The results of the CCTS’ public awareness survey have now been published.

To more fully understand the results, we have prepared this document to provide some helpful context.

Highlights

• 20% of all respondents are aware of the CCTS
• 27% of those who have had an unresolved complaint are aware of the CCTS
• 49% of Canadians believe that a consumer has recourse in the event of an unresolved telecom complaint
• consistent with the CCTS’ internal surveys, few respondents report learning about the CCTS from their telecom provider
• primary sources of information about the CCTS are media reports, online activities and word of mouth

Public Awareness of the Ombudsman

A 2011 study by three UK law professors entitled The Ombudsman Enterprise and Administrative Justice notes that the “general public’s awareness of the work of the Ombudsman is a perennial concern for most offices around the world [and that] the few awareness surveys that have been commissioned suggest that the Ombudsman institution is not well known by the general public.”^[1]

According to the most recent data provided by the UK’s communications regulator (Ofcom), consumer awareness of the UK’s telecommunications Ombudsman offices was just 8%. This figure rose to 15% among those who had previously complained to a telecommunications company.^[2]

Ombudsman awareness levels in Canada are also traditionally low. In January 2016, Sarah Bradley, the new head of the Ombudsman for Banking Services and Investments (OBSI, Canada’s primary financial services Ombudsman office) stated that “One of the biggest challenges that OBSI faces is public awareness.”^[3] Her predecessor, in a 2012 paper, commented that it is “difficult to make FDR (financial dispute resolution) well-known,” pointing out the low unaided public awareness (<2%) and that awareness is in fact “very reliant upon firm disclosure and referrals backed by rules.”^[4]

The exception to low Ombudsman awareness appears to be Australia’s Telecommunications Industry Ombudsman (TIO). Survey data shows that awareness of TIO reached an all-time high in 2012, with total awareness levels reaching 57%. The key distinction between the Australian and Canadian environments is that Australia has an elaborate Ombudsman system for a variety of industries, and Australians have a long history of turning to Ombudsman offices for redress. This history is absent in Canada.

On June 6, 2016, OBSI released the results of its recent independent evaluation, conducted by the former New Zealand Banking Ombudsman. The author considered OBSI’s public awareness activities and wrote, “We agree that awareness for the sake of it should not be the focus; besides, it is typically ineffective.”^[5] This is consistent with the CCTS’ approach to awareness, which is to focus on making information available and easy for consumers to find when they encounter a problem and actually need the Ombudsman’s help. We do this by making ourselves easily accessible to consumers through multiple channels, by focusing on providing relevant information at key points of referral, and by requiring service providers to make information about the CCTS available at defined times and at defined points in their internal complaints-handling process.

The author of the OBSI review continues: “Rather, we consider the focus should be on prevention: sharing the insights and lessons learnt from disputes resolved to help all stakeholders avoid mistakes, reduce complaints and know what to do. Telling the human stories – the cautionary tales, the success stories, and providing useful guidance is what firms and their customers typically value.”^[6] These are the very activities in which the CCTS has been engaged successfully for many years.

Summary

The results of our public awareness survey are consistent with the results of many other surveys reported by other similar Ombudsman organizations; in fact, overall awareness of the CCTS is higher than reported in some of those surveys.

There is no consensus, either in the Ombudsman community or among academics, as to the appropriate level of public awareness. The CCTS knows of no other similar organization that has a definitive awareness target.

The CCTS is mindful of the need to ensure that service providers are meeting their public awareness commitments, and, consistent with the CRTC’s direction in Broadcasting and Telecom Regulatory Policy CRTC 2016-102 – Review of the structure and mandate of the Commissioner for Complaints for Telecommunications Services Inc., will be increasing its activities to monitor compliance.

While there is no definitive benchmark to measure the optimum level of awareness for an organization like the CCTS, future polling and surveys will provide some indication of whether awareness is increasing over time and which initiatives are contributing most to this increase.

The results of the CCTS’ public awareness survey are available at: Environics – CCTS Awareness Survey

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[1] Trevor Buck, Richard Kirkham and Brian Thompson, The Ombudsman Enterprise and Administrative Justice, Ashgate, 2011, p. 94.

[2] Cosmo Graham, “Complaints handling and telecommunications in the United Kingdom and Australia,” conference paper presented at the National Conference organised in Melbourne by the Australian Communications Consumer Action Network (ACCAN), 28 June 2010, pp. 8-9. See also Ofcom, “A Review of Consumer Complaints Procedures,” 2009, fig. 6, p. 23.

[3] https://blog.getsmarteraboutmoney.ca/meet-sarah-bradley-ombudsman-for-banking-services-and-investments#sthash.nL22vVPK.dpuf

[4] Douglas Melville, “The Role of Financial Dispute Resolution Schemes in Enhancing Consumer Trust and Confidence. Perspective of Canada’s Ombudsman for Banking Services and Investments (OBSI),” HKMA-SFC-OECD Asian Seminar, Hong Kong, December 13th and 14th, 2012, p. 7.

[5] https://www.obsi.ca/en/news-and-publications/resources/PresentationsandSubmissions/2016-Independent-Evaluation-Investment-Mandate.pdf, p.56

[6] Ibid.