Each company will:
- provide information to customers which empowers them to secure the lowest possible bills and best possible service
- involve customers and representatives in preparing, changing and implementing its information provision approach
- consider its adherence to our information provision requirements each year and demonstrate this to Ofwat if required to do so
We will:
- provide the high-level information principles for companies to use – in addition to the obligations in their licences – to provide quality information to their customers
- apply a risk-based system for reviewing companies’ approaches to providing information to their customers, taking action to protect customers where appropriate
Information principles
We expect each company to make sure the information it provides its customers is consistent with its licence obligations and our information principles.
These principles, which complement each company’s existing licence obligations, describe what we regard as effective information provision. They capture the objectives of relevant legislation – such as the Equality Act 2010 – and Government guidance, such as that produced by the Department of the Environment, Transport and the Regions (DETR) to accompany the ’Water Industry Act 1999: Delivering the Government’s Objectives’.
Our principles are as follows.
- Accurate ‒ Each company should make sure the information it provides is correct by regularly reviewing it – for example, to make sure it is consistent with its charges scheme. Any updates should be shared with customers directly and with advice providers.
- Transparent ‒ Information should not be misleading. It needs to be unbiased and enable individual customers to make informed decisions.
- Clear ‒ Information should highlight key messages and direct customers to more detailed information.
- Accessible ‒ Each company should provide different information and use different communication channels to meet the needs and preferences of particular customer groups (‘customer segmentation’).
- Timely ‒ Companies should design and deliver information in a way that makes sure customers get the right information at the right time – for example, when a customer moves home.
- Customer-led ‒ Each company should actively seek its customers’ and their representatives’ views and feedback on the information it provides and how it provides it. It should respond to customer and customer representatives’ information needs.
Code of practice requirements
Companies’ licence obligations currently require them to submit to Ofwat a code of practice containing, as a minimum, specific information for customers. This information does not need to be packaged in the way indicated by the three licence conditions. Companies have freedom to design their code in a way that best meets customer needs and they must meet their information provision obligations in their licences having regard to our information principles.
Engaging with customers
Each company should use insights from its customers and customer representative bodies to design its code and the information it provides – and how it delivers it. This includes customers or representatives that may have particular expertise in how to effectively communicate with certain customer groups or on specific issues.
We will use the Consumer Council for Water’s (CCWater) views on how well companies are communicating with their customers and insights from other consumer bodies to inform our risk-based review of companies’ information provision.
Each company should also make its code available to its customers.
Sending codes to Ofwat
Companies are required to send us their code when they are producing one for the first time or when they change an existing code.
Reviewing the code and its implementation
We suggest that each company conducts yearly reviews of its code as a minimum. It should amend its approach as often as necessary to keep it compliant and in line with our expectations.
We suggest companies carry out their yearly review alongside their annual revisions of their customer charges. This will help companies keep their information accurate since changes to the charges scheme can be reflected in its customer information. This timing will also help with an effective and efficient consultation approach because each company already consults CCWater on its charges scheme. Companies need to consider how to communicate the content of policy documents like their charges schemes to their customers.
Companies will also want to review their information provision and consult with CCWater at other times of the year, for example, when there are significant changes that might impact their approach.
Risk-based review of information provision
When will we review companies’ information?
Each company will consider its compliance with our information provision requirements each year and be able to demonstrate that if required to do so. We have provided high-level information principles to support the obligations in companies’ licences to provide quality information to their customers.
We will adopt a risk-based approach to reviewing companies’ information provision. We will only review individual companies’ information provision approach where we have reliable intelligence that there are significant risks to customers. For example:
- if a company has a higher than average level of complaints and customers and their representatives alert us that critical information to help customers check and potentially lower their bills is not readily accessible
- if we receive intelligence that a number of the companies’ communications are inadequate on a particular issue – for example, if they do not make customers sufficiently aware of free supply pipe repair services while advertising insurance that covers these types of repairs
What we will do if we have any concerns?
When we conduct a review of a company’s or companies’ approach to information provision, we will:
- use our information principles to structure our investigation
- consider the contents of relevant companies’ codes
- require companies to demonstrate that their approach is compliant
This may include considering:
- the range of information they provide to their customers
- an up-to-date detailed communications plan
- how the company has taken account of feedback from customers, representatives and the Consumer Council for Water.
So each company should make sure this information is readily available on request.
We will publish the conclusions of our review on our website.
What action can we take?
We do not intend to actively approve codes. In accordance with each company’s licence obligations, if a company submits a revised code to us and we do not specify any changes to it within two months, it will be deemed that we approved it.
However, if we have any concerns about risks to customers caused by a company’s failure to comply with their obligations, we can require it to review its approach and make changes.
In the event of any company failing to take responsibility for meeting its customers’ information needs by failing to comply with its licence obligations or related statutory duties we may consider appropriate enforcement action.