Developing Public Awareness of CCTS – Updated

In July 2009 the CCTS Board of Directors approved the first “public awareness” plan, known as “Developing Public Awareness of CCTS”. The plan included a suite of activities to which the participating telecommunications service providers committed themselves, all designed to ensure that customers were made aware of CCTS and the independent dispute resolution service that we offer.

The Board has reviewed these commitments in light of CCTS’ experience and the feedback that we have received from customers and service providers. The Board has now approved a series of amendments to the measures to be taken by the participating service providers, intended to enhance their effectiveness:

  1. The service providers will notify customers about CCTS on their web sites and in the “white pages” using prescribed text. The prescribed text has been made more clear and concise;
  2. The service providers are required to place on their web sites a notice about CCTS and a link to the CCTS web site. The plan has been amended to provide more direction to the service providers regarding placement on their site, with the intention of making the relevant page easier for consumers to find. It is also intended to ensure that CCTS is properly described as an independent organization and not part of the provider’s internal complaint-handling process;
  3. Service providers were previously required to place notices about CCTS on customers’ bills twice per year. They are now required to do so four times per year. In addition, they will now also provide notice to customers who do not receive bills, such as pre-paid wireless customers;
  4. Under the original plan, a service provider that could not resolve a customer’s complaint was required to notify the customer about the right of recourse to CCTS following the completion of its internal complaint-handling process. This notification requirement has been changed and the notice must now be given following the second level of escalation in the company’s complaints process; and
  5. Service providers may choose to amend their Terms of Service to include reference to CCTS as an available dispute resolution mechanism.

The full text of the amended Plan is set out below.

  1. White Pages Message and Text

Those service providers that publish “white pages” directories will, in future editions of those directories, insert a reference to CCTS.

  1. The size and specific placement of this reference will be left to the discretion of the provider, but the participating service providers agree that the notice will be reasonably prominent relative to other notices of a similar nature and placed in a logical manner in a location where a customer with a potential complaint is likely to find it. Generally, the logical placement would be in the section of the introductory pages of the white pages addressing comments, concerns and complaints. By way of example, the notice will be similar in prominence to the references on page 10 of the local Ottawa directory to the Bell Executive Office of Customer Relations and the CRTC (see attached).
  2. The text of the notice will be as follows:
    Commissioner for Complaints for Telecommunications Services (CCTS) CCTS is an independent agency whose mandate is to resolve complaints of individual and small business customers about their telecommunications services. If you have a complaint about your telephone, wireless, or Internet service, you must first try to resolve it directly with your service provider. If you have done so and have been unable to reach a satisfactory resolution, CCTS may be able to help you, free of charge.

    To learn more about CCTS, you may visit its website at www.ccts-cprst.ca or call toll-free at 1-888-221-1687[1].

 

  1. CCTS Notice and Web Site Link on Participating Service Provider Web Sites

The participating service providers will provide information to their customers about CCTS on their web sites, and will provide a link from their sites to the CCTS web site.

They commit to making this information easy to find, of reasonable size, and readily accessible to any site visitor. To provide the greatest possible consistency for customers, the participating service providers will provide this information as follows:

  1. The information and link will be located on a section of their site to which customers are most likely to turn in the event of a complaint, e.g. “Contact Us”, “Customer Service”, “Customer Care”, “Make a Complaint”, “Compliments and Complaints”, or “Legal”.
  2. Those providers whose sites have a “Search” function will ensure that any search that includes any of the following key words will return a link to the page containing the CCTS information and link: “complaint”, “dispute”, “agency”, “CRTC”, “CCTS”, commission”, “ombudsman”.
  3. The information to be provided about CCTS will include, at a minimum, the same text as the white pages directory notice.
  4. The CCTS information may be integrated into the discussion of the service provider’s internal complaint-handling process, but in any event will be placed in such a manner that it is clear to customers that CCTS is independent of the industry and is not part of the service provider’s internal complaint-handling process.

The participating service providers will each provide CCTS with the URL for this page of their web site within 45 calendar days of the approval of this Plan by the CCTS Board of Directors.

  1. Customer Bill Messages

The participating service providers will provide a message referencing CCTS on customer bills (whether paper or electronic), or optionally by way of a bill insert:

  1. The message will appear at least four times per year, ideally on a quarterly basis. The service providers will make their best efforts to provide CCTS with their bill message or notice schedule, and any subsequent changes to that schedule, in order to permit CCTS to appropriately allocate its Contact Centre resources for periods of anticipated high call volumes.
  2. Over time, as service providers modify their billing systems, they should include a permanent and prominent location for a standard bill message notification about CCTS.
  3. The location of the CCTS notice on customer bills will be left to the discretion of the service provider, as long as the notice is reasonably prominent relative to other notices of a similar nature.
  4. The billing notice will read as follows: Do you have a complaint regarding your telecommunications service that we haven’t been able to resolve? The Commissioner for Complaints for Telecommunications Services (CCTS) may be able to assist you: www.ccts-cprst.ca or 1-888-221-1687.
  5. An optional third sentence for the notice will be available for use at the service providers’ discretion. This third sentence would indicate that CCTS does not address complaints relating to broadcasting services or regulated telecommunications services.
  6. Participating service providers will deliver a similar message to their customers that do not receive bills, such as pre-paid wireless customers. In the case of pre-paid wireless customers, the service provider will also deliver a message to active customers at least four times per year, to inform those customers about CCTS[2]. The message may take the form of a text message to the customer; it may be provided by way of the portal used by customers to purchase pre-paid time; or it may be provided in such other manner as will come to the attention of these customers. In the event that a service provider chooses to use the text message option, any such SMS message sent to customers will clearly indicate that it is a text message from the provider, and that it is free of charge to the customer.

The suggested wording of this message is:

“Free message from [name of provider]. Unresolved complaint about your telecom services? CCTS may be able to help. 1-888-221-1687 or www.ccts-cprst.ca.”

 

  1. Customer Notification by Service Providers

In dealing with customers who have come to the service provider with a customer service issue or complaint, the participating service providers will ensure that their staffs inform the customer of the recourse offered by CCTS in the event of an unresolved complaint.

The service providers have different internal complaint-handling processes. Some of these processes have multiple stages and are resourced with increasingly senior and experienced staff. The objective is for participating service providers to notify customers who have unresolved complaints of their right of recourse to CCTS at a stage that is not too early in the internal process (thus preventing premature escalations to CCTS) but not so late in the internal process that customers abandon their complaints prior to receiving notice of their recourse to CCTS.

No matter how any individual service provider designs and resources its internal process, the participating service providers will inform customers of their right of recourse to CCTS immediately upon a failure to resolve a complaint at the second level of escalation[3], and again at subsequent levels of escalation within the participating service provider’s internal process.

Front line representatives will not be required to make a customer aware of CCTS, in order to facilitate resolution of the dispute directly between the service provider and the customer, and in order to prevent the premature referral of complaints to CCTS. Front-line representatives will notify customers of their right of recourse to CCTS if the participating service provider does not have an internal escalation process.

Participating service providers will have until August 1, 2012 to implement this change.

  1. Amending the Terms of Service

The respective rights and responsibilities of customers and their service providers are generally set out in the service provider’s Terms of Service/Terms of Use/Terms and Conditions (“the Terms”). Many of these documents discuss dispute resolution but do not reference CCTS. CCTS therefore suggests to the participating service providers that they may wish to insert a reference in their Terms regarding the availability of CCTS for the resolution of disputes between customer and service provider.

Approved by the CCTS Board of Directors – April 2012


[1] All of the “notification” texts will be made available to the participating service providers in both English and French. The providers will communicate with their customers in the language with which they normally communicate with the customer.

[2] In order to allow service providers adequate time for implementation of this new measure, for the balance of 2012 a minimum of two messages to customers that do not receive bills will be required, with full compliance effective 2013.

[3] For the purposes of this Plan, “second level of escalation” means that customer notification will be made by the third service provider representative with whom the customer deals in an attempt to resolve their complaint. For service providers with only two complaint-handling levels (i.e. one level of escalation), notification will be made at the second level.