Publications

Citizens Advice Scotland has responded to Ofcom's proposed plan of work for 2023/24. 

The day-to-day activities of citizens are becoming increasingly dependent on their ability to use telecommunications services, such as mobile phones, broadband or landlines. The COVID-19 pandemic has highlighted the essential nature of online connectivity and access to internet data, with many people relying on internet access for working from home, staying informed, or interacting with welfare services, and friends and family.

For clients of the Scottish Citizens Advice network, their mobile phones have become increasingly important in accessing vital online services; with one in five of our clients accessing the internet only through their smart phones. Having a reliable, consistent and affordable mobile connection is essential for clients to access services such as Universal Credit journals and online banking.

CAS has responded to Ofcom's consultation on the regulatory framework for postal services for the next 5 years. 

The competitive water market in Scotland was launched in April 2008. This report explores small to medium business customers’ experiences of the market. It brings together policy insights and market developments with evidence from recently commissioned research. Recommendations are provided which, when actioned by the market, will deliver offerings that have been informed by service users to improve consumer outcomes.

CAS welcomes the Consumer Duty consultation paper. We believe that, in principle, Scottish public bodies should have an embedded duty to consider the impact that decisions related to policy, and adopted practice could, and does, have on those engaging in its services, particularly vulnerable consumers. Scotland’s Citizens Advice network regularly deals with clients who are impacted by a lack of regard to consumer outcomes or who fall victim to poor service design.

We believe that a consumer duty will strengthen consumer protection from unintended consequences resulting from public authority decision-making. It is essential that a consumer duty results in meaningful improvements in the consumer journey and achieves positive outcomes for public authority service users.

This year the eyes of the world will be upon Glasgow for COP26, as parties and delegates try to accelerate action on climate change. Citizens Advice Scotland supports Net Zero and we want to see a just transition that creates good quality jobs and doesn’t increase the burden on the poorest consumers. That Net Zero must also be tangible and accessible to the poorest consumers is a theme that has run through much of our policy and research work in the run-up to COP26, highlights of which are set out in this document.

The day-to-day activities of citizens are becoming increasingly dependent on their ability to use telecommunications services, such as mobile phones, broadband or landlines. The COVID-19 pandemic has highlighted the essential nature of online connectivity and access to internet data, with many people relying on internet access for working from home, staying informed or interacting with welfare services.

Executive Summary

CAS generally supports the measures proposed by Ofcom. In summary:

• The voluntary measures to support consumers introduced by providers during the outset of the COVID-19 pandemic were welcomed by CAS, as an effective response that has assisted in reducing consumer detriment over the past year.
• With consumers facing potential economic uncertainty as furlough and support schemes taper and Universal Credit uplifts look likely to be reversed, we believe it is timely to reconsider whether the protections for people in debt or struggling to pay remain appropriate, or whether there is a case for strengthening them.
• CAS supports measures which allow consumers in debt or at risk of disconnection to be treated fairly and have every opportunity to resolve these issues before disconnection takes place or service restrictions are imposed.
• CAS welcomes proposals to improve how providers identify and communicate with vulnerable consumers.
• CAS agrees that there should be more consistency in the ways providers communicate regarding debt and the ways they seek to obtain payment from customers in debt.
• CAS would wish to see the Consumer Principles embedded within the development of future measures, guidance, and regulations.
• CAS remains concerned regarding affordability issues and would welcome an early engagement approach by providers which aims to prevent a build up of debt
• We believe that further work is required to encourage providers to not only provide but to actively encourage take up of social tariffs for consumers who may be at risk of falling into debt.

Scotland’s Citizens Advice Network is an essential community service that empowers people through our local bureaux and national services by providing free, confidential, and independent advice. We use people’s real-life experiences to influence policy and drive positive change. We are on the side of people in Scotland who need help, and we change lives for the better.

Citizens Advice Scotland are pleased to respond to the department of Business, Energy, and Industrial Strategy's consultation on Reforming Competition and Consumer Policy. CAS plays a significant role in the provision of consumer advice and advocacy in Scotland, and we recognise the significance of the proposed reforms for consumers. We welcome the UK Government’s focus on Consumer and Competition policy and the role it can play in promoting long-term economic development and consumer protection during the post pandemic recovery. 

Executive Summary

CAS welcomes the opportunity to respond to this consultation. We also welcome many of the proposed reforms, however it is essential that reform results in meaningful improvements in the consumer journey and achieves positive outcomes for consumers. We believe the consumer needs to be placed at the heart of consumer policy and would recommend that the consumer principles and the principle of “fairness by design” be used as an overarching guide to assess and inform consumer policy.

In relation to the detail of the proposed reforms CAS’s views are as follows:

• We support the granting of additional powers to the CMA but have mixed views on whether the CMA’s priorities should be informed by governmental direction.

• We wish to see a greater ability for regulators to respond to the differential impacts of competition across the devolved nations.

• We are of the view that these reforms provide an opportunity to further strengthen and enhance the function of the Consumer Protection Partnership to improve collaboration and responsiveness on consumer protection issues.

• We believe that further action is required to equip consumers with the skills and knowledge to participate in online markets safely; in this regard we support proposals to reform the use of subscription services.

• We wish to see reforms which make it easier for consumers to understand their rights and to take swifter, more effective action to enforce these rights.

• We believe there is a need for better education on consumer rights as well as a need for clearer information to be provided about Alternative Dispute Resolution (ADR) so that consumers understand what it is.

• We are of the view that the ADR landscape is overly cluttered and would support streamlining to provide for one consumer ADR provider in each sector. As a minimum, there should be a single branded entry point for people wishing to access ADR on consumer matters.

• We recommend that ADR providers should report to regulators on trends. This would close the feedback loop and help drive up standards across regulated industries by enabling regulators to take action to prevent consumer detriment.

• We would wish to see Competent Authorities play a role in setting and monitoring common standards across the sector, including in relation to how providers support vulnerable consumers.