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The ethics of non geographic numbers and information, connection and/or signposting services

ESA ICSS non geographic
ESA ICSS example

Information, Connection and/or Sign Posting Services (known as “ICSS”, subtly different from the topical ISIS, though many will put them into a similar “scourge” pigeon hole) at their core are simply a number translation service on non geographic numbers overlaid with advertising.

The idea is that ICSS providers make it easy for you to locate the phone number you are looking for, or, to put it another way, they are better at Search Engine Optimisation that the companies you may be looking for. In one sense, it’s a Directory Enquiries service via Google as opposed to dudes with moustaches.

But like all things, they can be abused. If you Google “British Gas Customer Services”, thankfully you’ll see official bona fide entries at the top, with their plethora of freephone numbers. A few entries further down is this;

British Gas ICSS
British Gas ICSS

 

What’s that? An 0844 number at 5ppm (plus call set up fee) from a BT Landline and probably more from mobiles? It’ll translate through to their 0800 numbers, netting the value chain for this service circa 5 pence per minute margin to share around between them. There are two sides the argument on the ethics of this – be it paying a premium to reduce your notional search costs and revel in your own laziness (ultimately this is no different to why I employ a cleaner) versus exploitation of the naive.

I don’t take a view on that here; and nor did PhonepayPlus when they intervened in this market on 09 numbers and 0871 numbers (6 pence per minute and higher) last year. Essentially, they laid down the detailed and comprehensive ground rules to ensure that such services were only used by people on the left hand side of the ethical spectrum I outlined before.

But 084 numbers aren’t included in the Premium Rate Services Definition and aren’t covered by the Code of Conduct and all the requirements therein. That means they are more open to being used on the right hand side of that spectrum. And that’s when I start to get concerned. A few years ago, the Department for Work and Pensions entered into negotiations with major mobile networks to make their freephone numbers genuinely free to their users. Ofcom’s own research says that around a quarter of socioeconomic group DE households (the most vulnerable) are mobile only which makes their move, surprisingly for government, well targeted.

But if you Google “ESA contact number” as in Employment Support Allowance, this is what you get

ESA ICSS example
ESA ICSS example

 

Another 5 pence per minute 084 number, an ICSS hidden in a void of regulatory oversight, which could be argued to be exploiting the most vulnerable and least able to pay (noting that historically some mobile phone operators have charged upto 75 pence per minute for an 084 call, with many tariffs still at 40 pence per minute). Is this ethical? I’ll leave that for you to reach your own personal conclusions, but in the mean time, I hope to raise awareness of the issue after someone I know was caught out.

Peter Farmer

By Peter Farmer

Peter Farmer is the Commercial and Regulatory Manager at Gamma, writing here on Trefor.Net in a personal capacity. He sits with Tref on the Internet Telephony Service Providers' Association Council and is their Chair of the Regulatory Affairs Committee.

Peter's experience covers consultation responses and disputes with Ofcom, lobbying government (UK and European) on telecommunications matters, litigations at the Competition Appeal Tribunal, Court of Appeal and Supreme Court. Despite all of that, and having three Masters degrees, his main job is actually being a Personal Assistant to his two cats.