This page sets out how to use our Paying Fair Guidelines.
Our Paying Fair guidelines set out our minimum expectations of the services that water companies deliver to residential customers and the way they are delivered – and our overall principles to guide each company’s actions.
Water companies should deliver all our expectations in full. Companies can still comply with our guidelines and take different approaches to our expectations where they have evidence that allows them to:
- accurately identify that a customer will not pay rather than cannot pay; or
- show why an alternative approach is more suitable because of the customer’s circumstances and delivers a better result for the customer.
In these situations, companies must clearly demonstrate their reason for departing from the guidelines – and be able to provide evidence when asked. We expect any other approaches companies take to be consistent with our principles.
Our approach is focused on the outcomes that water companies are delivering for customers rather than the precise means by which those outcomes are achieved. It is imperative for all companies to own and address the needs of their customers.
Our guidelines do not include every aspect of companies’ service delivery. We set out some further areas where we would expect companies to do the right thing for their customers.
Our guidelines balance protecting individual customers and allowing companies to collect money they are owed efficiently. All customers in England and Wales pay for services through their water bills and so the cost of collecting debt – or failing to collect debt (‘bad debt’) – is spread amongst the rest of customers. So, it is in everyone’s best interest that companies bill and recover debts efficiently.
Delivering good customer care and service through customer focus, best practice and good quality data
We expect water companies to strive for best practice service for all customers while recognising that good outcomes will look different for different customers. These are essential pre-conditions for good customer service but are especially important to achieve good outcomes for vulnerable customers, including where customers are in debt or struggling to pay.
Good customer care and service are underpinned by robust records and systems, as well as transparent procedures that are based on timely and accurate customer data. This is important for:
- developing and maintaining relationships with customers;
- identifying customers that may need support at an early stage;
- checking account information;
- checking correct billing information;
- making sure customers – particularly those that move – are not incorrectly pursued for debts or have debt action taken against them without their knowledge;
- debt management purposes; and
- demonstrating compliance with applicable data protection law.
Companies should regularly quality assure their people, procedures and systems so that they 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.
Putting things right quickly where they go wrong
Where customers have a dispute about billing, payments or any other issue covered by our guidelines, we expect companies to prioritise resolving these matters quickly, pragmatically and in a way that treats customers fairly. Companies should identify if any changes to their approach – including communications and contacts with the customer, systems, policies, and culture – could have avoided the dispute and any similar disputes from happening – and (where relevant) change their approach for future.
Complying with all legal requirements
Finally, we expect water companies to comply with other legal and regulatory requirements which apply at the relevant time. This includes:
- the Equality Act 2010 ; and
- ‘The Debt Respite Scheme (Breathing Space Moratorium and Mental Health Crisis Moratorium) (England and Wales) Regulations 2020’; and
In engaging with different customer groups, water companies should also check their policies, approaches and systems are consistent with our:
- customer information principles;
- ‘PR24 and Beyond: Creating tomorrow, together. Appendix – Reflecting customers’ preferences‘ (May 2021); and
- any future development of that policy.
This is not a complete or exhaustive list and water companies will need to consider for themselves how they comply with all their legal and regulatory obligations. We would also expect companies to anticipate new requirements – and plan and deliver changes to their approach ahead of time.
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