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A solid consumer landscape requires evidence-based policymaking

By Derek Mitchell, Chief Executive, Citizens Advice Scotland.

NB This article was first published in the Sunday Herald on 15/07/18.

Last week the Scottish Government launched a consultation on Consumer Scotland, a proposed new independent body dedicated to consumer interests.  

There is no doubt that consumers need someone to stand up for them. Whether it’s the food we eat, the water we drink, the energy and transport we use, the holidays we take or a variety of other commercial activities, we all consume goods and services on a daily basis.

There is therefore a need to ensure that the policies and decisions which impact on consumers are fair, and that vulnerable people are protected.

We are pleased the consultation recognises the value of the consumer work already done by Citizens Advice Scotland (CAS). Advising thousands of consumers every year across a variety of markets in all parts of Scotland enables us to gather huge amounts of data on the consumer experience in Scotland. We have used this evidence to play a key role in a number of successful consumer campaigns over the years, like the fight for a cap on payday loans, or support for those in funeral poverty.

In 2013 CAS also took on statutory responsibility for consumer advocacy and education. Blending these functions with the existing strengths of the CAB network – public trust, community reach, and case data - has enhanced the power of our consumer work. By combining real-life CAB case evidence with detailed new research we not only identify the problems consumers face, but also develop solutions to these and then advocate to get them adopted.

A good example is the problem of parcel surcharging. We first became aware of this issue through cases identified by our Highland CABs. We then built on this evidence by conducting further research, which identified the scale of the problem.  We are now working with delivery companies, governments and politicians to come up with solutions. And real progress is being made, including recent enforcement action by the Committee for Advertising Practice directed at companies who make misleading delivery claims.

This is a prominent example, but it is far from an isolated one. After seeing CAB network cases about problems with district heating, we researched that market and the Scottish Government is now taking forward several of our evidence-based recommendations to protect these consumers.

We have also worked to help the Scottish Government devise home energy efficiency programmes and to re-define fuel poverty. Meanwhile our research has helped lead to bus services being a key part of the recent Transport Bill, and to the launch of a specialist data hub for consumers of private water supplies.

So on a variety of issues, the virtuous circle of the evidence we have from CAB clients, plus our more detailed research and our professional advocacy, has put the fight for consumer rights at the heart of everything we do.

Consumer Scotland could complement and build on that work. For example placing a duty on public authorities to consider the impacts on consumers of their policies or decisions, as proposed in the Scottish Government’s consultation, would certainly be a positive step.

So we look forward to engaging with the government and others to discuss this further. The objective must be to ensure that Scotland has the best possible legislative and regulatory landscape for consumers.

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