OFCOM drop the ball?

OFCOM have created a new system for migrating broadband lines, harmonising it with phone lines. The system is called Gaining Provider Led (GPL) because you simply order service with a new provider - no need for a Migration Code (MAC).

Dangerous!

Many of us think this is a bad idea. Broadband is not like electricity or gas, where an incorrect migration does not disrupt the actual service, it simply creates billing differences which can always be sorted later. With broadband you could find you inter office leased line that works using Ethernet over FTTC circuits suddenly changes to some generic residential broadband service, taking 10 days to fix, simply because someone put a wrong digit on their order with an ISP and somehow your organisation missed the "Notice" that was sent to the account department in another office. There are real danger of some ADR or suing if this were to happen. There is also the fact that it will now take 10 days, not 5, to migrate services, which seems a backwards step.

Details

However, looking at this in practical terms, as it all kicks off in June, we did consider that it should be relatively easy:-

• Orders to BT are the same, except we don't send a MAC, simple enough
• Notices from BT are the same, as we get them for migrate-out using a MAC, some fields will be a tad different, but we already get these notices, we just need to email the customer
• Cancelling a migrate-out is something we could do already, but don't have to as a MAC is used. We'd have to integrate it a bit more in to our systems and make it easy for customer to cancel.

Of course we expected a few other changes:-

• Update details of how to migrate on web site
• Change order form not to ask for a MAC
• No longer offer people option of getting a MAC

Not so simple!

Unfortunately, now we are working on some of the details, it is far from simple.

For a start, we have a couple of places where we have to send letters which then have a detailed list of things we have to say. Most are simple, but not all. For example, our billing system (priceless) can work out what to charge people for a minimum term when it picks up that a line has ceased and raises a bill - easy. However, the broadband management system which deals with these messages (clueless) does not have billing/pricing data, so for it to tell people the exact amount they will pay for the remainder of a minimum term (Early Termination Charge) means it needs to somehow ask the billing system, but not actually raise a bill (not something the billing system usually does). So not as simple as it sounds, so that will be fun.

Also, these letters need to go by post unless the customer has agreed we contact by email. Well, all of our customers have agreed this. It is in our terms and very clear, and we email invoices and DD notices and so on. But OFCOM are saying that being in our terms is not good enough, we have to have explicit consent from the customer for this. Well, that is easy for new orders, but are we going to have to contact all existing customers to get this explicit consent - that will be a pain for us and them. We're asking OFCOM to confirm.

We also can't talk to the customer to even ask why they are leaving as that could be seen as a reactive save (retentions call).

Anyway, obviously. we are working hard to ensure we follow all these crazy rules to the letter by the time the new process starts in a few months...

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But what of OFCOM dropping the ball?

Well, this is where it gets interesting, and we hopefully get reaction from BT and OFCOM today on this. These rules are imposed by OFCOM General Conditions. GC22 covers the migration. 22.30(s) defines "End-User" such that it excludes large businesses (those with more than 10 people doing work for them). 22.30(n) defines "Customer" as an "End-User", so that excludes large businesses. 22.30(j) defines "Communications Provider Migration" as an "End-User" or "Customer" changing provider, so that excludes large businesses. Even 22.30(gg) defining "Migration" as a word, excludes large businesses by use of "End-User" or "Customer". Pretty much all of GC22 uses these terms which exclude large businesses. Even 22.25 which is a catch all for cases not using BT, etc, and basically says ISPs have to work together to facilitate a migration fairly/quickly uses the "Migrate" definition which excludes large businesses.

The whole of the migration process does not apply to large businesses!

This is new. This is different. This is a surprise. I am happy that such a dangerous system does not apply to large businesses, but there is no alternative. The old MAC based system is stopping, so that does not apply either.

Large businesses may simply not be able to migrate phone line or broadband services now. Obviously there will be cases where providers co-operate and do this, using the underlying BT/carrier mechanisms, the same as small businesses, but they don't have to. If a large business asks us to take over a line, the losing provider could just cancel the migration as it is not covered by the migration process at all.

Obviously if I have missed a step here I hope someone will tell me, but I can't see it.

Is this what you meant OFCOM? If not, please let us know when you consult on a new version of GC22 to fix this as we'll be happy to comment.

I'll update if I get responses from BT and OFCOM on this.

Update: No word from OFCOM yet. BT have a relatively easy job of the various messages and process changes, but are not sure of the "point of no return" and cancellations at the last minute. They also get the impression that OFCOM are being a tad wooly on several points. They were interested in the large businesses issue and they too have asked OFCOM for comment.

Update: OFCOM have apparently confirmed to BT that the new migration process does nt cover larger businesses.