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									Consumer Focus
Draft Annual Plan
Consultation period

17 December 2010 – 18 March 2011

 Chairs’ foreword                                   3

 Our successes for consumers                        4

 About Consumer Focus                               4

 For consumers of energy                            7

 For consumers of post offices, post and digital
 communications                                    10

 For consumers of financial services               13

 For consumers of public services                  16

 For consumers in unfair markets                   19

 On the international stage                        22

 Reaching out to consumers                         25

 How to respond                                    28

 Draft Annual Plan 2011/12 for consultation         2
Chairs’ foreword

This document sets out our draft Annual Plan for 2011/12. We are particularly keen to
receive your feedback and guidance on our work next year in view of the significant
change taking place in the economy, for consumers, and in terms of the overall consumer

The draft plan sets out a broad programme of potential work for next year and covers a
range of areas and projects where we believe Consumer Focus could make a real
difference and reduce consumer detriment.

The difficult economic environment means that our resources for next year are likely to be
more constrained. We therefore need to ensure that we prioritise the work we do and
concentrate on areas where Consumer Focus can have most effect. We would like your
help in making those decisions and welcome feedback on the range of potential work set
out in this draft plan including areas where you think we should focus our efforts and any
which you feel are of lesser priority.

We take our responsibilities to small and micro-businesses seriously, especially in
relation to the energy and postal markets. We are keen to hear how we can make a real
difference for these consumers in the coming year.

We are very alive to the fact that priorities set may be different in Scotland, Wales and
Northern Ireland. This needs to be recognised as Consumer Focus Scotland, Consumer
Focus Wales and Consumer Focus Post firm up their specific work within the framework
of the overall plan. Our devolved structure is a huge strength for consumers, so
stakeholder feedback on national priorities is also invited.

The Government announced its proposals to reform the consumer landscape in October.
At some stage over the next two to three years Consumer Focus will close, with its
functions largely taken up by other bodies (Citizens Advice, Citizens Advice Scotland and
the General Consumer Council for Northern Ireland). We want to work closely with all
involved so we can help achieve a smooth transition to the new arrangements and good
outcomes for consumers.

Until these changes are brought into effect we will continue to represent the interests of
consumers to the best of our ability, including in energy and post markets where we have
important responsibilities. Consumer Focus, and its predecessor bodies, has built a
strong body of expertise and knowledge on consumer policy, advocacy and
representation over many years. This is a precious resource, and we hope to continue to
nurture it as we transfer to the new arrangements.

We look forward to your feedback on our work programme for next year.

Christine Farnish
Consumer Focus

Viv Sugar                  Douglas Sinclair              Rick Hill
Consumer Focus             Consumer Focus                Consumer Focus Post
Wales                      Scotland                      Northern Ireland

Draft Annual Plan 2011/12 for consultation                                                  3
Our successes for consumers

Since October 2008 we have brought about changes in markets and public
services to deliver better value, access, customer service and consumer
protection. We estimate that we have recovered £500 million for consumers
in direct and indirect benefits. These are some of our successes.
       We were instrumental in npower returning £70 million to 1.8 million of their
        customers because of energy bill overpayments in 2007
       Our cash ISA super-complaint will gain consumers at least £15 million each year
        in interest that was previously lost
       100,000 consumers a week who switch energy supplier or tariff can use 13 price
         comparison websites accredited to our Confidence Code and save an average
         of £32 a year
       Consumers lose up to £3.3 billion from rogue traders through bogus claims or
        fake lotteries. We successfully argued for stronger legal protection in the Civil
        Sanctions Programme and consumers can now claim compensation
       Our work with Ofgem led to their 2008 Probe making cuts in excess energy
        charges of £332 million each year
       Consumer Focus Scotland won a new ‘User Focus’ duty on scrutiny bodies to
         continuously improve the experience of consumers in the Public Services
         Reform (Scotland) Act
       Consumer Focus Scotland’s Energising Communities shaped guidance to local
        authorities on rolling out the Universal Home Insulation Scheme
       Our report that more than half of postal consumers received ‘sorry you were out
        cards’ while at home led to immediate action from Royal Mail
       During the post office closure programme we helped to win early changes for 12
        per cent of closure proposals and for 100s of others as the process progressed
       Our Extra Help Unit has recovered £1.4 million for energy consumers, many at
        serious risk of being disconnected from their energy supply
       After years of campaigning, Consumer Focus Scotland helped secure the Legal
        Services (Scotland) Bill which will widen choice and increase access to justice
       We won mandatory price support for low income households; fairer prices for
        pre payment meter users; a ‘super priority’ group for the Carbon Emissions
        Reduction Target
       With consumers confused about how to get the best mobile phone deal,
        Carphone Warehouse circulated 200,000 of our advice leaflets
       An end to overcharging of up to £150 per year for motorists who use one of the
        5,000 garages which have signed up to a tough code
       A powerful report from Consumer Focus Wales led to action to prevent a repeat
        of the tragic outbreak of E.coli O157
       25,000 people signed-up to Stayprivate.org, a CF Labs website which simplifies
        the process of registering with telephone and mail marketing opt-out services
       Our advocacy on the European Telecoms Package strengthened consumer
        provisions, increasing tariff transparency and putting a cap on contract lengths

Draft Annual Plan 2011/12 for consultation                                                  4
About Consumer Focus

Who we are
Consumer Focus is the independent champion for consumers across England, Wales,
Scotland and (for postal consumers) in Northern Ireland. We were created through the
Consumers, Estate Agents and Redress (CEAR) Act 2007. We operate across the
economy, persuading businesses and public services to put consumers at the heart of
what they do, and helping consumers get better outcomes for themselves.
Consumer Focus has specific responsibilities with regard to the energy and post sectors
and we will gain responsibilities with regard to the water industry in Scotland in 2011.
In October 2010 the Government announced its intention to transfer the functions of
Consumer Focus into Citizens Advice and Citizens Advice Scotland by 2013.

What we do
We are an advocacy body that tackles the issues that matter to consumers, and gives
people a stronger voice. We don’t just draw attention to problems – we work with
consumers and with a range of organisations to champion effective solutions that make a
difference to consumers’ lives.
The CEAR Act sets out the three core functions of Consumer Focus:
        Representation – Consumer Focus may provide advice and information, make
         proposals and represent the views of consumers to ministers (including those in
         Scotland and Wales), regulators and any other relevant person
        Research – Consumer Focus may obtain information about consumer matters
         and consumers’ views on those matters
        Information – Consumer Focus may facilitate the dissemination of advice and
         information to consumers
The CEAR Act also gives Consumer Focus a significant role in providing advice to
individual consumers on energy and postal matters, together with a power to investigate
cases that raise wider issues for consumers in general.
Our knowledge of consumer problems and solutions in different markets and regulatory
regimes enables us to intervene effectively on behalf of consumers, across the economy.
Consumer Focus must have regard to the interests of people who are disabled or
chronically sick, pensioners, people on low incomes and those in rural areas. We are also
obliged to undertake our work in a manner that is best calculated to contribute to the
achievement of sustainable development

How we work
The CEAR Act allows Consumer Focus to obtain information from business and others
that is not already in the public domain. These powers play a vital part in our analysis of
consumer detriment across the economy. In many cases having the power means
companies often pre-empt formal requests by providing us the information voluntarily.
Critically, a substantial research base underpins our work. In 2009/10 we conducted
about 60 consumer research and engagement projects involving around 25,000 people in
quantitative, qualitative and deliberative research in 500 locations around the UK.

Draft Annual Plan 2011/12 for consultation                                                    5
Consumer Focus Scotland also has a consumer network of over 400 volunteers from all
parts of Scotland who help to keep us informed about consumer concerns. They identify
local consumer issues and investigate services and facilities in their area, and this
intelligence feeds into our work programme.
With strong powers set out in law, a good reach across the UK and with an excellent
research and evidence base, we are able to improve the situation for consumers by:
        Identifying issues of concern within various markets and services that don’t work
         for consumers
        Engaging with issues through research, policy development, and working with
         stakeholders and consumers
        Campaigning to bring about needed change
        Empowering consumers to get a better outcome for themselves or to challenge
         unfair treatment
Our investigations team, based in Cardiff, provides an expert resource that is able to
deploy to the greatest effect, our information gathering powers and our ability to make
legal challenges. Our legal powers are one of our greatest strengths and we are ready,
willing and able to use them to challenge unfair treatment and to disclose important
information to consumers and those who represent their interests.
CF Labs, also based in Cardiff, is our online empowerment team. It builds innovative
tools and services to make consumers' dealings with companies fairer and simpler, or to
improve access to important information and data.
Our Extra Help Unit, based in Glasgow, works with vulnerable consumers to help resolve
individual complaints in energy or post – for example, if someone is facing disconnection.
Vulnerable consumers can be referred to the Extra Help Unit by Consumer Direct, Ofgem
and Postcomm or by their MP, MSP or AM.
We also provide online and telephone support for advice-agency staff on energy and
postal issues, including background information and advice with answering enquiries.
A strong, devolved organisation
Consumer Focus acts for all consumers in Great Britain and, for postal services, Northern
Ireland. We are uniquely placed to ensure that consumer interests are firmly at the heart
of business and Government decision-making.
Our work takes place within a highly devolved context. We have strong organisations in
Consumer Focus Scotland, Consumer Focus Wales and Consumer Focus Post (Northern
Ireland), who deal with both devolved matters and with the different consumer issues,
and sometimes markets and laws, in their nations. Working across four administrations
makes our work more complex, but it is an important source of strength for us and for
consumers across Great Britain, and Northern Ireland in respect of post matters.
The breadth of topics covered in the nations is similar to those at GB level, but the
emphasis can vary substantially. For example, there has been a greater focus on public
services in both Scotland and Wales, while Consumer Focus Scotland and its
predecessor, the Scottish Consumer Council, have a distinguished record in issues
around legal services and access to justice.
Both Consumer Focus Wales and Consumer Focus Scotland continue to do significant
amounts of work on public health and food, while at Consumer Focus it has been the
National Social Marketing Centre which has done important work in this area, enhancing
its international reputation on behaviour change and public health.

Draft Annual Plan 2011/12 for consultation                                                6
For consumers of energy

The big challenges
The challenges facing consumers of energy are massive, complex and inextricably bound
together. The industry plans up to £200 billion of investment over the next decade to
decarbonise the electricity generation market. Even disregarding the effect of volatile
wholesale gas prices, consumers could see annual bills rise by £300 over 10 years.
By 2020 every home in Britain will have had a smart meter installed, the biggest single
energy change in our homes since natural gas was piped in. Over the next few years the
Green Deal is intended to be the ‘game-changer’ for energy efficiency. Consumer trust in
energy suppliers is already low; these developments will see a seismic change to the way
consumers experience the market and will present new priorities for consumer protection.
Higher prices mean more households at risk of sliding into fuel poverty. There is a
pressing need for a coherent programme to safeguard the interests of those endangered
by rising costs. Any programme of safeguards must include consumers in rural areas who
are more likely to be without mains gas and with hard to heat homes. These consumers
have been left for too long in the too-difficult-to-deal-with category.

Well placed to deliver
We have made strides to ensure that the consumer interest is kept at the heart of the
regulated energy market with improvements to debt and disconnection policies; direct
selling rules; social tariff support; energy prepayment services and consumer information.
This included a landmark agreement with npower to return £70 million to customers who
overpaid for energy.
We have used our legal powers frequently to gain access to information on the operation
of the energy market, to understand when and how the market fails consumers and what
the practical solutions are. We already provide a strong set of empowerment tools and an
Ask the Adviser service for organisations such as Citizens Advice and Consumer Direct.
Our commitment to an evidence based, detailed approach means that consumer interests
can be heard at the design and planning stage of major policy decisions on smart meters,
Green Deal, feed-in-tariffs, network investment, changes to energy bills and fuel poverty
programmes. Our place on the different key industry code bodies means we can inform
decisions on the way that costs are distributed among consumers and make sure the
needs of disadvantaged consumers are recognised.

Provisional plans for 2011/12

         Representing consumers on the big decisions
        Consumer Focus has championed the potential of smart metering to radically
         change the energy retail market and reduce many common consumer problems.
         However, it may also bring more complex tariffs, lock-in contracts, data
         protection concerns and marketing abuses. We will deliver our smart meter
         action plan to ensure that implementation happens with technology that works
         across multiple energy providers and with consumer and data protections in

Draft Annual Plan 2011/12 for consultation                                               7
       All the building blocks of the Green Deal – the finance package, the supplier
        obligation, and the accreditation scheme – must work together if it is to deliver
        for consumers. We will engage at every step of the way to ensure a simple and
        well-designed package that helps everyone, and especially those in most need
       Underpinning much of our work on major market reforms is the question ‘who
        pays for the transformation of the energy sector?’ We will argue for a fair
        distribution of costs between consumers, citizens, shareholders and
        Government. We will argue for a new era of transparency about how the market
        operates, about achieving sustainability objectives, about how consumers pay,
        what they are paying for, and what benefit they receive

        Improving consumer experiences
       We could tackle key consumer issues for households and small businesses in
        the retail market – more accurate and informative bills, better complaint handling
        and customer service, easier switching and more responsible marketing. We will
        build on our tariff complexity referral to Ofgem to make it easier for consumers
        to compare deals and switch
       Consumer Focus Scotland may expand its Energy Best Deal Scotland
        campaign, supported by Ofgem, which empowers consumers in Scotland and
        aims to help consumers, especially the most disadvantaged, to get a better deal
        on their energy supply through smarter switching
       Over five million households are in fuel poverty in Britain and the number is
        widely predicted to climb. Building on past campaigns we could work closely
        with UK and devolved governments to identify solutions, supported by coherent
        strategies. We would bring a new determination to face the challenges of rural
        fuel poverty. Consumer Focus Scotland plans to work with partners and the
        Scottish Government on a new regulatory framework for energy efficiency in
        private housing to deliver urgent improvements without regressive costs for
        tenants or homeowners
       We could strengthen our empowerment initiatives for domestic consumers and
        small business as well as our partnerships with Consumer Direct, the Energy
        Ombudsman and advice agencies. We will look to further develop our monthly
        customer service performance data, our tariff tracker, a stronger Confidence
        Code and improved online advice and information
       We may explore the experiences of households without mains gas who face
        higher heating costs and inappropriate energy efficiency programmes. This
        affects consumers in Scotland and Wales disproportionately and so Consumer
        Focus Scotland and Consumer Focus Wales could make recommendations on
        how consumers can best access and afford alternative heating sources

Devolution perspective
While most issues in the regulated energy market are GB-wide, there are important
national policy dimensions and devolved issues. The greater proportion of households in
Scotland and Wales who are not on the mains gas network make this a pressing
consumer issue in Scotland and Wales.

Fuel poverty and energy efficiency are devolved matters to Scotland and Wales and
both Consumer Focus Scotland and Consumer Focus Wales are fully engaged in
national programmes and campaigns to reduce fuel poverty.

Draft Annual Plan 2011/12 for consultation                                                  8
Case study: sorting out problems on a grand scale – npower
On 1 October 2010 npower announced that it would make refunds to customers who
overpaid for gas in 2007. That announcement came after two years of Consumer Focus
campaigning and another year of close co-operation with npower to deliver a solution that
was right and fair

In 2007 npower changed the way it applied its unit charges for gas supply, but did not
communicate this change effectively to customers. An estimated 1.8 million customers
may have paid for more higher-priced units than they had expected. In February 2009,
after an energywatch referral and an Ofgem investigation, npower repaid an average £6
to around 200,000 customers (£1.2 million). Consumer Focus and many customers
thought this did not fully reimburse people for the overpayments made, and we pursued
further discussions with npower.

We used our information gathering powers and took legal advice, but all the while we
kept talking to the company and we were able to agree that they should make payments
to affected consumers. A series of regular meetings, conference calls, exchanges of
calculations and negotiations on methodology followed over many months.

As a result of our intervention, npower reviewed its customers’ billing records, working
closely with us, to ensure a fair amount was paid back. The average figure for those
customers entitled to a refund is £35, with payments ranging from £1 up to around £100.
The combined total available for all affected customers is £70 million, comprising £63
million of payments for gas charges plus £3 million in VAT and £4 million in interest.

Our deep understanding of the market, and its regulations, but also of the way that the
business of energy supply works, meant that we were able to identify what went wrong
but also how to put it right.

Draft Annual Plan 2011/12 for consultation                                                 9
For consumers of post offices,
post and digital communications

The big challenges
Change seems necessary to secure a future for Royal Mail and the Post Office network.
However, the risk of unintended consequences – higher costs, worse service levels, loss
of trust and weakened regulatory oversight – is high. Postal services and post offices are
a particularly vital lifeline for consumers in rural, remote and deprived urban areas.
Rural consumers also suffer in other aspects of the communications market. Broadband
connections – where they exist – can be slow at best just where they may be most
needed given the extra distance consumers have to travel to access public and financial
services. Change is needed, but the impact on consumers must be fully understood.
While broadband internet is not a cure-all for the problems facing the postal service,
consumers need postal and post office services to be seen in the context of the broader
communications market and in the context of fair access to broadband and online
services. Consumers need access to communication networks and to fast, high quality
and reliable services. Some will need support and encouragement to get online and reap
the benefits of digital technologies.

Well placed to deliver
Consumer Focus has acquired a strong reputation across Europe for its work on postal
matters. We have recently published our joint research with Postcomm on the impact of
possible market changes. Our expert seminars in England, Scotland, Wales and Northern
Ireland brought consumer issues to the attention of community groups, market players
and decision makers, so that debates about market and regulatory changes can happen
with a comprehensive and closely argued account of how consumers may be affected.
Our predecessor, Postwatch, tracked every proposed closure across the UK post office
network in 2007 saving post office services or proposing appropriate local solutions for
hundreds of communities. Our tracker research has kept a close eye on the level of
service from Crown post offices and the impact of new models of service delivery. We
have shown how the network is well placed to offer new services, but that it must address
weaknesses in its quality of service to realise its potential.
Our work on access to broadband, copyright reform, digital consumer rights and a fairer
deal for consumers in these complex markets enables us to take a coherent view across
all the converging communications markets. Building on this work will contribute to
making Britain the best place in the world to be a digital consumer.

Provisional plans for 2011/12

         Representing consumers in the big decisions
        Commercialising Royal Mail must not be at the expense of its customers. As the
         Postal Services Bill is implemented we intend to highlight the risk of regulatory
         blight in the lead up to Ofcom taking over responsibility for the Royal Mail;
         campaign against any unraveling of consumer protections and try to safeguard

Draft Annual Plan 2011/12 for consultation                                              10
          consumers from undue price rises or service reductions before any sale of
          Royal Mail and as Post Office Limited is decoupled from the Royal Mail group
         As Post Office Limited rolls out the ‘Local’ model, consumers must have a
          proper say in the decisions that affect post office services in their area. We
          could press for the active involvement of communities in local plans and make
          decision makers fully aware of the risk of service degradation if implementation
          fails to take account of the needs of consumers and their local communities

          Improving consumer experiences
         We may challenge proposals that might diminish the essential character of the
          universal postal service, in particular in relation to rural and remote communities
          and services between Northern Ireland, Great Britain and the Irish Republic
         We could press the case for extending banking, credit union and government
          services through the Post Office. We may advocate an expansion of the Post
          Office role in the context of reforms to mainstream banking and the provision of
          public services in a devolved, local and community context. Consumer Focus
          Scotland could build on its work mapping the provision of public services and
          encouraging the delivery of more government services though Scottish post
         Consumers may receive poor customer service, particularly in High Street post
          offices. We could challenge Post Office Limited to redefine the consumer
          experience on the principles of convenience, flexibility, and efficient service. Our
          functions in relation to business-as-usual changes to the Post Office network
          would help us to safeguard those most affected by Post Office changes or
          service failures
         Being online has shifted from a useful to an essential part of the lives of most
          people. Many consumers increasingly rely on the internet to engage with a
          whole range of private markets and public services. We could keep pressure on
          policy makers across Great Britain for better access to broadband in rural and
          remote areas and to tackle the barriers that stop people from getting online
         Communications markets – mobile phones, fixed line, broadband and digital
          broadcasting – are confusing. Complex products and services, lengthy lock in
          contracts and a lack of useful information makes it difficult for consumers to get
          a decent deal or resolve a problem. We may identify where better information is
          needed, as well as the type of information that would benefit consumers most
         UK copyright law needs to be updated and the copyright licensing system
          reformed. With copyright owners seeking to enforce their copyright, the process
          for obtaining evidence, the quality of that evidence and the proportionality of
          sanctions are critical consumer issues. We would seek reforms to copyright law
          to deliver statutory user rights in relation to copyrighted content

Devolution perspective
Post and post offices are not devolved issues, but they are vital services. Changes to the
universal postal service and the Post Office network carry a threat to isolated and rural
areas where the post office may be the only retail outlet in a village and broadband and
communications infrastructure can be poor. Access to broadband and digital services is a
particular issue in Scotland, which has the lowest levels of broadband uptake in the UK.

Devolved governments have a significant role in promoting the delivery of government and
other public services through the Post Office network. The Scottish Government has set up
a Post Office Challenge Fund to help maintain the network. The Welsh Assembly
Government is providing diversification grants to subpostmasters, and is looking to support
the viability of post offices to deliver wider social and financial inclusion objectives.

 Draft Annual Plan 2011/12 for consultation                                                11
Case study: putting the consumers’ case
– Post Office banking
Everyone wants to support their local post office, but we wanted to show what more this
service could offer consumers, especially those neglected by mainstream banks.

Our report Opportunity knocks showed that consumers who are neglected by, or
mistrustful of, banks, saw the strong potential of the Post Office as a provider of
customised financial services that better meet their needs. We argued that expanding the
post office role would be good for the network and good for many poorly served
consumers. The case was strong but it had to be made with those who would determine
the future for the post office network and for consumers who had either been dissatisfied
by their experience with mainstream banks, or had felt neglected by them.

We took the case outlined in Opportunity knocks to No 10 Downing Street and across
Government. We contributed to cross departmental committees and influenced the
Business & Enterprise Select Committee’s Post Offices – securing their future report. The
quality of the report and the research that underpinned it was recognised across
Government and by a range of stakeholders.

The commitment in the Government’s Post Office policy statement to support the Post
Office as it expands further into financial services, provides the opportunity to further build
on the progress it has made to date.

Consumer Focus Wales presented the research to Welsh Assembly Government
officials, Welsh MPs and Assembly members. Consumer Focus Post engaged the credit
union movement in Northern Ireland. Consumer Focus Scotland used the Opportunity
Knocks report and Department Business, Innovations and Skills consultation to engage
with MSPs, Scottish Government officials, the Poverty Alliance and wider stakeholders.

The Post Office Advisory Group (POAG), the Consumer Focus initiated stakeholder
forum on post office issues, submitted a joint response to the BIS consultation, signed by
members including Age UK, Citizens Advice, the Federation of Small Businesses and the
Commission for Rural Communities.

Members supported the policy of developing the post office into a ‘neighbourhood bank’;
urged the Government to instruct Post Office Limited to introduce a range of transactional
accounts, including for consumer groups who are currently poorly served by the major
retail banks; and advocated the introduction of the custom account outlined in our

Some progress is being made toward greater access to mainstream banking products
through post offices. But the case we made in Opportunity knocks remains strong and we
will continue to advance it.

Draft Annual Plan 2011/12 for consultation                                                  12
For consumers of financial

The big challenges
Consumers of financial services have been in the eye of a storm. Fundamental questions
about the prevailing cultures of financial service providers, adequacy of regulatory
oversight, consumer protection, competition and the design of financial products have led
to a root and branch rethink of market rules and governance arrangements.
Major reforms will see regulation and consumer protection carried out by new bodies
including the Consumer Protection and Markets Authority, the Prudential Regulation
Authority and a Financial Policy Committee of the Bank of England. The scope of
regulatory reform is huge and the design and culture of these bodies will be key if the
changes are to work in the interests of consumers.
The interests of consumers must be hardwired into the new regulatory bodies in order to
deliver more competitive markets, more effective market rules and better outcomes for
consumers. The new bodies will need to be transparent and accountable to consumers,
but success will also require targeted and timely representation of the consumer interest.

Well placed to deliver
Our intervention into the Cash ISA market and on complaint handling and switching
behaviour on current accounts has already delivered change in these markets. The
issues we have exposed are relevant to many other financial services products and our
investigative and super-complaint powers can help to remove multiple layers of
complexity, confusion and delay for consumers and facilitate better decisions and choices
in these crucial markets.
At the same time our work on consumers at the margins of these markets, their
increasing reliance on high cost credit options and the role of post office banking and
other solutions, has shown that we can provide realistic and workable solutions for those
consumers often neglected by markets and regulators.
Consumer Focus Scotland was a member of the Scottish Government’s repossessions
group, which made a series of recommendations leading to the Homeowner and Debtor
Protection (Scotland) Act, which came into force in September 2010. The Act introduced
a new set of increased protections for consumers at risk of repossession in Scotland.

Provisional plans for 2011/12

         Representing consumers on the big decisions
        The composition, role and powers of each of the new regulatory bodies are
         being developed, with legislation to reform the regulatory system planned for
         mid-2011. We could work with all the new bodies to help shape the remits,
         structure and work programmes so that they are demonstrably capable of acting
         in the interests of consumers. We would push for consumers to be provided with
         enough information to make judgements about the institutions they are dealing
         with and to have confidence that the regulator will act

Draft Annual Plan 2011/12 for consultation                                                13
         Improving consumer experiences
       Our lively debate on consumers issues, held with the Independent Commission
        on Banking, identified key areas where our strengths of market analysis,
        knowledge of regulatory regimes across other sectors and information gathering
        powers could drive better customer experience. We will challenge the
        performance of service providers regarding complaint handling; complex and
        bundled products; poor consumer information; and customer control of
        payments leaving their accounts
       Our work has shown the inter-connected nature of the disadvantage that low
        income consumers face across financial services and other sectors. That work
        includes a framework by which financial services, products and policies can be
        analysed, developed and assessed for their ability to meet the needs of low
        income consumers. We will use this framework to persuade the financial
        services industry to change their products and policies to reduce the ‘poverty
        premium’ – where poor families pay more for essential goods and services
       A current account model that is based on making revenue through penalty fees
        is unfair and uncompetitive. We would argue for measures that improve
        competition and for alternative models that increase transparency and consumer
        choice, while delivering essential services at reasonable cost. We will persuade
        decision makers that there is room for both fee AND free models
       Many consumers, currently seen as high risk and low return, need lower-cost
        credit. We will build on our work on people without bank accounts, post office
        banking and payday loans to press for the availability of lower cost credit both
        through specialist and community-based models and through mainstream
        financial services
       We plan to follow up our report, Stick or twist, with the Office of Fair Trading
        regarding the persistently high error rate we found in switching; with BACs on
        how the switching service consumers receive can be improved; with the
        Financial Services Authority, Financial Ombudman Service and banks to make
        complaints data more nuanced, more comparable and more trustworthy; and
        with consumers by making available detailed analysis of complaints data and
        pricing information

 Devolution perspective
 Consumers experience financial services in much the same way across the whole of
 Britain and the regulation of the markets is not devolved.

 However there are significant differences in the provision of local debt and money advice
 in Wales and Scotland, as well as in relation to the mechanisms used to recover debt in
 Scotland. As in other work areas, access to financial services for consumers in rural
 communities is a particular issue in Scotland and Wales. The Welsh Assembly
 Government is developing its own Financial Inclusion Strategy while the Scottish
 Government is considering financial capability initiatives. These initiatives are reflected in
 the way we address financial services in a devolved context.

Draft Annual Plan 2011/12 for consultation                                                 14
Case study: driving change in failing markets – Cash ISAs
We estimated that 15 million cash ISA holders could be losing out on interest worth up to
£3 billion a year because of the way the market operates. Millions of people have
invested in these savings products as a way of supplementing pensions. The marketing
and structure of these products, which typically see initial interest rates plummet after a
matter of months and which discourage switching to get a better deal, through
unnecessary delay and complexity, manifestly fail consumers.

In March 2010 we submitted our first super-complaint to the Office of Fair Trading (OFT).
We undertook market analysis to support our case and drew on consumer experience
gathered through moneysavingexpert.com. Our super-complaint helped to raise
consumer awareness of the issue. Support from consumer campaigners and leading
newspapers showed that it had addressed a crucial part of the financial services market
that had fallen into disrepute.

In its decision, the OFT announced measures to cut the length of ISA transfers to 15
working days, saving consumers up to £15 million a year. Significantly, the OFT’s
decision highlighted that the issues we exposed were relevant to other financial services
products, expanding the impact of this super-complaint.

Removing multiple layers of complexity, confusion and delay will mean that consumers
can more easily understand what sort of shape their savings are in and whether they
would be better off switching.

We will continue to subject products and services in the financial services market to
investigation and if necessary will bring more challenges to make these markets work
better for consumers.

Draft Annual Plan 2011/12 for consultation                                               15
For consumers of public services

The big challenges
The broad challenges for public services are similar across Britain. Diminished budgets
will force far-reaching changes in the way key public services are configured. At the same
time there is a shift of control over services towards more community involvement.
In combination this may mean a period of fundamental change in the way people interact
with and experience services. These changes will present opportunities to redesign
services around the people who use them and to give people a greater say in how the
services they use are delivered and prioritised. However, there are risks that service
standards may deteriorate and the need to put consumers at the centre of service design
may be drowned out in the noise of change.
To a greater or lesser extent, most public services are devolved to the Scottish
Government and Welsh Assembly Government and the approach from Consumer Focus
will reflect the differing approaches and priorities in England, Scotland and Wales.

Well placed to deliver
Consumer Focus can build on an extensive body of evidence that shows that services
that are consumer-led and designed around the needs of their users are more effective
and more efficient.
We have shown how to consider consumer issues in relation to some sensitive services
        how satisfied people are with the service they get from the police in England and
        how well Jobcentre plus delivers on its personalised service pledge
        whether directgov, which needs to be a pivot for the interaction of consumers
         with public services, was built for the convenience of providers, rather than the
         needs of consumers who were expected to use it.
In particular, Consumer Focus Scotland can point to how its years of advocacy (and
those of the Scottish Consumer Council before it), on involving users in public services
helped to secure a ‘User Focus’ duty on public sector scrutiny bodies. This represents a
fundamental shift in Scottish public services to considering how well public services meet
the needs of consumers and communities.

Provisional plans for 2011/12

        Representing consumers on the big decisions
        Public services need to be both effective and efficient. Engaging with consumers
         is critical to achieve effective services and the insight that engagement brings
         makes greater efficiency a more achievable objective. Whether the approach is
         one of the ‘Big Society’, ‘User Focus’ or ‘Innovation and Efficiency’, Consumer
         Focus would build on work exploring the consumer appetite and preparedness
         for localism. Assumptions about what consumers and communities want from
         ‘localism’ must be balanced with the information and understanding that will be
         necessary to make it a reality

Draft Annual Plan 2011/12 for consultation                                               16
        Improving consumer experiences
       Digital exclusion in all its guises will become more pronounced as accelerated
        shift to online technology becomes part and parcel of access to public service.
        Digital technologies can improve consumer experiences by making transactions
        convenient, providing better access to information and redress, and bringing
        new opportunities for engagement. They hold the promise of doing more for
        less, but they do not guarantee it. We could argue for a set of practical
        consumer principles to ensure that the design of a new generation of online
        public services is driven by an understanding of what people want from them,
        rather than by provider assumptions, application ‘fervour’, or the allure of quick
        win savings
       Consumer Focus Scotland may build on its work on consumer engagement in
        public services by advocating best practice to service providers. We may also
        build on current work on the delivery of services to older people, focusing in
        particular on social care, housing and food services
       In 2011/12, Consumer Focus Scotland may continue to press for health services
        which place the patient at the centre of service planning and delivery and for
        effective models of consumer representation. Consumer Focus Scotland also
        manages Health Rights Information Scotland, a national development project
        funded by the Scottish Government, which produces information for patients to
        empower them in their interactions with the health service, whether in relation to
        their own care or to services in their local communities
       Consumer Focus Wales will shortly be consulting on projects to help further
        develop the citizen-centred agenda of public service reform in Wales. Projects
        under consideration include plans to help increase public involvement in service
        design and capacity for organisations to engage effectively with users and

Devolution perspective
Consumers rely on public services wherever they are in Great Britain. However, the
responsibility for the delivery of public services is a highly devolved issue. Most public services
are devolved in Scotland and Wales including health, local government services such as
education, and housing (and also the justice system in Scotland).

There are also significant differences in the national debates about how cuts to public services
and the involvement of communities in the design, decision making and delivery of public
services will be taken forward. These different national approaches and priorities will determine
the character of our work on public services in England, Scotland and Wales.

Under the provisions of the Public Service Reform (Scotland) Act 2010, Waterwatch Scotland,
the consumer advocacy body for water in Scotland, will be dissolved and its functions
transferred to Consumer Focus Scotland. These functions include a range of statutory powers
and duties. However, Consumer Focus will also develop its own research and policy agenda on
the big consumer issues in the industry and work has already begun with the key stakeholders
to start shaping the scope of our work after July 2011.

Draft Annual Plan 2011/12 for consultation                                                17
Case study: changing the perspective on service provision –
user focus in public services in Scotland
On 1 October 2010, a duty placed on scrutiny bodies in Scotland to be ‘user focused’
came into force.

The duty represents the outcome of years of research and advocacy by Consumer Focus
Scotland, and previously the Scottish Consumer Council (SCC).

The development of the User Focus duty has its roots in the Independent Review of the
Inspection, Audit, Regulation and Complaints Handling of Public Services in Scotland
carried out by Professor Crerar and published in 2007. The SCC was actively involved in
this review. Douglas Sinclair, then Chair of SCC, was a member of the review’s expert
panel and SCC provided briefing papers and a literature review on the consumer
approach to scrutiny of public services.

Our involvement led directly to the review’s focus on the needs of consumers as the
ultimate beneficiaries of scrutiny activity. Our influential booklet, User Focus: Seven Key
Tests, published in 2009, is widely used by scrutiny bodies as a toolkit to develop their
user focus strategies.

The duty has widespread implications for Scottish public services. By requiring scrutiny
bodies to have ‘user focus’. The duty requires inspection, regulation and audit activity to
be focused on the impact that services have on users. This represents a fundamental
shift in Scottish public services to considering how well public services meet the needs of
consumers and communities.

It also provides a blueprint for other jurisdictions that are committed to putting people at
the heart of public services.

Draft Annual Plan 2011/12 for consultation                                                     18
For consumers in unfair markets

The big challenges
Markets that treat consumers unfairly deny people access to good value, decent levels of
service, and effective remedies when things go wrong. At a time when household
budgets become ever tighter, the cumulative effect of markets that fail consumers grows
more serious in scale and in impact. Increasing the effectiveness of competition for
consumers and tackling restrictive practices is a key challenge across the economy.
At the same time, a UK Government programme to reform consumer law, consumer
protection and market enforcement may transform the consumer welfare landscape. The
signs of success must be: a simpler and quicker system for redress; decisive action
against companies and markets that do not trade fairly; and a framework for consumer
law that is both fit for the age and leads the world.
Structural reform of consumer law and regulatory regimes must go hand in hand with a
massive growth in the exercise of consumer power across Britain. Consumers can
condition markets by their choices and actions. Increasingly, the provision of advice
directly to consumers can be complemented by consumers sharing and pooling
experiences with accurate and timely information about complaints against traders and
the organisation of collective action.

Well placed to deliver
Consumer Focus, and our predecessor bodies, has been prepared to challenge markets
and companies that fail consumers. We have used our legal powers of investigation to
understand how companies treat consumers and how consumers and markets can be
adversely affected. Where necessary, we have lodged super-complaints, publicly named
and shamed companies and otherwise pushed for effective enforcement action. We have
demonstrated that we are ready, willing and able to challenge major companies and
markets that do not play fair with consumers.
We also build on an unrivalled experience in helping to construct frameworks of
consumer law, regulation and self-regulation in global, European, UK and devolved
contexts. We can draw on the experience of over 30 years of practical engagement with
the challenges of making better regulation and more effective consumer rights.
Consumer Focus, and our predecessor bodies in energy and post, has a long track
record in empowering consumers with advice and guidance to make informed decisions
about value and service from competitive markets. CF Labs, our online empowerment
team has harnessed the increased consumer use of the internet to show how simple and
well considered online resources can transform the ability of consumers to shape markets
and services through their actions.

Draft Annual Plan 2011/12 for consultation                                              19
Provisional plans for 2011/12

        Representing consumers on the big decisions
       The opportunity to influence and change the consumer law landscape comes
        infrequently. As the UK Government considers a White paper on consumer
        empowerment and prepares to transpose the Consumer Rights Directive, we
        plan to pursue measures that would ensure that Britain has the most effective
        markets and consumer rights in the world

        Improving consumer experiences
       We could investigate markets that fail consumers, as we did in the cash ISA
        market. In cases where there is clear detriment and potential market remedies
        we will use our full powers of investigation, challenge and super-complaint to
        drive out bad and rip-off practices
       Consumer Focus Investigations, based in Cardiff, may use its network of referral
        partners, data from Consumer Direct and our statutory information gathering
        powers to identify and pursue markets and companies that fail consumers
       Consumer Focus could champion a pragmatic approach to industry-led
        regulation and co-regulation based on our existing review in this area. We would
        seek out partners in the business community who are willing to take action
        themselves to make their markets better and fairer
       Consumer Focus Scotland is the leading campaigner for improvements in the
        property and land management market in Scotland, estimated by the OFT to be
        worth around £66 million. We also seek to promote the interests of tenants in
        the private rented sector, who are often disadvantaged. We plan to continue to
        work with the Scottish Government and other stakeholders to develop and
        implement those practical solutions that will improve consumer experiences of
        these markets
       The retraction of legal aid and the cost of civil justice in England and Wales
        mean that alternative ways of funding cases are the only way by which some
        consumers can access justice and seek redress. Consumer Focus would argue
        for consumer solutions that make civil justice accessible, affordable and
        navigable. We could highlight those areas where consumers will not have fair
        access to justice by representing themselves
       Following Lord Gill’s review of the civil courts in Scotland, Consumer Focus
        Scotland will publish in early 2011 the report of the Civil Justice Advisory Group
        chaired by Lord Coulsfield. This will make practical recommendations to the
        Scottish Government on the way forward in relation to ensuring appropriate,
        affordable and fair dispute resolution processes. We would build on this
        foundation and expand our work on civil justice and public legal education, in
        anticipation of civil justice reform legislation in 2012

 Devolution perspective
 The legal framework differs fundamentally between Scotland on the one hand and
 England and Wales on the other. Consumer Focus Scotland has a long and successful
 record in consumer advocacy in relation to the legal framework in Scotland and that
 work will continue in the devolved context.

 The increasing process of devolution also means that measures passed by the
 National Assembly for Wales will also affect business behaviour in Wales. Most notably
 this will shortly include new laws in Wales regarding the Welsh language which will
 affect not only public services but also utility companies.

Draft Annual Plan 2011/12 for consultation                                              20
Case study: driving up the standards to food safety
– E.coli O157 in Wales
In September 2005 a major outbreak of E.coli O157 occurred in South Wales.
Contaminated cooked meat was served to pupils in schools throughout four local
authority areas. 157 people became ill and a five year old boy died.
A Public Inquiry, chaired by Sir Hugh Pennington, made recommendations aimed at both
the public sector and food businesses. Last year, Consumer Focus Wales decided to
take on the task of reviewing the work that had been done to put the recommendations
into action.
We also carried out research into consumer trust in food safety more generally. This
found that consumers in Wales have a lower level of trust than those in the UK as a
The combination of sound research, a determination to see recommendations from the
public inquiry carried out and the drive to transform the attitude of public bodies and
private companies to food safety made the report one of the most effective ever
interventions into the food industry in Wales.
Nine out of 10 consumers in Wales told us that they want mandatory display of food
hygiene ratings to be introduced in Wales. We will campaign for that to become reality.
The impact of the report and our continuing advocacy has been to see:
        a renewed vigour from Welsh Assembly Government to address the outstanding
        a far greater awareness of, and response to, Food Standards Agency proposals
         on food safety
        the clear understanding that consumers in Wales will not allow the issue of food
         safety to slip off the agenda
For the mother of Mason Jones, the little boy who died as a result of the outbreak, it
provided some reassurance that action would be taken.
On behalf of myself and my family and other affected families, I would like to thank
Consumer Focus Wales for all the hard work they have carried out in compiling this

Transparency is what we called for after the recommendations were announced and I
think this report gives us some much awaited answers to some of the questions which the
agencies involved have failed to answer since Professor Pennington’s report was

This report shows us that although a little progress has been made, so much more is still
yet to be done.

Sharon Mills
Mother of Mason Jones, who died on 4 October 2005 from E.coli O157

Draft Annual Plan 2011/12 for consultation                                                21
On the international stage

Big challenges
Legislation in Europe will have a direct impact on consumers in Great Britain. Directives
on the regulation of energy markets and universal postal services will determine the
framework for consumer protection and service. The transposition of the Consumer
Rights Directive (CRD) could affect the very foundations of our consumer rights.
Consumer Focus is at the heart of getting these matters right.
At the same time, there are issues of consumer protection that need to be addressed at
an international level. When consumers buy goods and services over the internet, the
physical border of the UK and its consumer protections can mean less than international
and European guidelines and rules. It is in the interests of all British consumers that the
rules work for them wherever they buy.

Well placed to deliver
Consumer Focus carries more specialist knowledge in the energy and postal services
markets than any other consumer body in Europe. We have developed considerable
understanding of digital communications. On all these areas we have played a crucial,
and acknowledged, role in the development and critique of European legislation and
We can build on over 30 years’ experience, authority and credibility from the National,
Scotland and Wales Consumer Councils, in shaping the framework of consumer law. The
application of this experience helps enshrine consumer principles at the heart of the
framework of consumer law benefiting consumers across Europe and in Great Britain.
We also benefit from our well established networks both in the consumer world – through
our membership of the European consumers organisation, BEUC, the Transatlantic
Consumer Dialogue and Consumers International – and directly in the European

Provisional plans for 2011/12

           Representing consumers on the big decisions
        The draft CRD is currently going through the EU legislative process and
         proposals being developed on collective redress and contract law by the
         European Commission will have a significant impact on UK consumers’ rights
         when buying goods and services and on the development of UK consumer law
          Consumer Focus has already been influential on the CRD. Working closely with
           BEUC and consumer organisations in other member states we have succeeded
           in ensuring that the proposal was not rushed through. We persuaded all three
           European institutions to move away from a maximum harmonisation approach
           across the whole package which could significantly lower consumer rights in the
           UK. However, much remains to be done to ensure that the final outcome is the
           best possible for UK consumers. We could continue to apply our influence and
           argument to ensure that the CRD and any forthcoming proposals produce
           stronger, not weaker protection for consumers

Draft Annual Plan 2011/12 for consultation                                                22
        Improving consumer experiences
       The European Union (EU) will begin to roll out a new energy strategy and
        energy efficiency action plan in 2011 that will bring changes to legislation and
        financing in the sector. Without a strong voice for consumers, their needs and
        concerns risk being overlooked as industry and regulators work to bring in the
        necessary changes. Consumer Focus could work directly to influence the EU
        institutions and the relevant national ministries and other national stakeholders
       The EU and the UK are simultaneously reviewing the suitability of the current
        legislative framework for postal services in the light of the evolution of the digital
        economy. This is expected to lead to legislative changes including a review of
        the EU Postal Services Directive and particularly what should form part of the
        universal service obligation. We may work with EU institutions and all relevant
        stakeholders in the drafting and implementation of European policy, supporting
        European standards development where appropriate
       As part of its digital agenda the European Commission is reviewing the E-
        commerce and Data Protection Directives. Any new proposals will have a direct
        impact on UK consumer protection and privacy rights. We could ensure the key
        areas of concern – limited consumer protection rights when purchasing digital
        products, protection of online payments, behavioural advertising, privacy rights
        and enforcement – are addressed
       The European Commission is producing a proposal for a directive on copyright
        licensing and collective rights management that will affect competition in the
        market for creative content. We may work to influence the legislative process to
        advocate outcomes that are beneficial to consumers
       The EU like the UK is actively reviewing the framework for regulation of financial
        markets. We could be active with our partners across Europe to ensure that the
        interests of UK consumers are well represented at all levels. In particular, we
        would use our influence to ensure that European rules on deposit guarantee
        schemes, the single European payment area (SEPA) and Commission initiatives
        on current account fees and switching provide tangible benefits for UK
        consumers. We may also work to prevent proposals for EU directives on the
        mortgage market from weakening consumer protection in the UK

Devolution perspective
While European legislation affects consumers across the whole of the UK, how this is
implemented in practice can vary between the different UK nations. While consumer
protection legislation largely emanates from Europe, this must be enforced via the
separate legal system in Scotland. There is currently no class actions procedure in
Scotland, for example. Moreover, some aspects of consumer protection, such as food
labelling, are devolved in Scotland.

Draft Annual Plan 2011/12 for consultation                                                  23
Case Study: achieving influence in Brussels
– the Telecoms Package
Consumer Focus is a respected and effective international advocate for the interests of
UK consumers. Influencing policy and legislation from Brussels, in particular, helps to set
the consumer interest at the beginning of the process. This makes it more likely that a
sound framework for UK legislation and regulation will increase, not compromise,
consumer protection.
The telecommunications market
When the European Commission began to consider legislative proposals on the
telecommunications markets (the Telecoms Package) we saw the opportunity to
influence the development of a legal framework that could strengthen consumer
protection and encourage more open and fair markets.
Building on the work of the National Consumer Council, we worked closely with the
European consumer association BEUC, to ensure that the Commission and the
European Parliament (EP) heard the views of consumers as well as of governments and
global communications giants. We lobbied Commission officials, MEPs in the relevant EP
committees and the UK Government on the consumer issues that needed to be
addressed in the legislation.
Our objective was to make sure that the new legal framework brought about by the
Telecoms Package provided a better consumer protection regime. Our advocacy resulted
in strengthening consumer provisions (mostly in the Universal Service Directive and E-
Privacy Directive) through:
        increased transparency of information to consumers on prices, tariffs and terms
         of conditions
        a reduction to one day in the time operators can take to transfer consumers’
         mobile numbers
        a cap of 24 months on the length of contracts plus a requirement for service
         providers to offer 12 month contracts
All of these should make it easier for consumers to choose the best deal and to switch
At present our work focuses on the implementation of the Telecoms Package regulations
at national level, to ensure that all the consumer protection provisions are duly
transposed into the UK laws by the middle of next year, so that consumers can benefit
from the new legislation.
Without Consumer Focus working in concert with consumer bodies across Europe the
consumer voice would not have been heard and it is unlikely that the improvements in
consumer protection would have been achieved.

Draft Annual Plan 2011/12 for consultation                                               24
Reaching out to consumers

Extra Help Unit
Our Extra Help Unit (EHU) helps vulnerable consumers across Great Britain with their
energy and postal complaints. In particular, we have a duty to investigate cases where a
consumer has been disconnected from their energy supply, been threatened with
disconnection or has experienced a failure with their prepayment meter system.
Consumers who come to us can be very distressed, on impossibly tight incomes and in
desperate need of support. Many suffer from health problems and often there are young
children or older people living in the home to consider. In resolving consumer complaints
we investigate and uncover failures in companies’ practices or policies.
Most consumers who need our help are in debt and facing disconnection (35 per cent) or
cannot resolve billing errors (27 per cent). Since the EHU was set up we have helped
over 15,000 consumers and recovered £1.4 million for them.
The evidence from these contacts plays a crucial role in identifying how consumers
experience the debt and disconnection practices of energy companies. A formal referral
from Consumer Focus, based on this evidence, has led to Ofgem carrying out an official
investigation into one energy suppliers’ compliance with the licence condition that is in
place to ensure consumers are able to repay debt at an affordable rate.
Consumer Focus also provides assistance to MPs, Members of the Scottish Parliament
(MSPs) and Members of the Welsh Assembly (AMs) where their constituents have
complained about energy or post. Support is also available for advice-agency staff, such
as Citizens Advice, with energy or postal queries via our online Knowledge Base and our
telephone based Ask the Adviser service where we provide industry information and help
answer queries.

CF Labs
Consumer Focus helps people become more powerful in relation to the markets and
services they use. When consumers start to pick up and share information about how to
get better deals, better treatment or how to avoid problems, then other consumers,
companies and service providers can take note and respond. CF Labs develops
innovative online solutions and tools to make people’s dealings with companies fairer, or
to improve access to important information and data.

Collective action means ever growing numbers of consumers adopting behaviour which
can condition and, if necessary, discipline markets. Increasingly, this happens through
the informal online sharing of information and advice. CF Labs' Recalled Products
website uses data from the EU's RAPEX product recall notice service to help consumers
access and digest this information. It has been cited as a positive example of innovation
by the Australian Government and the EU Directorate General for Health and
Consumers. Its ‘widget’ service, which allows broadcast of its content on third party
websites, is used on an increasing number of local authority websites.

CF Labs can prompt and show the way to claim the internet as a route for consumers to
engage and change markets, not just as a sales channel for companies.
Many of the best ideas are those in the heads of consumers and other consumer
organisations. We could continue to change some of these ideas into real empowerment
tools for consumers.

Draft Annual Plan 2011/12 for consultation                                              25
In partnership with the Scottish Government
Consumer Focus Scotland manages four Scottish Government funded national
development projects which promote better understanding of health rights, healthy diets
and guidance on accessible information.
Community Food and Health Scotland provides a national, strategic focus and
practical support to low income communities facing barriers to a healthy diet. The
healthyliving award works with the food service sector in Scotland to make it easier for
people to eat healthily when they eat out.
Health Rights Information Scotland produces nationally relevant information about
patients’ health rights and about the health services that are available from the NHS in
Scotland. The Scottish Accessible Information Forum aims to improve the standards
and accessibility of information and advice services for the benefit of disabled people and
their carers.

A strong voice for rural consumers
Rural consumers face a particular problem when trying to access affordable, high quality
goods and services. People living in a rural area who are also vulnerable or on a low
income are invariably at a double disadvantage with problems in accessing public
services and communication networks often amplified. Our objective is to challenge the
detriment that rural consumers face and to tackle the obstacles to decent value and
service in rural, remote and island communities.
This year we are bringing together over 100 pieces of research to form a coherent policy
agenda for rural consumers which will provide a prospectus for change in sectors where
they face particular problems.
We may converge the areas of action identified in this and previous work programmes on
fuel costs, access to services, local post offices, digital exclusion with those of other
consumer organisations and partners to create an action plan that could transform the
lives of rural consumers.

Tackling the poverty premium
Low income families pay an average £1,000 annual ‘poverty premium’ for essential goods
and services because they cannot access the deals enjoyed by better off households.
They also have less ‘market power’ to influence the provision of goods and services.

These costs can be sector specific, such as paying a higher premium for insurance in a
particular postcode. But they are usually connected such as getting a poor deal for
goods and services because of no internet access or ability to pay through Direct Debit.

Building on existing research from across Consumer Focus, the project could map the
additional costs faced by low-income consumers and explore with companies across
sectors to show they can transform their ‘offer’ to low income consumers and transform
their experience as consumers. We may make the connections between the
manifestations of the poverty premium in different sectors and bring players from different
sectors together with consumers to explore where potential solutions may exist.

Draft Annual Plan 2011/12 for consultation                                               26
Case study: Extra Help Unit (EHU) – debt and disconnection
…taking the call
People who have been helped by the EHU said:
‘...such a valuable service. I hope it remains. Some people don't understand our struggle with
these things, it's really good to have someone to talk to or work on your behalf’.

‘It has really been the best possible reference in terms of professionalism and capability of dealing
with the public. I would definitely recommend then to anybody I knew if I perceived they needed
help of this kind’.

‘..if it wasn't for an organisation like Consumer Focus being there to help you – what a mess you
could be in.’

‘I just wanted to say a big thank you and to tell you how grateful I am for you helping my cause. It
was so refreshing and inspiring to speak to an empathetic human being. You handled my problem
extremely swiftly and professionally’

‘I felt they cared... they treated me like an individual even although I know they must be dealing
with lots of cases’.

‘I honestly can't praise them high enough, they were totally fantastic, I feel like I should work for

… to changing the way that markets behave

Consumers calling our Extra Help Unit revealed that vulnerable people were being
disconnected in breach of industry-led self-regulatory initiatives.

We were prepared to submit a super-complaint about vulnerable disconnections.
However, Ofgem agreed with our assessment of the urgency of this situation, and began
to work with us on a ‘fast track’ review of vulnerable disconnections.

We wrote to the big six energy suppliers using our statutory powers to request key
information about their debt and disconnection processes. We also asked suppliers to
halt all disconnections temporarily until the question of vulnerability has been established.
Unfortunately no suppliers felt able to do this.

With Ofgem, we met suppliers to better understand their approach to disconnecting
vulnerable consumers in debt. We also made a further statutory information request to
seek clarification and statistical data from suppliers. As a result, Ofgem changed the
licence conditions to strengthen consumer protections, bolstering the
protection afforded to vulnerable consumers.

During the review of evidence from the EHU, two companies appeared to be setting
unaffordable debt repayment rates, potentially in breach of regulations. A formal referral
from Consumer Focus has led to Ofgem carrying out a formal investigation into one
supplier’s compliance with the licence condition that exists to ensure consumers are able
to repay debt at an affordable rate. We await the outcomes of this investigation.

Draft Annual Plan 2011/12 for consultation                                                              27
How to respond

This document presents potential areas of work for Consumer Focus in 2011/12.
The consultation process will run from 17 December 2010 to 18 March 2011. Your
responses will help determine how we could use our powers and resources to best effect
to advance the interests of consumers.
       What are your views on our proposed work for 2011/12?
       How can it be improved? Is there anything that should be dropped?
       Are there other specific projects you feel we should be involved in? Please
        specify these and explain why.
       What should we prioritise?
       Where are the opportunities to work in partnership with others to avoid
        duplication and use resources most efficiently?

Any comments you have on the annual plan should be sent to:

Consumer Focus:                                Consumer Focus Scotland:
Christine Farnish                              Douglas Sinclair
Consumer Focus                                 Consumer Focus Scotland
4th Floor, Artillery House                     Royal Exchange House
Artillery Row                                  100 Queen Street
London                                         Glasgow
SW1P 1RT                                       G1 3DN
consultation.responses                         consultation.responses-
@consumerfocus.org.uk                          scotland@consumerfocus.org.uk

Consumer Focus Wales:                          Consumer Focus Post (Northern Ireland):
Vivienne Sugar                                 Rick Hill
Consumer Focus Wales                           Consumer Focus Post
3rd Floor, Capital Tower                       Elizabeth House
Greyfriars Road                                116 Holywood Road
Cardiff                                        Belfast
CF10 3AG                                       BT4 1NY
consultation.responses-                        consultation.responses-
wales@consumerfocus.org.uk                     post@consumerfocus.org.uk

Draft Annual Plan 2011/12 for consultation                                            28

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