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Background

In 2018 the Commerce Commission was given powers to improve consumer outcomes in retail telecommunications markets. These powers can be used to improve telecommunications “retail service quality” (RSQ), which includes things like customer services, billing, and the performance, speed and availability of telecommunications services.

Our Improving Retail Service Quality – draft baseline report sets out:
  • why we were given powers to improve RSQ
  • the RSQ powers we have under the Telecommunications Act 2001 (Act), and
  • our baseline evidence for the key RSQ matters that we consider need improving.

About this feedback form

This feedback form is designed to make it easier for individual consumers to give their views on consultation questions asked in our Improving Retail Service Quality – draft baseline report.

Key information from the report needed to respond to the questions is summarised ahead of each question. Chapter references to the report are included for ease of reference.

The questions we would like feedback on are:

  1. Do you agree the proposed key RSQ matters need improving? Please tell us why, or why not.
  2. Do you agree that debt and affordability practices fall within the scope of RSQ? Please tell us why, or why not.
  3. Do you agree that we should only maintain a watching brief over the matters in paragraph 53 of the report? Please tell us why, or why not.
  4. Of the proposed key RSQ matters, which ones do you think we should address first? Please tell us why.
  5. Do you think an industry or Commission RSQ code would improve the proposed RSQ matters? Please tell us why, or why not.
Please complete this feedback form by 5pm, Friday 15 October 2021.

If you represent a telecommunications industry stakeholder, or a consumer group, please upload your feedback using our submission portal.
Question 1

We consider the proposed key RSQ matters, set out in the table below, need improving and could be addressed by our RSQ code powers under the Act.

Chapter five of our Improving Retail Service Quality – draft baseline report details the evidence we have collected about each RSQ matter.

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* Do you agree the proposed key retail service quality (RSQ) matters need improving?

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* Please tell us why, or why not.

Question 2

Debt and affordability practices are not expressly included in the listed examples of RSQ matters in section 5 (s 5) of the Telecommunications Act. However, this list is not intended to be exhaustive and, in our view, these matters directly relate to the way an RSP treats and deals with its customer over the course of a service contract, such that they could reasonably be regarded as falling within the scope of RSQ under s 5. These matters are similar to, and could be considered an aspect of, customer service, contract issues and billing that are listed examples of RSQ matters in s 5.

Chapters 3 and 5 of our Improving Retail Service Quality – draft baseline report detail RSQ scope and the evidence we have collected about debt and affordability practices.

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* Do you agree that debt and affordability practices fall within the scope of RSQ?

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* Please tell us why, or why not.

Question 3.

Paragraph 53 in Chapter 4 of our Improving Retail Service Quality – draft baseline report states after assessing the data, it is not clear that we have sufficient evidence to suggest that the following are RSQ matters that need improving at this time:
  • Exaggerated benefits e.g., not mentioning a large early termination fees accompanying sign-up bonus offers​.
  • No contract notifications when introductory offers expire, or the end of a contract is reached.
  • Telecommunications retail service providers (RSPs) not returning built up credit when a customer switches.
  • Existing customers are excluded from new offers - 'loyalty penalty'.
  • Additional fees​ - paper bills, post-shop, credit card.[1]
  • Late payments fees are rarely proportional to the size of the overdue amount.
  • RSPs require warranties and bonds before sending handsets off for repairs.
  • Overall satisfaction is low.
We therefore propose to maintain a watching brief on these matters at this time.

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* Do you agree that we should only maintain a watching brief over the matters above?

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* Please tell us why, or why not.

Question 4

We consider the proposed key RSQ matters, set out in the table below, need improving and could be addressed by our RSQ code powers under the Act.

Chapter five of our Improving Retail Service Quality – draft baseline report details the evidence we have collected about each RSQ matter.

Of the proposed key RSQ matters, which ones do you think we should address first? Please choose one from each RSQ category?

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* Billing - RSQ matters (please pick one)

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* Customer service - RSQ matters (please choose one)

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* Product disclosure - RSQ matters (please choose one)

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* The switching process - RSQ matters (please choose one)

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* Contract issues - RSQ matters (please choose one)

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* Debt practices and affordability - RSQ matters (please choose one)

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* What RSQ category we should look to improve first (please choose one)?

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* Please tell us why.

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* Confidentiality

We may publish a summary of all views received on our website (without any personal information or details). If you would prefer your views to be excluded from this summary, then please choose confidential

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* Are you happy for us to contact you about your feedback?

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* Would you like to receive updates about this work?

The Commission collects, holds and uses your personal information in line with the Privacy Act 2020. If you wish to access or correct your personal information, please contact oia@comcom.govt.nz.

Thank you

Thank you for taking the time to give your feedback.

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