On the 27th August 2021 we submitted to the Commerce Commission in relation to their open letter to stakeholders on the topic of the marketing of alterative services to consumers during copper and/or PSTN withdrawal.
TUANZ has over time received anecdotal evidence that the information being provided to consumers facing the decision to switch services as a result of a switch off of the PSTN or the underlying copper network is confusing at the least and misleading at worst. While we know that the requirement to switch in this situation is valid, in our experience there are also cases where this is being used to market alternative services where neither of the underlying reasons is currently being undertaken.
Furthermore, we have been concerned over the general marketing of alternative access services not only in this specific situation but across the board, especially where the consumers are less technologically aware.
Based on the information provided in the open letter, the report that we commissioned from BIT and our general anecdotal evidence we recommended the following actions:
a. We agree with the Commission issuing the principles and outcomes to the industry as guidelines under section 234 in the expectation that RSPs would incorporate them into an Industry code through the TCF;
b. That any code development be with the involvement of user representatives including TUANZ, and utilise the idea of testing prior to implementation;
c. That this new code cover not only the marketing of alternative services in the situation of copper/PSTN withdrawal but across all marketing of all connectivity options; and
d. That this new code replaces or updates the Product Disclosure Code with requirements to present information about services clearly in simple to understand statements which are easily accessible for all users.