THE ICSTIS CODE OF PRACTICE - DRAFT EIGHTH EDITION
Commentary and discussion
Introduction - ICSTIS and the Code of Practice
ICSTIS, the Independent Committee for the Supervision
of Standards of Telephone Information Services, regulates the
content and promotion of premium rate telephone services (PRS).
It is a non-profit making regulatory body funded by the industry.
Set up in 1986, ICSTIS is responsible for setting
and reviewing standards relating to the content and promotion
of premium rate services through its Code of Practice. It investigates
public complaints, monitors services, recommends measures to achieve
compliance with the Code and publishes information relating to
its work. ICSTIS consists of a Committee of ten members which
adjudicates on cases and sets policy for the regulation of premium
rate services. The Committee is supported by a full time Secretariat.
ICSTIS implements two codes of practice. The ICSTIS
Code of Practice sets out the regulations for the advertising
and content of all premium rate services, live and recorded. The
ICSTIS Live Conversation Services Code of Practice, or
'Live Code', sets out additional rules relating solely to
live premium rate services. Committee decisions about complaints
are reported in the ICSTIS Monthly Report.
The Code of Practice is now in its seventh edition.
This was published in May 1995. The fast rate of change in the
industry means that the provisions of the Code need to be kept
The current review of the Code has been carried out
for a number of reasons: there has been a proliferation of new
services operating at different tariffs, a build-up of important
Committee case and policy decisions, and a need to incorporate
the results of a number of different premium rate sector reviews
into the Code. Requests for change and clarification have also
been received from the industry and consumer groups.
How the Code review is being conducted
Work on the Code started with the formation of a
Code Working Party, made up of four Committee members. All recommendations
for changing the Code made since publication of the seventh edition
were considered in detail. These came from the industry, consumer
groups and from the Committee.
Consultative meetings were held with service providers,
network operators and consumer groups to listen to their ideas
and thoughts on the content and presentation of the new Code.
The draft Code was prepared incorporating this work, as well as
the results of reviews into the competition and virtual chat services
The next stage of the review is to obtain comments
from a wide range of sources, including the industry, government,
other regulators and consumer organisations. The consultation
will run until 10 October 1997. The results will then be
collated, discussed by the Committee and incorporated into the
eighth edition of the Code, which will be published in December.
It is intended that the new Code will come into effect in January
1998, giving service providers time to amend any services which
need to be changed to meet the requirements of the new rules.
How to read the draft Code
This draft looks quite different from the last edition.
However, much of the change is a result of redrafting to clarify
the current provisions, rather than substantive change to the
meaning of the Code. This editing aims to enable newcomers to
the industry to easily understand ICSTIS' requirements. Furthermore,
it should also assist current industry members when designing
or operating new services.
One of the main messages that came out of the industry
meetings was that service providers wanted as much guidance as
possible on how to interpret the Code. It was also requested that
the Code be made easier to read with the introduction of page
numbers and an index. (NB An index is not included in the draft
Code but will be when the finalised Code is published in December.)
The Code has been divided into a more logical sequence
than previous editions. The introduction, which outlines
the scope of the Code, is followed by a set of administrative
provisions. These relate to the operation of services as well
as the steps which must be taken prior to setting up a service.
General provisions, applicable to all services, and those
relating specifically to the promotion and content of services
come next, followed by the particular categories of service
which require additional measures. Information on ICSTIS'
procedures and sanctions is given at the end.
In this draft Code, the paragraph number relating
to the equivalent paragraph in the previous (seventh) edition
is given in brackets and underlined after each provision. This
will help readers to see the origin of the new provision. Changes
which affect the meaning of the provision are shown in italics.
Sections which have been removed have been shown struck out. Minor
changes in wording which do not affect meaning but improve clarity
are not indicated.
In the following section of this document, the draft
Code is set out on the left-hand page with a corresponding commentary,
highlighting key points, on the right-hand page. Any additional
policy issues on which the Committee would like comments are also
set out in the commentary alongside the relevant Code provisions.
These have been raised in the form of questions and appear in
Respondents are also encouraged to comment on the
unchanged sections of the Code as well as the overall order and
Commentary to the ICSTIS Code of Practice draft
eighth edition - August 1997
redrafted introduction brings ICSTIS' terms of reference to the
beginning of the Code. It goes on to cover the scope of the Code
and makes reference to all the documents which service providers
should be aware of before operating services, including the Code
of Practice for Live Conversation Services and any relevant guidelines.
Definitions of all the main terms used within the Code are also
definition of a premium rate service has been amended to make
clear that 'pay for product services' are included. Pay for product
services are services which enable the caller to pay for a product
or service via the telephone bill.
There have been some discussions about the introduction
of new tariffs which would enable the growth of these services.
This has prompted discussions with the industry on whether the
Code should contain additional consumer safeguards for these services.
Work in this area is ongoing and will be reported in due course.
contains information about the Code and services that service
providers need to know before setting up a service. This includes
the requirement for service providers to give ICSTIS information
about the numbers a company will be operating and the name of
the person to contact in the event of any problems.
2.2.5 From time to time decisions
about cases setting new precedents, or the need to give service
providers information about procedural matters, has resulted in
the issuing of guidelines. These guidelines are not binding on
the Committee or the industry but are intended to be helpful to
the industry in showing how the Codes might be interpreted in
certain circumstances. 'Live Premium Rate Services Guidelines
for Applicants' is an example of this, as are the new guidelines
on the legality of competition services. However, the Committee
has not fully co-ordinated the publication of these guidelines
before now. Some service providers have requested that these guidelines
are more readily available to avoid the possibility of Code breaches
Two examples of how these guidelines might look are given in Annex A.
A full list of the guidelines, and which versions
are in use, will be made available in each ICSTIS Monthly Report,
on the ICSTIS website and from the Secretariat. As and when new
guidelines are issued, or old ones altered, a notice will appear
in the Monthly Report and on the website. It is hoped that the
industry will find this a useful step forward and comments on
the idea are requested.
all ICSTIS documents, the word 'approval' has been changed to
'permission'. This change has been made to avoid giving the impression
that ICSTIS endorses a particular service.
provision has been expanded to explain that the different categories
of service requiring prior permission will be published as an
ICSTIS Guideline (see Annex A). The provision also makes clear
that additional conditions may be applied when permission is given.
The ICSTIS prior permission service began in 1994
with the introduction of the £1.50 per minute tariff. From
time to time there has been debate about whether a charge should
be made for this service. To date, charges have not been made
for the work involved in granting prior permission, even though
in some instances this has been very time-consuming. The Committee
now requests comments on whether some of the costs of the prior
permission service should be met by service providers, particularly
if the time spent processing an application is above average.
Comments are also requested on how a payment system, if appropriate,
Code Working Party looked in some detail at data protection issues,
particularly with regard to Calling Line Identification (CLI).
However, at present there appears to be no need for a Code change
because developments in this area do not currently appear to impact
on premium rate services. However, further developments will be
requirements regarding replacement of services on the same numbers
(paragraphs 1.3.6 and 1.4.6, seventh edition) have been combined
and put in this section. It states that services should not be
replaced by services which are inappropriate or might give offence
to people expecting the original service. An extreme example of
this might be if a children's service was replaced with a sexual
rate services can be advertised in media other than print publications.
To reflect this, specific guidance is given for certain media.
Premium rate services are now frequently advertised on the Internet
so it has been added to the list of non-print media.
section alerts service providers to the fact that they may have
to abide by other Codes depending on the medium in which they
are promoting their service.
word 'improper' has been changed to 'unfair' because the Committee
felt that this was more appropriate to the intention of the provision.
'Improper' was felt to be too high a test.
3.7.2 This provision of the Code,
which exempts services costing less than 50 pence from giving
pricing information, has worked well since its introduction, giving
service providers more freedom when promoting these low-cost services.
However, since the publication of the seventh edition of the Code,
two types of service have caused problems with pricing awareness
and comments are requested as to whether they should be excepted
from the scope of this paragraph because of the consumer harm
that the omission of pricing information has caused:
1. Practical joke services. These
are recorded services which people are duped into calling. They
are promoted by word of mouth, answerphone, fax machine or leaflet
and invite people to call a telephone number as a matter of urgency.
Callers are then greeted by a voice-activated message which, in
the majority of cases, misleads callers into believing that they
are having a live, conversation, the content of which has, on
occasion, been distressing. These services often last less than
a minute, so no pricing information has to be given in the promotion.
This adds to the deception on which these services rely.
2. Competitions which encourage repeat calling.
An example of this would be a competition in which the thousandth
caller wins. Callers hoping to win sometimes call the number repeatedly,
unaware of the high cumulative costs they are incurring.
3.7.3 The current Code requires promotions in
television programme time to give spoken pricing information.
However, concerns have been raised about the prominence of pricing
information in paid-for advertisements. It is therefore suggested
that all television promotions, both in programme time and in
paid- for advertisements, should give spoken pricing information.
Comments are requested on the feasibility of this
and whether there could be alternative methods of increasing the
prominence of pricing information in paid-for advertisements in
requirement for naming the country of termination for international
been removed. However, a new provision has been added requiring
that a statement appears on the promotional material making it
clear that an international call is involved. The reason for this
is that the names of some of the countries where these numbers
terminate might be unfamiliar to the general public. It was felt
that a general statement indicating that the call is an international
one, would be of more use to the consumer. For the avoidance of
doubt, this does not exempt service providers from the requirement
to give call cost information.
the initial consultation carried out with the industry, service
providers emphasised that they would like to have as much contact
with their callers as possible. This has been reflected in this
provision using the phrase "so that customers can contact
them directly". The provision has also been widened to allow
a helpline number to be given instead of an address.
The Code previously contained an option to allow
PO Boxes to be used. However, experience has shown that this can
be abused and there have been cases where the PO Box has been
false or has proved to be an ineffective way of making direct
contact with services providers. The Committee is proposing to
remove this option but would welcome further comments.
promotions for services are intended to stay in use for long periods.
Over time, the call charges for the number may change from the
one stated in the promotion. In cases where this occurs, service
providers will now be required to put a statement at the beginning
of the service informing callers of the new rate(s). This codifies
paragraph, which was originally put in place to combat a particular
type of competition service which encouraged fraud/unauthorised
use, has been amended so that it does not preclude 'pay for product'
paragraph has been removed because it is felt that this issue
is better dealt with under the delay/misleading provisions (3.10b/3.6.1a).
Committee considered lowering the age limit from 18 to 16. A number
of representations have been made over the life of the current
Code to the effect that it was no longer appropriate to apply
the restrictions of the children's services section to 16 to 18-year-olds
in particular. References have been made to codes and regulation
in other media sectors which fix an age limit at 16.
given careful consideration to the age limit which should be fixed
the Committee takes the view that it should remain at 18 largely
because this is the age limit below which it is not possible to
enter into a telephone service contract.
Committee is mindful of the comments and representations which
have been made and proposes to review and clarify the way in which
it will determine which services fall into the category of children's
services and are, therefore, bound by the provisions of this section
of the Code. In determining which services are "aimed at
or would reasonably be anticipated to be particularly attractive
to persons under 18 years of age", the Committee will take
a number of factors into account.
In the past the Committee has relied heavily on the
readership/viewership figures of the publication/medium in which
a service was promoted to determine whether or not the publication,
and therefore the service, was aimed at children. Paragraphs 4.1.1c
and d have now been removed and the Committee's new approach
extends the range of factors beyond this. The Committee proposes
to work to a new set of criteria, which will be published as an
ICSTIS Guideline, as follows:
"The following is a list of the factors which will be taken into account
when the Committee is assessing whether a service is a children's
service for the purposes of paragraph 4.1.1b of the ICSTIS Code:
attractiveness to children,
None of these factors will be taken in isolation.
The Committee is of the view that this approach ensures
appropriate safeguards for the most vulnerable users of premium
rate services while allowing it to take account of a broader range
of relevant factors in determining what should be considered as
a children's service. This will enable a more pragmatic and targeted
application of these important provisions of the Code.
and consultation has been carried out with regard to premium rate
telephone competitions, resulting in two documents: Premium
Rate Telephone Competitions in the UK: An ICSTIS Consultation
Document (June 1996) and a follow-up Statement (December
1996). The main areas of enquiry focused on fair play, the amount
of revenue generated by such competitions and legality. Many detailed
and helpful submissions were received in response to the two documents.
The provisions set out below represent the Committee's final proposals
for regulation in this area.
ICSTIS has looked carefully at the legal status of many premium
rate competitions. The Committee acknowledges that there are substantial
grey areas and that ICSTIS is not the appropriate forum in which
to decide the complex questions of law which could arise in many
cases. However, ICSTIS believes that there are certain competitions
which are without doubt unlawful and which have the potential
to cause serious consumer harm. ICSTIS is of the view that it
should continue with its practice of referring apparently illegal
services to the police. In addition, ICSTIS intends to adopt a
new policy in respect of potentially illegal services, where there
is no doubt as to legality and potential serious harm. No amendments
to the Code will be necessary. This policy will not be implemented
until the new Code of Practice comes into force.
1. In cases in which ICSTIS is given clear, expert
legal advice that a service appears to be plainly illegal and
has the potential for serious harm, it will raise a breach of
the Code with the service provider. If, following receipt of the
service provider's response to the alleged breach of the Code,
ICSTIS receives expert legal advice that there remains no doubt
that the service is illegal, ICSTIS will proceed to adjudicate
in accordance with the Code. ICSTIS will also notify the police
of the service.
2. If there appears to ICSTIS to be a breach which
is serious but in respect of which ICSTIS, on the basis of expert
legal advice, perceives that there is doubt as to whether the
service is in breach of the law or not, ICSTIS will not proceed
under its Code but will continue its practice of referring such
cases to the police.
Many service providers obtain legal advice before
running competitions and, while there are exceptions, make every
effort to avoid operating illegal services. ICSTIS considers that
service providers would benefit from an ICSTIS Guideline, which
would apply in the absence of fraud or other significant abuse:
a) Where the call costs the same as or less than
a first-class stamp, ICSTIS will not intervene, even if the service
might otherwise appear to be a lottery or an unlawful prize competition,
b) Where there is a prominent alternative entry process
(and not one which appears only in small print among 'rules of
entry'), ICSTIS will not involve itself as to whether or not a
two minute limit before competitions have to indicate the likely
playing time or full cost of the call (as well as information
on how the competition operates) has been removed. A 50 pence
limit has been introduced in its place.
The new Code will retain the pricing information
exemption in respect of calls which cost less than 50 pence. ICSTIS'
research showed that the exemption caused few problems in practice
and that its retention was favoured by service providers. (However,
see QUESTION 4 for an exception to this rule - services
which encourage repeat calling.)
If no changes were made to the current Code, three
levels of charge information for competitions would exist. Those
costing less than 50 pence would not have to display pricing information
(although most do in practice). Those costing between 50 pence
and approximately £1.00 (two minutes at the 50 pence per
minute tariff) would have to display only price per minute information.
Those costing above approximately £1.00 would have to display
the likely playing time or full call cost.
The differences in the pricing information requirements
for competition services costing under 50 pence, between 50 pence
and £1.00 and, in principle, over £1.00 are anomalous.
Ensuring that consumers have adequate information about a service
before they make a call is a cornerstone of the Code. With competitions,
consumers want to be able to gauge what their stake is going to
be against the value of the prize.
It is therefore proposed that all competitions which
can cost more than 50 pence display either the full cost of the
service or the price per minute and likely playing time.
This amendment brings this section of the Code into line with
the general Code provisions relating to pricing information (3.7.1).
provision has been amended in line with other provisions in the
Code where callers have to give confirmation that they wish to
continue. In view of this, what was formerly expressed in amounts
of call time is now expressed in terms of call spend.
Committee found little support for banning competitions aimed
at children. However, its concern at the level and types of prize
aimed at children was echoed in the responses to the consultation
document. Competitions aimed at children will therefore be restricted
to offering non-cash prizes with a retail market value of less
than £500.00. Comments are requested on the level of this
chat services, which allow callers to exchange messages, have
been the subject of ICSTIS research and consultation. A consultation
document, Virtual Chat and Live Premium Rate Services,
was published in March 1997 with the consultation period ending
in April. The Committee has carefully studied the responses to
the document and has held further discussions with service providers
over maximum call costs.
The Committee's final proposals for regulation in
this area are contained in a separate document, Virtual Chat
and Live Premium Rate Services - An ICSTIS Statement. This
has been published simultaneously with this draft Code. For the
sake of completeness, the Code amendments which are required to
bring the proposed changes into force have been included in the
draft Code, but all the detailed background discussion to the
changes is contained in the Statement. The consultation period
on the Statement is the same as for the Code. Comments should
be made to the ICSTIS Secretariat by 10 October 1997.
provision defines virtual chat services as opposed to 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 instantaneously.
which allow contact details to be exchanged between participants
must comply with all the rules in the contact and dating section
which are applicable to the particular service.
provision sets out the minimum training so that all employees
of service providers who participate, either as passive monitors
or actively in conversations, are trained in the provisions of
the ICSTIS Code. This mirrors the requirements for operator training
in the ICSTIS Live Code.
4.3.4 ICSTIS has received
complaints from a small number of telephone subscribers who a,b
allege that their phones have been used without their permission
to call virtual chat services. It is important that these consumers
are able to seek compensation. ICSTIS, network operators and service
providers are going to be working together to develop a system
for dealing with these problems. However, it is important that,
in the absence of a formal compensation scheme such as that which
exists for live conversation services, consumers can be assured
that valid claims will be met. In order to ensure a consistent
approach across the industry, ICSTIS is proposing to build on
the good practice that already exists in relation to the handling
of complaints and payment of compensation. Any further recommendations
will be contained in an ICSTIS Guideline.
A new provision in the sanctions section (paragraph
5.7.2h) has been added so that if a breach of 4.3.4a
or b occurs, service providers can be required to pay compensation.
These provisions will only be applied if all other avenues of
dispute resolution have already been exhausted.
is the case with dating services, virtual chat service providers
should use all reasonable endeavours to ensure that no one under
the age of 18 uses virtual chat services. This provision reflects
what is already fairly standard practice in the industry. When
applying this provision, the Committee will be aware of the difficulties
facing operators in identifying minors.
virtual chat service providers employ people to talk on their
services. It was felt by the Committee that services promoted
as dating services should make this clear to avoid potential callers
being misled, should they be seeking to make a date with someone.
was felt that the best way of keeping callers informed of how
much time they are a,b spending on line is to give an indication
of how much time has been spent after every £10.00 of call
spend. Callers will also be requested to give a positive response
to confirm that they want to continue the call. If callers fail
to do this, they will be disconnected.
4.4.2c The requirement to collect
advertisers' names and telephone numbers on dating services was
put in the Code to enable people to be traced or where personal
details have been placed on a service for malicious purposes and
the person behind this needs to be identified. The main problem
with it is that it is hard to be confident that the details given
are correct. Comments are therefore requested on whether or not
this provision should remain in the Code.
paragraph has been altered to require the information about publications
in which advertisements will appear in to be included in the promotion,
rather than 'agreed with the service provider'. This is because
many dating services are now automated. This information should
also be given before a call is made because it might influence
decisions to use the service.
paragraph has been added because there have been a small number
of complaints from callers who have found themselves forced to
leave a voice message on the service when they did not wish to.
If they had been aware of this at the outset, they would not have
called the service.
It is suggested that provisions mirroring those in the virtual
requiring affirmations and cost warnings to be given should be
applied to dating services. Failure to do this could cause confusion
for services which act as both virtual chat and dating services.
provisions have been reworded to clarify their meaning, making
it a requirement to be specific in the promotional material as
to the actual amounts of money being paid to the charity.
paragraph has been amended in line with other paragraphs which
contain call cost warnings. What was formerly stated in terms
of time is therefore now expressed in terms of call spend.
requirement to proof tips to a third party has been removed and
replaced with a clause requiring substantiation of past selections
to be available. This substantiation could take the form of evidence
that tips have been proofed to a reputable, independent third
party. This advice will be incorporated into an ICSTIS Guideline.
The reference to ICSTIS providing a proofing service has also
been removed as this was found to be impractical and, in any case,
there was very little demand for it.
paragraph has been clarified to ensure that service providers
advertising adult services in non-print media do so in areas to
which access is restricted in the same way as top shelf magazines
in print media.
However, no such controls exist to address similar
problems with high bills and unauthorised use which may result
from calls made to recorded services of a sexual nature. In the
wake of the return of adult services to the domestic market, and
in order to address this anomaly, it is recommended that call
cost warnings and affirmations are introduced for recorded services.
Comments are invited on this proposal. An alternative to this
proposal would be to introduce a maximum call spend which may
be considered more appropriate. If so, suggestions for the appropriate
level of such a maximum would also be welcomed.
has been decided to place the requirements which were set out
in this paragraph in the specific sections where they should apply.
This will make it easier for service providers to see what obligations
are being placed upon them.
The sections affected are:
paragraph has been moved from the introduction to the procedures
section because it principally relates to complaints panels. Complaints
panels, which adjudicate on cases, consist of three Committee
one-month time limit for the receipt of complaints has been removed.
This is because complaints may arise some time after the premium
rate call has been made. Sometimes a problem with a premium rate
call may only come to a complainant's attention when the phone
bill is received, which can be up to three months after the call
informal procedure has been in use for some time and should therefore
be set down in the Code. As well as describing the procedure,
the factors which can be taken into account when determining whether
the procedure should be used are also described. It should be
noted that the exact combination of factors which would lead to
the informal procedure being used cannot be stated because each
case is treated on its individual merits.
one of its sanctions, ICSTIS can require network operators to
withhold any outstanding payments from the service provider. However,
it may also do so in the context of the emergency procedure, before
adjudication has been made.
sanction which requires virtual chat service providers to pay
appropriate compensation has been added. This corresponds to paragraphs
4.3.4a and b.
providers are given clear guidance about the procedure for oral
hearings, including the requirement to put reasoned requests for
such hearings in writing.
5.9.3 ICSTIS' policy on the review of sanctions and adjudications has been more clearly laid out.
Because the Code of Practice is unlikely to be the
first port of call for most complainants, the information on how
to complain has been made very much more general, with the emphasis
placed on how ICSTIS can be contacted.
QUESTION 7 - COMPLAINTS AND
Some complaints and comments made to ICSTIS do
not involve a breach of the Code. Many calls to ICSTIS' freephone
number concern technical difficulties, disputed items that appear
on bills, other problems with services or just general comments.
ICSTIS' currently either gives complainants details of the service
provider(s) concerned or passes details of complaints (with the
complainants' permission) to the service provider(s) concerned.
ICSTIS then has no further involvement unless the complainant
is so unhappy with the service provider's response that they come
back to ICSTIS, but this happens infrequently.
Service providers have stated on a number of occasions
that they wish to have closer contact with their customers and
are happy to meet reasonable claims. Service providers clearly
see callers to their services as their customers. They wish to
encourage direct contact in order to quickly identify problems
and try to ensure that callers re-use their services. Many service
providers use customer helplines promoted in advertising or during
services to enable direct customer contact. Again, unless a caller
is very unhappy, they will not make further efforts to pursue
the matter and possibly contact ICSTIS.
Oftel has recently proposed the introduction of
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 carries out this task to
a degree, as it receives many requests for information about services
and service providers, often from callers referred by network
operators. The Oftel proposal is currently being discussed but
whatever form the helpline finally takes, the intention is to
enable greater contact between service providers and their customers.
This draft Code suggests changes which would formalise a system of complaint handling and redress for virtual chat services. These proposals are discussed in detail in the statement on virtual chat and live premium rate services published at the same time as this document. The main proposal is that ICSTIS and representatives of the virtual chat service providers will draw up a good practice guideline on the handling of complaints and payment of redress. Network operators have indicated that they wish to be involved in these discussions insofar as they extend to the treatment of disputed items on telephone bills.
This guideline, which it is suggested operates
in the same way as the other ICSTIS Guidelines proposed in this
draft, could cover such matters as the definition of a complaint,
time limits for dealing with complaints, procedures for dealing
with complaints made via telephone helplines and informing complainants
how they can take matters further, if they are unsatisfied with
a service provider's response. It is ICSTIS' intention that this
work will build on the good practice which already exists in the
The developments outlined above share many common
elements. Industry estimates indicate that virtual chat services
now account (in terms of revenue) for a substantial part of the
premium rate industry. Discussions concerning complaint handling
practice will therefore affect many service providers. ICSTIS
is happy to see the spread of service provider helplines and welcomes
the good practice as regards complaint handling and redress that
already exists in the industry. The introduction of the Oftel
premium rate helpline will increase contact between service providers
and their customers.
ICSTIS would like to build on industry initiatives
and open discussions with the whole premium rate industry with
a view to ensuring that such good practice is applied across it.
In this way consumers can be sure that their complaints and requests
for redress will receive consistent treatment regardless of whom
they contact initially: their telephone company, a service provider,
the premium rate helpline or ICSTIS.
The Committee welcomes comments on the proposal
to develop a good practice guideline on complaint handling and
redress involving representatives from the whole premium rate
industry. What could, or should, be covered by such discussions?
This consultation is intended to be an open, two-way
process. The Committee welcomes comments on any part of this consultation
document or the Code itself. In addition, if consultees have particular
points they wish to raise with the Committee, meetings can be
arranged. Please contact the Secretariat to arrange times and