available. ICSTIS therefore must try and control this problem by imposing requirements upon service providers aimed at limiting the number of instances of unauthorised use and high bills. However, the Committee sees credit limits as the long-term answer to this problem.

4.6 In trying to prevent unauthorised use and high bills, partly or wholly attributable to vulnerability, the same consumer protection issue comes into play. It is vital that callers know the mounting cost of the calls they are making. If they are using someone else's telephone to make the call, but they do not have the authority to do so for that purpose, then callers will be aware that the calls will probably appear on the subscribers' itemised bills. The knowledge of the amount that has been spent will, in some cases, make the caller think twice about continuing the call. If it is the subscriber who is making the calls, they can then make an informed decision about continuing the call. The question for the Committee is how best to achieve consumer awareness of mounting call costs, while allowing the industry to operate effectively.

4.7 The Code already requires that call costs are clearly displayed in promotions for premium rate services. However, this often only informs consumers of the cost per minute of calls. Two of the proposals for change put forward, cost warnings and maximum call costs, were both aimed at giving consumers more information and control.

Call cost warnings during calls

4.8 Some network operators and service providers have stated that such a measure is unnecessary and would not help prevent unauthorised use and high bills. However, some service providers and network operators supported the idea, as did consumer organisations, who saw this as a useful general consumer protection measure.

4.9 Informing consumers about mounting call costs and providing them with an opportunity to reflect and possibly discontinue a call is best achieved, the Committee considers, by the use of call cost warning messages and affirmations. A call cost warning message after a set time from the commencement of the call will remind callers of how much of their, or someone else's, money has been spent. The requirement to affirm a wish to continue the call will make the caller consider their actions if they choose to continue.

Call cost warnings - conclusion

The Committee proposes to introduce the following requirement into the Code of Practice:

4.3.6 All virtual chat services must, as soon as is reasonably possible after the caller has spent £10.00, and after each £10.00 of call spend thereafter, do the following:

a inform the caller of the price per minute of the call and the number of minutes which have elapsed or the total cost of the call so far,

b require callers to provide a positive response to confirm that they wish to continue the call. If no such confirmation is given, the service must be terminated.

The Committee is aware of some of the technical and practical difficulties surrounding such a requirement, given the variety of services operating, and would welcome comments on how this can be best implemented.

Maximum call cost limits

4.10 Forcibly disconnecting callers from a service they have dialled would have some effect on unauthorised use, although it will not stop it altogether. Callers who are determined to ring these services will re-dial or ring another service. The cut-off may make certain callers consider if they should keep calling, knowing that each time they do a set sum of money will have been spent, but it is impossible to predict its exact effect. A maximum call spend might well have more effect on helping users who are responsible for paying the bill keep track of what they are spending.

4.11 If a maximum call spend is to be set at a level at which the vast majority of callers are not inconvenienced by being forcibly cut off from a conversation in which they are participating, the level would need to be quite high. If, for example, a call cut-off at £15.00 is set, this would translate into 30 minutes of conversation at the 50 pence per minute tariff. According to ICSTIS' research, some 90 per cent of calls to virtual chat services terminate before this point is reached. The remaining 10 per cent still represents some 1.5 million calls, accepting the industry's estimate of the number of calls made to virtual chat services. This is still an extremely large number of calls to affect with such a measure. Callers who are enjoying a conversation should not be put to the expense of

re-dialling (the cost of listening again to the service introduction and recording another introductory message) and the inconvenience of losing contact with a particular individual or group with whom they are in contact. Setting the cut-off at any higher time limit would have little effect.

4.12 The majority of replies to the consultation document from network operators and service providers were strongly opposed to the idea of setting a maximum call cost. Consumer groups were supportive of this as a general consumer protection measure, but even then doubt was expressed as to how effective such a measure could be in dealing with unauthorised use.

4.13 Concerns about the rising numbers of complaints and bad debts caused by high bills, expressed by network operators at the start of ICSTIS' work in this area, have not materialised in terms of statistics or complaints referred to ICSTIS. Responses to the consultation document received from network operators, who have contracts for telecommunications services with domestic subscribers, indicated that they were not aware of problems in this area. In addition, the number of complaints about unauthorised use and high bills received by ICSTIS appears to be declining.

4.14 At present the Committee cannot justify the imposition of a maximum call cost which will inconvenience a lot of callers. However, the Committee will carefully monitor the effect of the implementation of call cost warnings and affirmations and hopes to see a drop in the number of high bill and unauthorised use complaints reaching ICSTIS.

Maximum call cost - conclusion

No overall maximum call spend will be required at present. The ICSTIS Secretariat will continue to monitor the number of claims for unauthorised use and high bills it receives in respect of virtual chat services.

Dealing with problems - disputed bills and unauthorised use

4.15 Three proposals were put forward in respect of compensation: a Code change to require compensation to be paid (possibly involving the setting up of a compensation scheme), closer contact between the different parts of the industry enabling effective resolution of billing disputes and monitoring the effects of other measures proposed in the consultation document.

4.16 There was clear and strong support for the boosting of ICSTIS' role concerning disputes about virtual chat services. Network operators have stated that they are willing to discuss with ICSTIS and service providers how disputed bills can be better dealt with. Service providers stated on a number of occasions that they are happy to meet reasonable claims and wish to have closer contact with their customers.

4.17 Service providers clearly see callers to their services as their customers. They wish to encourage direct contact in order to quickly identify problems and ensure that callers re-use their services. Network operators, no doubt, also consider telephone subscribers, who may or may not be the same person as the caller in question, as their customers. There is a potential for confusion here. It is vital that consumers can quickly get access to the organisation that can sort out their problem. When considering redress consumers fall into two categories. Certain callers who seek redress because calls to a particular service were unsatisfactory for some reason probably need, in the first instance, to talk to either the service provider direct or ICSTIS. Subscribers who want to query (and possibly refuse to pay) items on their telephone bills need to talk to their network operators, with possible later reference to ICSTIS or the service provider(s) involved.

4.18 This increased involvement and the need for a procedure to deal with bills that are disputed needs to be considered in conjunction with Oftel's recent proposal for a premium rate helpline:

"..it is proposed that a simple statement be put on bills carrying PRS calls which identifies a free 'PRS helpline', whereby a customer with a problem relating to a PRS call can phone to have their query dealt with or find out who to contact if they are not satisfied with the service provided."

At the moment, ICSTIS already carries out this task as it receives many requests for information about services and service providers, often forwarded on by network operators. The Oftel proposal is currently being discussed.

4.19 If the above proposal were to be adopted, items on bills, which subscribers claim were not authorised by them, could then be directly taken up with service providers. However, many disputed bills are comprised of calls to a variety of services provided by any number of service providers. It is clearly vital that network operators, service providers and ICSTIS communicate and co-operate when dealing with disputed items. Otherwise there is potential for confusion and duplication of effort in investigating claims.

4.20 An ICSTIS/industry working group is to be set up to ensure that communication about and investigation of disputed bills is effective. Consumers do not want to be passed around a number of agencies and organisations before finding out who is responsible for particular services. In addition, consumers must be confident that if their claims are valid, and reasonable, they will be met by the industry.

4.21 There is already a compensation scheme in existence for live conversation services. It exists to ensure that subscribers who have suffered unauthorised use, as a result of calls made to live services, have access to compensation. The Live Conversation Services Code of Practice and the Compensation Scheme have two main strengths: they allow ICSTIS to fully investigate complaints as the Live Code requires the recording of most live services and services providers can be compelled to pay compensation in respect of unauthorised calls to live services.

4.22 The Committee considers that the cost and bureaucracy involved in setting up a compensation scheme (including a requirement to record all calls) similar to that in place for live services is not warranted by the current level of problems with virtual chat services. Any compensation system for virtual chat services must replicate the best features of the live system. The Committee considers that this can be best achieved in two ways. Firstly, by working with the industry on guidelines building on the best practice of network operators, service providers and ICSTIS when dealing with complaints and claims for redress. Secondly, by having an ICSTIS Code of Practice provision which requires service providers to have in place systems for dealing with complaints and paying compensation. This will ensure an industry-wide approach to the problem and provide a backstop if all attempts at dispute resolution fail. The precise detail of such systems and when compensation might be payable will be dealt with in an ICSTIS guideline. This could cover defining a complaint, time limits for dealing with complaints, procedures for dealing with complaints made by telephone and informing complainants how they can take matters further if still unsatisfied. This guideline will relate to the ICSTIS Code in the same way that it is proposed that other ICSTIS Guidelines do (see the consultation document on the eighth edition of the ICSTIS Code). It is hoped that this guideline can be agreed by the Autumn of this year.

4.23 The success of this system will depend on the co-operation of network operators and service providers. As no requirement to record all calls is being put in place there may be issues of proof in particular cases. Many disputed bills contain calls to services operated by a variety of service providers. An effective procedure, which does not involve service providers duplicating effort in investigation claims, will have to be worked out. If such co-operation does not prove effective the Committee will review the need for a compensation scheme.

Disputed bills - conclusion

ICSTIS will work with the industry to produce good practice guidelines on the handling of disputed bills and complaints about virtual chat services. In addition, the following amendments to the Code are proposed:

Service providers must:

4.3.4 a have in place and implement in appropriate circumstances a reasonable complaints handling procedure,

b pay reasonable and valid claims for compensation.

  1. ICSTIS has a range of sanctions which it will apply according to the degree of seriousness with which it regards the breach. Having taken account of all relevant circumstances, ICSTIS may:

5.7.2 h require, in the case of virtual chat services (see section 4.3), that service providers pay appropriate compensation to consumers.



5. BARRING UNDER-18 ACCESS TO VIRTUAL CHAT SERVICES

5.1 Most respondents to the consultation document agreed that such a Code change is necessary but reservations were expressed about how this would work in practice. The Committee is fully aware of the difficulties involved in trying to gauge, on the telephone, if a caller is over 18-years-old. But the Committee will expect service providers to use their best endeavours to do so. This is an attempt to deter under-age callers and mirrors requirements in the ICSTIS Live Conversation Services Code of Practice.

Under-18 access - conclusion

A new Code of Practice provision will be introduced as follows:

4.3.4 Service providers must:

c use all reasonable endeavours to ensure that nobody under the age of 18 uses virtual chat services.

6. EMPLOYEES ON-LINE

6.1 ICSTIS proposed that the use of employees by service providers in conversations with callers to virtual chat services should be made clear. This recommendation caused a degree of confusion as service providers thought ICSTIS was requiring all monitors (service provider employees listening for under-age use or offensive language) to declare themselves as such on-line. As the original recommendation states, a change will only be made in respect of service provider employees who are not monitoring the lines for under-age callers or inappropriate material but actually taking part in conversations. Consumer organisations expressed strong support to the effect that callers should know if the person they are talking to might not be a genuine caller to the service.

6.2 Chat and chat and date services fall into two main categories. Some virtual chat services only involve chat. The service providers who operate these services actively discourage the exchange of home telephone numbers. This is achieved by monitoring the content of every message sent. Virtual chat and date services often feature a dating section which is sometimes not easily distinguished from the chat section and is easy to access. Most service providers operating these types of service do not monitor every message that is sent in the chat section or left in the dating section. Some callers to the second type of service may be expecting to make contact, possibly leading to a physical meeting, with another caller. If they do not know that service providers employees are participating in the service they may not achieve the aim of the call. Callers to these services should know, in advance, if service provider employees are going to be involved in conversations.

Employees on-line - conclusion

The Committee considers that callers should know in advance if employees of the service provider might be taking part in conversations, in cases where the services are promoted as dating services as well as virtual chat. This factor is likely to affect a decision to call a particular service. A new Code of Practice provision to reflect this has been drafted:

4.3.5 Promotions for virtual chat services which are promoted as contact and dating services must make it clear that some participants on the service may be employees of the service provider if that is the case.

7. DELAY

7.1 The consultation document raised the problem of lengthy introductory messages to services. There was strong agreement amongst respondents that ICSTIS should monitor closely the introductory sections to services.

Delay - conclusion

ICSTIS will continue to look closely at complaints involving alleged delay. Callers should be allowed to by-pass introductions, except in the case of services that involve dating which should continue to require callers to hear the essential safeguards in this respect. This will not require an ICSTIS Code amendment.

8. TRAINING

8.1 The issue of the training of service provider employees (monitors) who listen to introductory messages and actually participate in conversations was raised in the consultation document. This will reflect the provisions in the ICSTIS Live Conversation Services Code of Practice.

Training - conclusion

An amendment to the Code of Practice will require that service providers ensure that all monitors involved in virtual chat services should be given adequate training on the requirements of the Code:

4.3.3 At the time of entering into employment, service provider employees who are either monitoring or taking part in the service must be given a copy of this Code. After adequate training (which should be for a minimum of four hours), the operator or monitor must sign a document to confirm that s/he has read this Code and has had its contents and significance explained and that s/he will comply with its provisions. On-the-job training should also be given. A copy of this signed document must be retained by the service provider and should be produced on request from ICSTIS. No operator or monitor shall be under the age of 18 and ICSTIS will retain the right to impose a condition that operators should be of a higher age.

PART THREE - LIVE SERVICES

9. UNAUTHORISED USE AND HIGH BILLS

9.1 The revival of the live services market noted in the consultation document has not, so far, resulted in an increase in claims for unauthorised use. More widespread or aggressive advertising, however, could lead to more claims. The amount of money in the Compensation Fund is currently adequate.

9.2 The Committee can impose conditions on the operation of live services as part of the live services prior permission procedure. Maximum call durations (or other limits) are imposed on services where necessary. Live services operating at the £1.00 and £1.50 per minute tariffs have had maximum call durations imposed. Service providers wishing to operate live entertainment services at the lower tariffs are also still required to pay into the Compensation Fund. The Committee considers these controls are currently adequate to deal with the problems of unauthorised use in the live services sector.

9.3 The final discussions over the new funding arrangements for the Compensation Scheme are now taking place. The new proposals allow for a bond-type scheme, whereby a maximum call spend imposed by service providers (among other factors) could be taken into account when considering what size bond a service provider has to put up in order to become a fully paid-up member of the scheme.

Live services - conclusion

The Committee considers that the requirement to apply for prior permission to operate live premium rate services allows it to apply appropriate maximum call durations. In addition, the existence of the Compensation Scheme already ensures that claimants can receive redress and these arrangements continue to be adequate. There is no current need to impose an overall maximum call limit in respect of live services. However, the Committee will continue to monitor changes in the live services market.
PART FOUR - OVERALL CONCLUSION

Preventing problems

The proposals outlined above will bring the live and virtual chat sectors much closer into line in respect of the prevention and reduction of the likelihood of consumers encountering problems with these services. The requirements regarding the use of these services by under-18s and the training of monitors and operators will be almost identical for both virtual chat and live services.

Unauthorised use and redress

The arrangements for redress in the two sectors will remain different, but the overall effect for consumers should be similar. Consumers should have access to redress, regardless of which type of chat services they have encountered problems with. The Compensation Scheme will continue in operation for live services. Virtual chat services will be affected by the proposals set out above which should give consumers access to redress. However, the Committee is fully aware that the popularity of virtual chat services is increasing. ICSTIS will continue to monitor the development of this market very closely. At the end of a six month period the Committee will return to this area to assess both the effectiveness of its own new measures and the attitude of the industry in dealing with problems in respect of unauthorised use and high bills.














APPENDIX 1 - SUMMARY LIST OF CONCLUSIONS

Virtual chat definition

4.3.1 Virtual chat services are services in which callers send and receive separate recorded messages. There is no element of simultaneous conversation during which callers can be in direct contact with each other or can instantly hear or respond to each other - such services are classed as live conversation services and are subject to the provisions of the Live Conversation Services Code of Practice.

4.3.2 Virtual chat services which are promoted as contact and dating services or which allow contact details to be exchanged between participants are also subject to the dating provisions where it is reasonable and applicable.

Call cost warnings

The Committee proposes to introduce the following requirement into the Code of Practice:

4.3.6 All virtual chat services must, as soon as is reasonably possible after the caller has spent £10.00, and after each £10.00 of call spend thereafter, do the following:

a inform the caller of the price per minute of the call and the number of minutes which have elapsed or the total cost of the call so far,

b require callers to provide a positive response to confirm that they wish to continue the call. If no such confirmation is given, the service must be terminated.

The Committee is aware of some of the technical and practical difficulties surrounding such a requirement, given the variety of services operating, and would welcome comments on how this can be best implemented.

Maximum call cost

No overall maximum call spend will be required at present. The ICSTIS Secretariat will continue to monitor the number of claims for unauthorised use and high bills it receives in respect of virtual chat services.


Disputed bills

ICSTIS will work with the industry to produce good practice guidelines on the handling of disputed bills and complaints about virtual chat services. In addition, the following amendments to the Code are proposed:

Service providers must:

4.3.4 a have in place and implement in appropriate circumstances a reasonable complaints handling procedure,

b pay reasonable and valid claims for compensation.

5.7.2 ICSTIS has a range of sanctions which it will apply according to the degree of seriousness with which it regards the breach. Having taken all relevant circumstances into account, ICSTIS may:

5.7.2 h require, in the case of virtual chat services (see section 4.3), that service providers pay appropriate compensation to consumers.

Under-18 access

A new Code of Practice provision will be introduced as follows:

  1. Service providers must:

c use all reasonable endeavours to ensure that nobody under the age of 18 uses virtual chat services.

Employees on-line

The Committee considers that callers should know in advance if employees of the service provider might be taking part in conversations, in cases where the services are promoted as dating services as well as virtual chat. This factor is likely to affect the decision to call a particular service., particularly for those seeking to actually meet people. A new Code of Practice provision to reflect this has been drafted:

4.3.5 Promotions for virtual chat services which are promoted as contact and dating services must make it clear that some participants on the service may be employees of the service provider if that is the case.

Delay

ICSTIS will continue to look closely at complaints involving alleged delay. Callers should be allowed to by-pass introductions, except in the case of services that involve dating which should continue to require callers to hear the essential safeguards in this respect. This will not require an ICSTIS Code amendment.

Training

An amendment to the Code of Practice will require that service providers ensure that all monitors involved in virtual chat services should be given adequate training on the requirements of the Code:

4.3.3 At the time of entering into employment, service provider employees who are either monitoring or taking part in the service must be given a copy of this Code. After adequate training (which should be for a minimum of four hours), the operator or monitor must sign a document to confirm that s/he has read this Code and has had its contents and significance explained and that s/he will comply with its provisions. On-the-job training should also be given. A copy of this signed document must be retained by the service provider and should be produced on request from ICSTIS. No operator or monitor shall be under the age of 18 and ICSTIS will retain the right to impose a condition that operators should be of a higher age.

Live services

The Committee considers that the requirement to apply for prior permission to operate live premium rate services allows it to apply appropriate maximum call durations. In addition, the existence of the Compensation Scheme already ensures that claimants can receive redress and these arrangements continue to be adequate. There is no current need to impose an overall maximum call limit in respect of live services. However, the Committee will continue to monitor changes in the live services market.








APPENDIX II- LIST OF RESPONDENTS TO THE CONSULTATION DOCUMENT

Office of Fair Trading

Consumers' Association

Mr R L Trillo

Christian Action, Research & Education

The Newspaper Society

Broadcast Advertising Clearance Centre

Independent Television Commission

Advertising Standards Authority

Radio Advertising Clearance Centre

The Newspapers Publishers Association Ltd

BT

Cable and Wireless (formerly Mercury Communications)

Energis

NORWEB Communications

General Cable

Scottish Telecom

Cable Communications Association

Dostana Telecommunications (on behalf of various service providers)

Firstsound

Interactive Telecommunications Ltd

Tele-Dater

Victoria Telecom Limited

Cablecom Productions

Audiotex Solutions

Sound Advertising

IMS

Linkscom Ltd

Ferda Ltd (on behalf of various live service providers)