Thursday, 2 October 2014

Slower broadband migrations and more slamming

The way broadband migrations work is changing next year.

The main changes are that they will be slower, and there is much more risk of migrations happening without agreement (slamming).

The existing way means getting a migration authorisation code (MAC) from the losing provider, and giving it to the gaining provider with your order. The gaining provider can validate the MAC, phone number and postcode and place an order in to a carrier to migrate the service over. It takes 5 working days (annoyingly), though with 20CN it seems to be instant now.

The new way is that the customer contacts the gaining provider to take over the line. The only information is telephone number and postcode, so easy for someone else to make the request, no real check that the line actually belongs to the person making the request. The gaining provider places an order with the carrier, and the losing provider gets a notification. The losing provider notifies their customer. The customer can cancel/reject the order. It then takes 10 days now, so slower.

Now, the old way does have rules - the main one is that the losing provider has to provide a MAC within 5 days and not withhold for commercial reasons. This is one of the common issues - ISPs taking too long. The other issue is the losing provider will also use this as a chance for retention which can be annoying.

The new system has rules too. When the losing provider gets notice, they have to advise their customer (by letter normally, but looks like we are OK with email). They are not meant to call and try retention. Of course, you can see that they will just happen to be sending a promotional email or posting or even call at the time... Of course they won't accidentally cancel the migration will they. Of course they will be 100% efficient sending the notice, sending to right place, and sending in time, to avoid slamming. Of course customers will not ignore the notice assuming it is junk, and suffer from slamming...

There are some other quirks which relate to monitoring how this all works and fixing issues if it goes wrong. All resellers have to have a reseller ID (RID) so it is possible to identify who placed orders. But this means defining a reseller. If you simply re-sell a broadband line, then fine. But what of someone selling, say, a point of sale system. They are not selling a phone line or broadband, they are buying these for their use to provide the point of sale system. So who is the customer for the broadband, and is there a reseller? Of course, from our point of view it is complex, as we don't know why our customer is ordering - we have no idea if they are a reseller of the broadband, an end user of it, a customer that is using it as some non re-sell service, or what. We don't know if we should ask for a RID with the order or not. The best we can do is have the option to enter a RID on the order form, but that will confuse people and get mistyped, and so on.

This does not come in until next year, but it has made us ponder some of the logic for migrates already. The process is basically the same for phone lines now, and we often see incorrect take-over requests coming in and contacting the end user to confirm they asked for it. We have issues where our customer may be an IT company (like the point of sale example), and the end user tries to take over a line. They are not the customer for the line, so that has to be rejected. It is hassle. But we have things like our Office::1 package - the phone lines for that are installed by us simply as bearers for the broadband lines which are part of a complete package which offers high availability internet and even includes a mobile dongle as backup. Who is the "customer" for the phone lines there? We don't itemise that on the invoice. Arguably we are the customer, as we buy them solely for the broadband service. Given that nobody else (as far as we know) offers the Office::1 package, do we have to even allow migration of the service? Migrating any part (phone or broadband or mobile) would break the service. What would happen if we ran an IT company that bought the components for Office::1 as the end customer, and used them to provide the Office::1 service to their customer? Who has a right to migrate that? I do get the feeling that OFCOM only thing of the simple cases.

How would I have done it? I suspect I would have made the MAC a fixed (rather than dynamic with 30 day expiry) key that has to be included on every bill. That is easy to police rather than waiting for people to try and get a MAC and finding an ISP is slow. Then we still use a MAC as we do now, and the migrate could be instant even. A new MAC on each change of provider. It avoids annoying retention calls as there is no notice that the MAC is requested/used. It avoids slamming as the bill holder is the only one with the MAC. It would mean almost no change to the existing system. I am pretty sure I suggested this when they consulted. Oh well.

23 comments:

  1. As a victim of slamming (by a very unapologetic T...T...) I don't think the current system or the proposed one are robust enough. Printing a MAC on every bill means anyone in a household or org could cause trouble, as if posite doesnt' dump enough bills in the local bins or random blocks of flats already. There should be a way for the key contact or bill payer to get a MAC via a trusted authentication and no way for sneaky slamming - and punish the slammers hard instead of the current Ofcom tut tut.

    I see the current 'Ed (sorry) of Ofcom is off, so a new boy will have new rules anyway.

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  2. Would it be within the rules to ask customers if they wish to sign up to a slam prevention service? I for one would happily give you permission to call and check if I actually wanted to cancel my service.

    Anything rather then go to BT….

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    1. Not sure the rules allow a call - but interesting idea - a bit like "locking" domains - maybe an optional service to reject all migrate requests automatically if "locked". I'll have to ask OFCOM.

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    2. +1 on the locking idea. This should be a standard thing, locked and requires confirmation.

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    3. I rather like the locking idea. Don't see why you shouldn't accept instructions from customers to reject migrations.

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    4. The only issue would be if the broadband subscriber didn't 'own' the line - ie Company provides broadband for employee on employee's line.

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    5. In that case who should be entitled to "switch" the line? If the employer is the "customer" they would get the notice of take over and they could say "no, we did not ask for a switch", so no different to them pre-setting a "lock".

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    6. Another yes here to the locking idea, basically a standing instruction to A&A to reject migrations. You could have the instruction expire requiring renewal.

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    7. I guess whoever can cease the line the one that's the owner. A ceased line would terminate the service, right?

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    8. Well, that adds to the complexity - the "customer" for the PSTN has ultimate control for ceasing, but may be different to the "customer" for the broadband who has control to cease broadband or migrate it. And the "end user" could be neither of those!

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  3. Very interesting. We pretty much only sell bonded internet connections, which again are a service that includes CPEs, central servers, transit, and circuits, but in a discrete product. We very much comply with the MAC rules as they are, but we do on occasion get asked to migrate the entire connection, which of course we can't!
    I too am concerned with the new rules, and have been since they were drafted, although I missed the opportunity originally to be involved in the consultation (not that having your say guarantees anything of course).
    I agree, it's going to mean more slamming, and all we can do as a responsible provider is act to the letter and the spirit of the rules, if only to distinguish ourselves in some way from the lesser providers out there who will do anything.

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  4. If someone does try to slam you, can you take them to ADR? And could you take them even if you managed to catch the slamming in time to get it cancelled?

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    1. Naturally, provided there's a dispute of course.

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  5. I don't understand how slamming happens. Can someone explain with a worked example please.

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    1. Well, there is usually some contact, a junk call from another ISP saying how good their service is, and without you actually agreeing to switch to them they get enough info to switch the service. In practice all the need is your ADSL line number which is usually the phone number they have called - what they need is enough to bill you such as name and address, but they may have that from marketing stuff anyway. They get the service switched, and even have their service allow any login so it "just works". If it was a simple single dynamic IP and NAT before and carries on as such then you don't even notice, but start getting bills from new provider.

      (Yes, they need phone number and postcode, but they can get postcode from the number, and anyway if they have address for billing then they have the postcode anyway).

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    2. Thinking about it, with realms, they would need a login change, so maybe they post a replacement router as well.

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    3. Mind you, if switching to another carrier, or if they are the other carrier, then the login issue may not exist.

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    4. My understanding was that every ISP had their own backend auth system (obviously you would know this) so unless you were swapping between two resellers of the same ISP you would have to have a new router.

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    5. On BT links it will direct using the realm (after @) to the ISP so that would change, but on others it may not. The ISP itself need not care what is in the auth, and indeed many do not, using the circuit ID to identify the line.

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    6. Switching someone's broadband service without them agreeing to it? Surely that's illegal, not to mention massively immoral. I don't understand why any company that does that is still in business, why haven't they been sued into bankruptcy by the regulators or forced out of business?

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    7. Well, obviously it can happen by mistake, and they can say that you agreed to it in the call, and so on. I believe it is more common on phone lines, which makes sense given equipment config and login issues for broadband.

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    8. Switching the office broadband+phone was surprisingly - perhaps worryingly - easy: while Sky dragged their heels, ignoring several MAC requests (as well as requests for VAT receipts), switching both phone and ADSL together to a TalkTalk bundle just required placing an order with TalkTalk.

      On the bright side, there was at least a warning in time to prevent it had the transfer been unauthorised - as long as we were watching the mail closely enough. An unscrupulous salesman could easily slam neighbours by timing it so they're on holiday when the transfer warning arrives, then they get home too late to prevent it.

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  6. I am going for another plus one on the locking idea, it makes A&A look even better, if that's possible.

    I have the opinion that ofcom are a bunch of corrupt idiots, everything they do seems to make life worse for both providers (except the huge bad ones) and customers alike!

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