This has happened a few times and I can see it being an interesting possibility.
Basically, there are occasions when I would like to give someone a really expensive number to call me on. It is not because I want to get revenue from the call, it is because I want them to pay a lot for the call and be inconvenienced.
One such obvious case today was an insurance company that only publish an 09 number to contact them on. So I think only reasonable to expect them to call me on a similarly expensive 09 number.
Customers have asked for such things before. They know the telco (in this case A&A) would get revenue, and are actually quite happy about that happening. They know they would not get revenue, and would not want any of the hassles associated with actually running a premium rate service.
This is where it gets interesting...
The law says OFCOM can regulate premium rate services. However, my reading of the Act is that it is the service that is premium rate not the number. I.e. just because it is a really expensive number on an 09 prefix does not make it premium rate. What makes it premium rate is providing a service via the telecommunications service (for which there is extra charge made and passed on to the service provider).
So, in theory, we could set up 09 numbers, with no pay out and no service provided via them, just as expensive numbers to call. We could run these with none of the normally require warnings or hassle or contibution to PhonePayPlus (or whatever they are called today).
Now, the cost of setting this up would be peanuts, as long as it is not a premium rate service and has none of that hassle. Just another inbound number range to add to the hundreds we run already. We could do it free of change and even direct to a landline or mobile as the means of delivery of the call.
Perhaps I'll write to OFCOM and suggest it and see what they say :-)
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I know you have mentioned this before (well, the definition of service) and I still don't understand your interpretation.
ReplyDeleteSurely you would be offering a service - simply passing calls on to somebody else is a service, no?
If your customer wants an 09 number, what are they getting from you if not a service?
OK, yes. But that is just a telecommunications service. I have to say the wording in the comms act is crap. It defines premium rate services. And defines as a service provided "via" the communications service. That phrase only makes sense if there is a communications service AND some other service provided via it. Just passing on calls is the communications service and there is no other service provided via it.
ReplyDeleteIf just passing on calls met the definition, then *all* normal phone calls would count as premium rate calls under the Act. I can't imagine for one second that was the intention of the Act so I am trying to interpret it as best I can in that context. That said, I am not a lawyer.
Bear in mind, inmarsat calls are like £5/minute, and are "just a communication service" so not subject to any premium rate rules at all. No price warning. Nothing.
What I am pretty sure of is that the comms act does not define premium rate services by number range, and does not define them as "any number range OFCOM designate as such" or something wooly like that. At the end of the day, either the service is premium rate under the act or it is not. If not, then non of OFCOM or PhonePayPlus rules on premium rate services have legal power over it.
ReplyDeleteI suspect that they would argue that a premium rate call is one which could be provided on a different number at a lower cost to the caller but which isn't - therefore calls for which a premium is being charged. Satellite phones can't be routed via a cheaper number...
ReplyDeleteAs far as you are concerned though, surely the communications service is the 'getting the call to A&A' bit. Your call diversion is a service provided via the communications service.
Looking at it another way, if you had a geographic number in and diverted it to a mobile number for a customer, you'd charge the customer for a call diversion service. The only reason you wouldn't charge for diverting the 09xxx call is because of the premium rate which provides you with an outpayment.
That would be a horrible definition, and not the one in the comms act, thankfully. That definition would be fun if you have competition that happens to be cheaper, suddenly all your service would be premium rate.
ReplyDeleteThe definition ICSTIS used to use (and again, not relevant as the comms act is what gives ICSTIS/PhonepayPlus power) was a number where there was an out-payment to the called party. That actually makes some sense, but makes a lot of 0845's premium (which perhaps they should be).
A&A is a telco, so us getting the service to the end point is a telecommunications service end to end. But if that was an issue (and I can see it may make it come under some "personal numbering" definition) then we could just have it deliver to SIP.
Also, as per your last point, if we have a call to an 07 number that we send to a landline, we can do that for free as the revenue on the 07 covers the onward leg. Orange did this for example. But that does not make the 07 a premium rate service. It is simply a matter of what is commercially sensible for the telco.
Of course we could get an 07 block that we fill at say 50p/minute (an expensive mobile number) and do an "instant temporary mobile number" service where you text us and we text back a number which you can then use as your number and we deliver calls and texts to your phone.
Please let me know how you get on if you pursue that. I have noticed that if we want to provide an 0871 number we are required to indicate what the "provided service" is - no facility to say "nope, no service, it's just a number which calls a person/company".
ReplyDeleteYes, we have had that argument already with carriers which is partly why this all came up.
ReplyDelete0871 were not premium rate, and we run a load of fax numbers on them which are just telecommunications services.
The OFCOM changed them to premium rate in their minds with no change to the legislation!
I can see no logical reason why a person or a company should not use a "you pay for the call" service for their main phone number, fax number, what have you. Any more than I see a problem with sending "postage due" items except the PO will no longer do it!! In the case of teh PO, I can see how it's a major extra workload to deal with. In the case of telephone numbers, it isn't.
ReplyDeleteIt should cut down the spam!!
Ah - I was chatting with someone else about this today. My thrust was "when is it not a service". and he said
ReplyDelete"You register as an automated concierge/secretarial service; that way you're not required to know/care a priori what the content is; the only thing you're required to know is who your custies are."
Which could just about do it!! I'll re-read the ppplus small print.
A few years ago we had a 25p/min line for a 'normal' phone line, and ICSTIS didn't need it to be registered. It was only later when we decided to offer a tech service on it that we then had to register. Not sure if the rules have changed since we did it though.
ReplyDeleteI'm told by PhonePayPlus that if you chose to use, say, an 0871 number as your "Main" number, that this is perfectly acceptable under the rules (as they undertand them - my comment) but that you must still register it as a "service".
ReplyDeleteMy point is that if such use is not a premium rate service then the law that give OFCOM powers to make the rules and delegate those to phonepayplus does not apply. So there is no reason to even talk to phonepayplus let alone register. They are not thinking top level here!
ReplyDeleteSorry - I meant, when I added a the comment about their undertanding, was in that direction.
ReplyDeleteOTOH, it looks like you CAN run like that AND inform PPP (even if you don't have to) and still not be told "you can't". IYSWIM.
So how do I go about setting up a premium rate number on the cheap...
ReplyDeleteWe own a locksmith company and want to make a few quid by using a PR number..