Consumer vulnerability: ACMA sets its expectations for telcos

1. Culture and practices

Outcome: embed a culture that encourages increased focus and support for identifying, interacting with and helping consumers experiencing (or at risk of) vulnerability.

Expectations:

1. Show executive or senior management oversight of development and implementation of better practices;
2. Implement appropriate systems, processes, policies and procedures to identify and support vulnerable customers;
3. run regular and specific training on practices above for staff who interact with vulnerable consumers;
4. encourage staff to advise management of any deficiencies in practices; and
5. make internal policies on vulnerability available on request.

2. Selling and contracting

Outcome: consumers are sold products appropriate to their needs and circumstances.

Expectations:

1. Incentivise staff to make relevant enquiries to help consumers express their needs, for example by discussing affordability;
2. support staff to be proactive in making consumers aware of affordable products and services which meet their needs; and
3. disincentivise staff from inappropriately upselling.

3. Customer service

Outcome: An accessible and inclusive telecommunications market where Telcos understand, identify and assist consumers who may benefit from additional or specialised support.

Expectations:

1. Have inclusive and accessible customer service communications options;
2. Help customers self-identify as vulnerable and use systems to proactively identify customers as vulnerable;
3. Offer support or referrals to support services, for example financial counselling; and
4. Make websites and apps compliant with accessibility guidelines.

4. Financial hardship

Outcome: Telcos are supportive of consumers struggling with their bills so they can maintain access to their services.

Expectations:

1. Help customers self-identify as vulnerable and offer support;
2. Provide access to dedicated, specialised and timely customer service;
3. Select financial hardship arrangement best suited to the individual and authorise staff to tailor arrangements;
4. offer flexible contracts such as moving to cheaper options, or cancellation at minimal/no cost;
5. minimise the use of restrictions that prevent customers accessing their telco services;
6. support staff with training and information on financial hardship arrangements;
7. approve access to financial hardship arrangements, except where there is clear evidence a customer can pay their debt without such arrangements; and
8. monitor repayments and proactively respond to indicators of vulnerability for a customer.

5. Credit/debt management and disconnection

Outcome: Credit and debt management processes are fair, accurate, flexible, and proportionate, with disconnection as a last resort.

Expectations:

1. Approach credit management and debt collection with sensitivity to customer circumstances;
2. suspend credit management action while considering the customers financial situation, and work with customers to find a suitable solution;
3. keep customers connected wherever possible;
4. ensure customers facing disconnection have been offered all reasonable options;
5. ensure vulnerable customers are not prevented from contracting new services after disconnection; and
6. take further steps to make sure health or safety concerns requiring access have been mitigated before disconnection.