Response to Ofgem consultation on networks’ Complaints Handling Regulations
Overall, we support Ofgem’s suggestion to remove the Complaints Handling Standard regulation 10(3), ie to relieve Distribution Network Operators (DNOs) and Gas Transporters (GTs) of the duty to annually inform all of their domestic customers (most likely by mail) of the existence of their complaints handling procedure. Consumers are generally less aware of who their DNO or GT is, as there are fewer reasons to get in touch with them compared with their supplier. Several incentives and regulations do remain in place for DNOs and GTs to reach all of their customers, including vulnerable consumers, and inform them of their complaints handling procedures. Importantly, the cost of sending out mail to every household will ultimately be borne by the consumer.
Even though we agree with the proposed change to regulation, we have concerns about the accessibility and quality of complaints handling procedures once consumers do find they need to make a complaint. In January 2017 we compared the websites of all DNOs and GTs and found that:
complaints handling procedures are not always in a “clear and prominent location” on the website, but sometimes require many clicks or the use of the search engine function to be found;
some DNOs and GTs have their full procedure written down on their website; others only offer the contact details of their internal complaints line and refer to the full procedure in a downloadable PDF file;
most do refer to the OS:E; some refer to Age UK or Citizens Advice but partially the information provided is outdated. For example one DNO refers to Consumer Direct (from which Citizens Advice Consumer Service took over in 2012), another to Consumer Futures (which was renamed in 2013).
These findings give rise to concerns around the accessibility of complaints handling procedures through DNO and GT websites, and the accuracy and completeness of their content.
Drawing on our work with energy suppliers, we propose that networks should be given better guidance to know what is considered good practice and what they can practically do to help their customers find the help and information they need. We would welcome the development of a guidance document with standardised text for networks’ complaints handling procedures to ensure that all customers receive the same detailed and correct information about sources of advice and redress. This should be developed by networks in collaboration with industry stakeholders such as the Energy Networks Association and Citizens Advice.