Posted on: 8th December 2022, by Magrathea
You will have seen that the long-awaited statement arrived from Ofcom last month, firming up much of what they included in the consultation earlier this year. In summary, they have confirmed a three-prong approach:
- Disrupt scams by updating rules and guidance and supporting comms providers to do more;
- Collaborate and share more information between relevant parties (e.g. government, regulators, banks etc);
- Help consumers avoid scams by increasing reporting and raising awareness.
In this Part One post we have summarised the key points from the statement specifically relating to misuse of numbers. We will cover the updated CLI guidance in our next post Part Two. Links to the original documents are included at the end if you would like to study the full texts.
Summary points from the Good practice guide to help prevent misuse of sub-allocated and assigned numbers
This guide is applicable to all range holders and to anyone who has been sub-allocated telephone numbers. Because the regulatory requirement to manage numbers effectively already exists this guidance takes effect immediately.
It is only a guide and not a regulation but when judging if we, or you, have met our regulatory obligations Ofcom will check how effectively we comply with this guidance; so it’s a good idea to consider implementing the suggestions. However, Ofcom make it clear that they expect providers to take steps that are reasonable and proportionate in their approach; so that does give you scope to implement exactly what works best for you as situations will be assessed on a case by case basis.
Magrathea already require our clients, by contractual agreement, to properly manage the sub-allocation of any numbers we have assigned. We also already carry out a due diligence process during onboarding and at least annually for each client.
We have reviewed our existing processes with this new guidance in mind and have added a few extra steps to our routine; this might mean that when your next catch-up comes around we will need to ask you a few additional questions. If we identify any particular client as being higher risk, or have reason to believe numbers are not being correctly managed, we now have a more proactive and consistent approach to manage those situations.
For the vast majority of our clients there will be no impact. The aim is that as an industry, we can all use this guidance to assess and if necessary improve what we do, with a collective purpose of trying to reduce the level of nuisance and scam calls.
The key thing to note here is that Ofcom have asked us to report any cases of misuse that are deemed serious, mostly likely due to significant consumer harm, or where there are repeated issues from one client. Ofcom can then take action directly with the service provider involved. One of the most likely interventions is to withdraw number ranges from these service providers and prevent them obtaining future service elsewhere.
If any of our clients wish to discuss how the above impacts them or what changes we are making to our internal processes please do get in touch with us and we will be happy to talk through it.
See here for full document https://www.ofcom.org.uk/__data/assets/pdf_file/0022/247504/annex2-good-practice-guide.pdf