GC22 - the new migration rules that replace MAC codes for broadband, simply do not apply to lines for customers with more than 10 people working for them or which are communications providers.
They suggest such migrations are best managed by a cease of old services and re-provide of new services with some overlap (and notable cost).
In some ways this is sensible, in some it is not.
They do not confirm who is responsible for determining that an end user has more than 10 people working for it, and who is liable if a telco acts on statements made by the customer on such things or what happens if number of staff changes over time.
They do not confirm the reason code to give when a losing ISP refuses a migration because its customer is more than 10 staff and hence "GC22 does not apply".
I have to feel that OFCOM have not thought this through.
P.S. - this is not just broadband, but fixed line telephone services as well!
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I presume that as many of your customers declare that they are buying service from you as a "communications provider" they will be protected from aggressive migration attempts.
ReplyDeleteWe need to tidy up the customer status logic - we have a thing on clueless for DEA considerations (which are sort of obsolete now as we are not in that club) and we have questions when setting up a new account for ADR and now GC22 reasons.
DeleteThat does seem a bit off, we have more than 10 people so wouldn't be able to use the migration services should we ever chose to leave (heaven forbid!) though at least we'd be protected against someone trying to take our lines without asking us first!
ReplyDeleteQuite - In practice we want to offer an "anti-slamming" service anyway, and so we can allow people to choose if they want us to reject migrates or not. I think, reading the GCs we can do that, but sadly we cannot make the service "ask first" if we get a migrate - it would have to reject the migrate regardless as we are not permitted to "ask for consent".
DeleteI am wondering if this could work similar to domains where you can have a simple toggle to 'transfer lock' the domain (or in this case xDSL service). Assuming this was a simple lock/unlock option on the control panel ?
DeleteI would need to read it more carefully, but my feeling is that GC22 precludes AAISP from *requiring* the granting of consent.
DeleteGiving a subscriber the option to require contact from AAISP / express consent to AAISP before migration would seem fine, as the subscriber is not required to do so.
Even setting this as the default position, but letting the customer change that default to letting a migration through without contact / consent, would seem within the scope of the wording of GC22, although probably harder to justify in the event of a complaint.
It would seem that with all these crazy new rules it would be useful to A&A to have a simple process to accept new terms of use by a simple email & link click (or reply with "Yes")
DeleteThat way you could send out new terms saying "You agree to have A&A contact you if a migration is attempted"
If it's for fixed lines too now, how the hell are you supposed to migrate a number?
ReplyDeleteI assume "porting" is still different, but don't know, to be honest.
DeleteNumber migration always seemed to be a complete mess with BT anyway. Crazy limitations like a requirement to cease a line when the number is ported away from it - if I want to move my voice number to another telco (possibly a VoIP provider), it seems I end up with my entire POTS line ceasing, VDSL and all rather than them just allocating a new number to it.
DeleteUh-oh - depending on the definition of "working for", my old employer has six directors (the three active directors added their wives, for tax reasons IIRC) and four people who sometimes work in the office (half a day per week in my case, and another is a student on work experience). Add one more person, and suddenly TalkTalk can not only tell us 10% packet loss is the result of using an unlimited service "too much" (40 Gb in a month) but prohibit us from switching away too?!
ReplyDeleteIMO, Ofcom need to rethink this and apply the definition product by product - so an ADSL or FTTC line would qualify (even if it happens to be paid for by BP) and a leased line won't (even if it's someone's personal connection). If I gave you two BT FTTC circuit numbers to transfer to A&A, how would you even know if one isn't portable under GC22? (Not to mention, why would the number of staff really matter anyway, when they are really just Openreach circuits you rent either way?) What would happen if some unscrupulous ISP started bouncing *all* requests as "more than 10 staff, GC22 exempt"?