Regulatory Best Practice

AIME promotes the principle of co-regulation with industry and regulatory bodies co-operating to agree and apply responsible standards to premium charged services accounted using the consumer’s telephone bill.

AIME’s membership applies the philosophy that consumers who are accurately and openly informed of the nature, content and cost of participation in an interactive service experience are perfectly placed to exercise their freedom of choice and thereby enjoy the most effective form of consumer protection.

Examples of industry initiatives undertaken by AIME are listed below.

Regulatory Process

Since January 2010 AIME has been working collaboratively with PhonepayPlus towards a forward thinking regulatory framework that supports industry innovation, investment and growth. This has been broken into the following four areas for development:

• Structure & Legality
• Industry Confidence
• Converged Media Services (Future Technology)
• SLAs (Including KPIs)

Following member feedback the issues currently being addressed include:

• Categorisation of complaints (Triage process)
• Use of informal procedure
• Publication of Emergency Procedure
• Length and process of investigations
• Adjudications & Sanctions
• Reviews & Appeals

PhonepayPlus 12th Code of Practice - Consultation Response

Following extensive communications with members AIME submitted its response to the PhonepayPlus consultation on the new 12th Code of Practice in July 2010. Members strategic concerns included:

• Coping with change - PhonepayPlus cultural change, transition from 11th to 12th Code
• Regulatory Process
• Regulatory Cost
• Objective Compliance Assessments - compliance advice, subjectivity & interpretation
• Proportionate Liability
• Due Diligence

AIME also submitted feedback to the PhonepayPlus 12th Code Guidance Consultation - over 50% of which was implemented

AIME Best Practice Guides

To promote Industry self-regulation and share experience and knowledge, AIME has worked with its members to produce the following Best Practice Guides:

• Voice Services Best Practice Guide
• Special Requirements for Premium Rate Print Advertsing Guide Aug 2011
• Best Practice Guide for the provision of Live Psychic TV Services Sept 2010
• Issue 2 Best Practice Code for Mobile Terminating Providers launched March 2010
• Issue 1 Best Practice Code for Mobile Terminating Providers launched June 2009
• Best Practice Guidelines for Participation TV Services using Mobile Shortcode Text and Voice Services launched October 2008
• Interactive Broadcast Services Guide launched May 2008

AIME's Best Practice Gudies are available to download here

Merchant Promoter Registration Scheme

• AIME originated a proposal for a Service Promoter registration scheme designed to distribute responsibility for compliant services more fairly and accurately and particularly closer to the point of sale
• The proposal was originally submitted in 2004 and again to ILP and Ofcom in 2007
• Ofcom and PhonepayPlus included an Industry Registration scheme as part of their PRS scope review and the proposed 12th Code respectively
• An Industry Registration Scheme was implemented by PhonepayPlus as part of the 12th Code 1st September 2011

Industry Value Chain and Descriptors

• The term of Service Provider used in PhonepayPlus 11th Code of Practice actually means the Aggregator Technical Facilitator who, according to the Code, takes responsibility for all aspects of services handled by their platforms across their network. Consumers have no relationship with Aggregator
• This has in the past led to regulatory anomalies e.g. prior permission enforced at aggregator, not promoter
• In 2009 AIME created simplified Industry Value Chain & Descriptors document prior to the 12th Code consultation
• Current PhonepayPlus 12th code uses the terms Level 1 & Level 2 providers

Customer Care incl. Number Checker & Complaints Handling

• AIME member research found PhonepayPlus number checker accuracy to be less than acceptable and with incomplete content
• AIME tabled at ILP and working group has been formed May 2009
• PhonepayPlus looking at customer care processes again based on input from AIME board
• AIME continue to lobby PhonepayPlus on importance to Industry of an accurate number checker for customer care and centralised Industry database