New Institution - New Ombudsman: Commentary on DTI Consultation on Consumer Representation
- New Institution - New Ombudsman
- Regulator First - A No Brainer Relationship Choice
- The New Ombudsmodel - Inventing Your Own Complaints
The following article is in reference to the DTI consultation document Consultation on proposals to strengthen consumer representation.
Background Reading
The full consultation document (URN 06/682) can be downloaded from the DTI's web site (link below).
For a very brief outline - I have reproduced the Summary of Questions (section 3, pp 16-17) here.
PDF download from:
http://www.dti.gov.uk/consultations/consultation-1589.html)
It seems clear that we will soon see the creation of a single publicly-funded consumer advocacy body so the consultation is about a done deal. The consultation document does not contain a single reference to user or consumer views. Unsurprising perhaps since we are talking heavy duty institutional manoeuvres here of interest only to consumer policy wonks and employees of the organisations affected. The debate about value for money is brief. Cost figures are only discussed on one page with a heroically vague estimate for merger costs ranging between £7.1m and £19.4m.
Consumer Awareness - A 'how big is yours?' discussion
It is just a little ironic that all this discussion about the best way to represent the consumer voice does not include one single piece of data from the users/consumers themselves. I was surprised for example at the absence of such data in the discussion about the false god of consumer awareness - high = good, low= poor.
When will managements understand that general awareness of anything is on a need to know basis? Of course anyone with a life has no clue what Energywatch is/does/says UNTIL they have a problem and then they find out. I did research on Ombudsman awareness and while very few could trot out the name or whatever, they all assumed that such things existed and the detail could wait. Those who believed there was a Travel Ombudsman - trick question! - were going to be disappointed but they will find someone else.
The old advice was to keep this leaflet handy in your drawer. Well these days "handy" means "Google". Google in electricity complaints UK and Energywatch is the first listing.
Who needs awareness marketing to raise unprompted awareness from 0.5% to 2.1%? It is a "How Big Is Yours?" exercise and a ploy to get a bigger marketing budget. Management must factor in understanding of the role of timing in the 'need to know' moment in any discussion about awareness. We need other, better measures for the effectiveness of these bodies.
Code Words
Consultation connoisseurs will also appreciate the coded use of the adjective 'fragmented' (as in "consolidation of fragmented consumer representation") as shorthand for shambolic = bad, as opposed to centralised =good. Of course in other contexts, fragmented may be good because it equals 'diverse', 'local', 'pluralistic'. The vision of the single consumer voice/advocate has always been torpedoed by the fact that the consumer interest is not monolithic. We can express a single consumer interest only at a very high level of generality: for example the NCC consumer principles lay out e.g. Need for Information, Safety etc.
The other use of words I enjoyed was in Question 2 about persuading suppliers to raise their game where 'incentives' - usually denoting a carrot - is actually used to mean a stick - licence obligations to "secure improved standards". It's all getting a little Orwellian.
In or Out? Shake (Some of) It About
The consultation is also interesting for the bodies it does not bring under the Consumer Voice umbrella.
Watervoice or the Consumer Council for Water has a stay of execution to give it a chance to test out its new status and role. This leaves out the trendily re-branded Passenger Focus (the old Rail Passengers Council) - why? Is it because the focus is on the "slow boil" ( as in cooking frogs) re-nationalisation of the railways and nothing is allowed to interfere with that priority?
But perhaps the whole consumer representation consolidation exercise can be seen as a form of creeping re-nationalisation? Air travel is not there either. Different regulatory model? What about extensions of the principles of consumer representation on this model into the Health Service? Wouldn't this be a cost-effective solution for the expensively abandoned Commission for Public and Patient Involvement? Food - why not? Deirdre Hutton - longtime chair of the NCC - would be overjoyed I am sure to find herself back there.
The Consumers' Association - Alone in their Corner ?
What of the Consumers' Assocation or Which? Ltd. Even when the NCC and CA dominated the consumer landscape, they found agreement on any given issue a strain. Actually no, agreement on the line to be followed was much easier that deciding who should be the lead player. There was a certain amount of pushing and shoving to be acknowledged as the prime mover or architect of that policy.
Faced with the aggregrated power of the State consumer movement, will CA give up? Will the new structure have any room for them? Why should it? And even if such a space was on offer why should CA accept it? They have an opportunity here to stand out from the crowd - they will be in one corner and everyone else in the other.
Continued: Regulator First - A No Brainer Relationship Choice
