Paying Fair Guidelines to support all customers

Paying Fair Guidelines to support all customers

This page sets out our principles and minimum expectations for the services that water companies deliver to support all residential customers. This is part of our Paying Fair Guidelines.  

1. Help make it easy for all customers to pay their water bill

Companies should seek to understand what will make it easier for different groups of customers to pay. This includes providing a reasonable range of payment frequencies and methods, for all customers. The entire range of options should be properly and widely advertised to ensure that customers can select the arrangement which best suits their circumstances. 

Ensure information about customers is correct, up to date and is used 

1.1 Have robust systems and procedures for establishing who is moving into and out of properties being supplied – and record accurate information about the occupant and account.  

1.2 Have robust systems and procedures for contacting customers and  recording and recalling contacts with them. This should include maintaining up to date customer contact details with at least two methods of contact (where available) – and the customer’s preferred contact times.  

1.3 Where properties are rented, companies should: 

  • work with landlords – including make them aware of the Landlord and Tenant Address Portal (LTAP) – to establish tenant details, where tenants are expected to pay water charges; 
  • explore data sharing arrangements to better understand which properties are rented; and  
  • accept evidence provided by tenants to show who is responsible for paying bills. 

1.4 Regularly quality assure their people, procedures and systems use customer information correctly. They should: 

  • use customer contacts and feedback; 
  • correct any errors from happening again; and  
  • find ways to improve the quality of consumption, customer and asset data to improve the accuracy and helpfulness of bills and other communications to customers.   

Make payments possible in person from different locations 

1.5 Review their network of payment locations at least once every two years to make sure that all customers have reasonable access to make payments. Companies will need to take account of the number and geographical distribution of locations and the demographic and social profile of their region. The network of available locations at which the customer can pay must accommodate both rural and urban customers. 

1.6 Review the charges, if any, for making payments at the network of locations offered and offer a reasonable range of locations at which customers can make payments free of charge. This should include frequent payments, in cash, for customers who would benefit from paying weekly or fortnightly.  

1.7 If there is a charge then companies should be transparent to customers regarding what the charges for making cash payments are and which location options will make a charge. 

Offer flexible payment and billing frequencies to match customers’ circumstances 

1.8 Offer all customers at least the following payment frequencies: 

  • fortnightly/weekly. 
  • monthly; and 
  • annual/half yearly/quarterly as appropriate on receipt of the bill.

1.9 Where possible, be flexible about the date on which direct debits or standing orders are taken. 

1.10 Offer or accept non-standard flexible payment arrangements so customers have the ability to make payments when they need and want to in ways that work for them. This is important for customers with irregular incomes – such as those in ‘gig’ employment or on zero hours contracts.  

1.11 Offer or accept more frequent billing frequencies to encourage customers to pay and avoid unexpected and unaffordable increases in their bills (‘bill shock’). 

1.12 Make information about what customers owe accessible to them in a variety of ways, such as online, by telephone or other methods.   

Offer choice and availability of payment methods to suit customers’ needs and preferences  

1.13 Offer instalment payments by at least the following methods 

  • mobile phone or mobile phone app;  
  • cheque/debit card; 
  • cash; 
  • direct debit;  
  • standing order; and 
  • payment booklet / card. 

1.14 Review payment methods periodically so that any advances in technology which widen the range of options offered are considered.  

Encourage customers to use digital payment methods if they can 

1.15 Encourage customers to use digital payment methods and support them to use them by providing guidance. 

Advertise payment options to all customers in a variety of formats, languages and for those with specific communication needs 

1.16 Advertise the available payment options within billing communications in a variety of formats, languages and for those with specific communication needs so that the customer can choose the option which bests suits their circumstances.  

1.17 Companies should clearly set out the payment methods not incurring a transaction charge, and the option to pay on a frequent basis and, where possible, tailor these to individual customers’ needs.  

1.18 Companies should also take advantage of further opportunities to draw customers’ attention to the range of options available.  

1.19 Where the company is offering new payment methods, these should be advertised in billing communications at the earliest opportunity. 

1.20 Use messages on envelopes to raise awareness of financial support to customers. 

Use customer bills and payment transactions to improve customer understanding of options 

1.21 Where companies become aware that a different tariff, payment level, location, frequency or method may suit a customer better than the one they currently use, they should proactively offer the option.  

1.22 Encourage customers to pay in bitesize instalments and offer more regular account balances to customers, particularly those with low and variable incomes. 

Respond efficiently to customer requests to change payment arrangements 

1.23 Where a customer wishes to switch payment level, location, method or frequency, the company should try to accommodate any reasonable request as quickly as possible. 

Seek better ways to engage with different customers 

1.24 Make information about services and bills more understandable for all customers – and make it available in a way that best meets their needs. This includes, for example, considering ways to: 

  • improve customer understanding of bills;  
  • help customers check bills are correct; and 
  • better explain in advance why the company is changing a customer’s direct debit, how it has calculated the new level of payment and how the customer can change the amount or spread payment.   

1.25 Work with other bodies – to reach customers in vulnerable circumstances, those in debt or at risk of falling into debt, particularly those that: 

  • may find it harder to understand information shared by water companies as a result of their vulnerability; or  
  • do not respond well to other efforts by the water company to directly communicate with them. Other bodies might include other companies, charities, local authorities, health and social care or other third party customer advice and authorised debt advice organisations. 

Show customers how their views on billing, payment and support are encouraging improvements to services 

1.26 Use insight and intelligence to regularly monitor customer satisfaction with billing, payment, support and debt services, identify issues and target areas for improvement. This should include satisfaction among customers in vulnerable circumstances. Insights and intelligence might include:  

  • commissioning customer research; 
  • identifying issues highlighted by customers in complaints with billing and charging; 
  • testing customer understanding of information provided to them;  
  • using data analytics from websites or apps on how easy or difficult it is for customers to find information about billing, payment and support; 
  • extracting voice analytics from telephone calls on how easy or difficult customers find it to understand their bills and access support;  
  • success rates of payment plans for customers in debt; and  
  • how the company performs on bills, payment and help compared with other service providers in other sectors that customers may use.   

1.27 Work in partnership with consumer and debt advice organisations to enhance understanding of different types of customer, best practice – and gather views on company proposals for improvements. 

1.28 Show customers how their views on payment, help and debt are encouraging improvements to services. Companies will need to make sure any changes they make are inclusive by design (see expectation 1.29). Any changes to policies should also be reflected in their code of practice on debt recovery or other core customer information they are required to publish under condition G of their licence. 

Make payment, help and debt services inclusive by design 

1.29 Adopt an inclusive approach to designing products and services so they anticipate and address the needs of all customers, particularly accessibility for those in vulnerable circumstances, and reflect key guidance such as ‘Inclusive design in essential services’ principles published by Fair by Design and the Money Advice Trust – or an equivalent publication that replaces it. For example, user-test new approaches or systems with diverse consumers, including vulnerable consumers. Companies should apply Inclusive design principles to different groups of customers, including customers: 

  • eligible for help 
  • that have their accounts managed by third parties 
  • in debt; and  
  • facing debt enforcement action. 

Consider how customers’ ability to pay affects their service experience 

1.30 Use and recognise the Money and Pensions Service Standard Financial Statement (SFS) as a consistent means of establishing customer’s ability to pay. Where companies do quick or initial affordability checks with customers, these should also be consistent with the approach in the SFS. Companies should be transparent and publish the details of the methodology they use alongside their code of practice on debt recovery to allow other companies, customer and debt advice organisations to understand the approach they use. Companies should use best practice to make their assessments consistent with other companies.  

1.31 Review how customers’ ability to pay affects their service experiences (for example, when chasing debt, or determining how long to spread repayment following payment breaks) and use these insights to improve outcomes for customers. Companies should be mindful of the impact that vulnerability can have on customers’ ability to pay. 

Use best practice when using credit reference agencies 

1.32 Use credit reference agency data to help identify customers that: 

  • may qualify for support;  
  • be at risk of falling into debt; and  
  • can afford to pay and can be contacted for payment.  

1.33 Communicate to customers: 

  • how and why the company uses credit reference agencies; 
  • the benefits and safeguards for customers; and  
  • what customers can do if they think companies have incorrectly negatively impacted their credit score.  

1.34 Use credit reference agencies carefully to avoid negatively impacting customers credit scores through errors by the company. Where companies make errors they should correct them immediately.  

1.35 Identify and use best practice when using credit reference agencies. 

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