ACCAN Customer Service Project (25 August 2009)

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6. Recommendations

The project brief asks the researchers to deliver an opinion on the potential role of service charters, based on the findings of this research project.

The clear conclusion from this research is that customer service charters are not an appropriate regulatory option for the communications sector in Australia at this time.

The key reasons for this conclusion are:

• Customer service charters compare unfavourably with other regulatory tools, in particular mandatory codes of conduct (for more detail, please refer to Section 2.2). Although codes of conduct have not been working effectively in the Australian communications sector in recent years, there are significant initiatives under way to improve the code development and approval process, and to invigorate code monitoring and enforcement. Those initiatives would appear to offer significantly more promise than diverting efforts to the development of service charters.
• Voluntary stand alone service charters (one per organisation, with no template or guideline) have not proved useful to Australian consumers in the communications sector to date. EDR schemes do not appear to receive complaints based on charter breaches, the presence of a charter does not necessarily indicate good customer service, and there are very few current charters in the sector.
• Industry and consumer interest in charters appears to have peaked in the late 1990s and then waned. The current profile of private sector customer service charters (both in Australia and overseas) is low. It may be difficult to re-invigorate the charter movement – skills and expertise in those areas has moved on to focus on the development of codes of conduct and other regulatory tools.
• The content of customer service charters is inconsistent and very poor from a consumer perspective. It is unlikely that there is anything in a charter that would help to address current consumer issues in the communications sector. A large proportion of consumer complaints (e.g. to the TIO) involve product and service issues that fall outside the content of charters (for more detail, please refer to Section 4.2).
• There is a considerable disconnect between consumer expectations of the content of service charters and business expectations of the content of service charters (as evidenced by examples of private sector charters in Australia). Key consumer issues such as affordability are not even mentioned in service charters.
• For those consumer issues that might be covered by a charter (e.g. timely response to an inquiry) the content of charters is written at such a high-level that they are unlikely to provide any additional consumer rights. Where service charters merely restate existing requirements, their value is limited.
• Service charters do not generally include arrangements for enforcement, sanctions, remedies or compensation. They will have little impact amongst organisations who are currently causing consumer concerns, unless backed up by considerable enforcement powers.

A major issue is that any efforts to ‘beef-up’ or strengthen service charters makes them look like codes of conduct. In Australia consumers and industry appear to be faced with a situation where efforts can be directed towards improving codes of conduct, or looking for alternatives. However, service charters are not an appropriate alternative. If codes were working effectively there would be little consumer interest in service charters in the communications sector.

More work is required to establish a regulatory framework that meets the needs of consumers in the communications sector – this work is beyond the scope of this current report. Further analysis of the a full range of regulatory options would be useful, including:

• Consumer driven charters;
• Laws;
• Regulations;
• Licence requirements;
• Customer Service Guarantees;
• Codes of conduct; and
• Standards.

This report is not recommending any one of these approaches at this stage, it is simply noting that other regulatory options are available that will be more appropriate than customer service charters.

Where some individual communications organisations wish to offer a customer service charter, they should be encouraged to do so. There is some limited evidence that customer service charters can play a role in improving service culture within an organisation. However, service charters should not act as an alternative to other effective regulatory tools.

If organisations are seeking ideas for how service charters can be improved, this study has revealed a number of key lessons:

• Service charters should include basic information on the scope and application of the charter promises, including clear information on the date of application of the charter;
• Service charters are more useful to consumers where they contain a greater level of detail regarding key promises, rather than high-level aspirational promises;
• Service charters could benefit from including more promises relating to disadvantaged consumers, and coverage of issues such as translation services and disability access;
• Service charters stand out when they include promises relating to issues that really matter to consumers, such as competitive pricing, safety, the environment and sector-specific promises on the reliability of services; and
• Service charters have the greatest impact when they include compensation or penalties for breaches of specific provisions.

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