Submission to OfCom on the subject of the Management and Operation of the Payforit Scheme rules.

Introduction

In July 2011 OfCom issued a “Review of Premium Rate Services- An application of the analytical framework” and the Mobile Broadband Group led by Hamish MacLeod facilitated the MCP response to the review.
Following a meeting at OfCom offices on the 2nd November 2011 it was agreed by the MCP attendees to supply OfCom with a document outlining the current management and operation of the Payforit Scheme rules particular to each MCP.
This document is submitted by Vodafone UK to OfCom and should be viewed in conjunction with submissions from the other UK MCPs in support of the principal that the UK MCPs continue to self-regulate the Trusted Mobile Payment Framework and associated Scheme Rules known as ‘Payforit’.
Vodafone Background:
It is important that key elements of the context in which Payforit sits within Vodafone UK is outlined before detailing specific initiatives relating to its management.
1. Customer Focus: Vodafone UK holds to business principles that includes a requirement for each and every employee to place Vodafone UK’s customers’ satisfaction central to each proposition delivered and in support of this and requires aggregator partners to sign contracts that look to protect Vodafone UK’s customers’ best interests in terms of clear and fair pricing and simple methods of redress should the situation arise.
2. Partner Rationalisation: To ensure Vodafone UK only works with trustworthy partners, over the last two years it has been reducing the number of aggregator partners who are allowed to directly connect to the Vodafone UK network to provide content using MPay (Payforit), SMS,MMS or Voice/video services to Vodafone UK’s end customers.
The effect of this rationalisation is that those that remain are highly professional and diligent and effectively manage the risk that some of their end customers may pose to Vodafone UK’s customers
3. Proactive Partner Management: In September 2011 Vodafone UK launched an aggregator partner program. This looks to refine this attitude still further, a number of categories were defined and these are broadly based on products that they have with Vodafone UK, the volume of business transacted and Vodafone UK’s view of the way aggregator partners do business with it.
It is fully Vodafone UK’s intention to have Aggregator Partners categorised based on performance which will act as an incentive for aggregator partners to behave in a trustworthy and customer centric way.

Management and Operation of the Payforit Scheme rules within Vodafone UK.
Payforit Scheme Rules Summary:

• The Payforit Scheme Rules are designed to protect the Consumer and ensure the Merchants and their Payment Intermediaries deliver a great user experience to ensure satisfied customers return to the service.
• The Scheme Rules exist in parallel and are distinct from the other PRS services regulated by the PhonePay Plus 12th Code of Practice (CoP).
• In fast paced environment in which the aggregators and MCPs function, Payforit has adapted and will continue to adapt at a speed unlikely to be achieved by any formal regulation.
Vodafone UK initiatives and Processes to manage Payforit internally:

1. Contracts with Accredited Payment Intermediaries (APIs/Aggregators)

Each Aggregator Partner has signed contracts that stipulate compliance with English Law, Payforit Scheme rules, Vodafone PRS CoP, Vodafone 3rd Party Content Standards and other relevant Advertising CoP and PRS CoP.

2. Vodafone UK monitoring programme

• Vodafone UK’s Fraud, Risk & Security (FRS) teams actively monitor data/voice traffic to identify fraudulent patterns of activity. Product Managers (PM) are required to escalate, block traffic and/or withhold revenues to aggregator partners when requested.
• The Red/Yellow card alerts issued by MCPs are monitored and Vodafone UK would insist that the agreed alteration is carried through for use on the Vodafone network
• Close, effective working relationships with Phonepay Plus established and maintained in other areas of PRS enforcement are considered useful for intelligence on general fraud issues in the industry
• Vodafone UK conducts independent security access audits to ensure secure protocols are used by aggregator partners to access its Age Verification (AV) systems. AV is based on a contractual undertaking between Vodafone UK and the end customer. Customer Services log complaints and approach product managers to resolve issues as required.
• Product Managers conduct audits of aggregator partners and their adherence to Payforit Scheme Rules. Each aggregator partner is subject to spot audits and requests for information to support any investigation.

3. Vodafone UK enforcement process.

• Financial claw-backs. A system of claw-backs exists whereby credits, disputed revenues and costs incurred to Vodafone UK are removed from Out Payments in line with contractual terms.
• Red & Yellow Card System. Vodafone UK has signed up to the Red and Yellow Card scheme and takes the protection of our customers seriously. If Vodafone UK has issued a Red/Yellow card then the aggregator partner is obliged to rectify as specified All Red card issued are to be complied with by the aggregator partners Vodafone UK contracts with. In summary this means; Red card, comply immediately and/or remove the service from network immediately; the yellow card stipulates fix and/or respond within two days. Failure to remedy leads to a Red card. Vodafone UK has not issued any Red and Yellow cards in the last 12 months for 2 principle reasons;
i. Issues that are common to all MCPs tend to be reported quickly via the automated system that O2 has installed.
ii. As the number of Aggregator Partners has been drastically reduced and the BDM management ensures the dialogue between Vodafone UK and its Aggregator Partners manages conflict effectively.
• Aggregator partners that materially fail to comply with their Vodafone UK contract will be terminated and as Information Providers look for the ‘one-stop shop’ loss of access to a single network ensures ever increasing management of risk by Aggregator Partners. [Note: We are unlikely to terminate for minor breaches of contract]

4. Vodafone UK customer resolution process

1. Customer contact to query an item on the bill
2. Agent records the contact and description of enquiry
3. Using their training and a support script the agent identifies the shortcode and provides the merchant’s name and contact number and advises the customer in the first instance to approach the merchant for an explanation and/or refund.
4. If the customer returns to Vodafone UK dissatisfied with the outcome then the Vodafone customer services agent will take responsibility for remedying the situation and crediting the customer directly.
5. The customer care team keep a central log of complaints and issues to help resolve customer experience. If a merchant is flagged as a recurring problem then the product manager is informed and asked to investigate the cause of the customer dissatisfaction.
6. Credit is moved to the Out Payments team who clawback the credits and costs pertaining to the customer.

When the customer does not receive satisfaction, a Case History:

This was brought forward by PP+ on 10th November 2011 to ask what had been done to support this customer)
Mrs GM, 07786 xxx xxx
PP+ quote: “Samsung Galaxy receiving charges for KKO Mobile”. “I’ve had no texts, no nothing, I’ve been charged since May. any apps I get are free, I haven’t clicked on any adverts. I only found out after I checked my banking and noticed that my bill was £70 this month.”

Vodafone UK Outcome.

The customer was directly credited £210 by Vodafone UK on the 31.10.11 when the ‘due process’ had been followed to determine the validity of the claim. The customer logs show that she signed up online for a service on 31/03/11 and has had regular charges of £18 a month £4.50×4.
This case was resolved in a single day by the Vodafone UK Customer Care team in the normal process (with no prompting from external parties) and the customer was satisfied with the prompt resolution that Vodafone UK delivered for her.
This case was not escalated to the product manager as the issue was not deemed to contain fraud and would have been included in the weekly credit report.
Conclusion:
Vodafone UK believes it has the processes in place to fully support customers and the desire to see this sector of the market grow and it believes this can be done with the current self-regulatory frame work in place