This week, a panel of TELUS marketing, regulatory and legal representatives appeared before the CRTC in its ongoing proceeding to establish a mandatory code for wireless services. Our message was that we support the draft code and what the CRTC is trying to accomplish. In fact, TELUS has already addressed many of the issues being raised, going back to the introduction of Clear and Simple wireless plans in 2009 and many changes we have made since.
But, we also pointed out a few places where the regulator should keep the focus on consumers and avoid unnecessarily detailed rules, lest they risk actually removing customer choice.
We’re on the same page as the CRTC when it comes to making sure consumers have the information they need to use their services effectively and avoid unexpected charges. Since making a number of changes under the Customers First banner, we have seen our complaint levels drop. We are not perfect, but we are making positive changes, and we have more changes in the works.
Our concern about some of the proposals in the CRTC’s draft code is that we might have to “take our foot off the gas” on some of those changes and divert resources to costly systems changes that we know would have relatively low impact or, in some cases, actually harm consumers’ interests.
In this post, we take some of the higher-profile issues in the proceeding and summarize what the TELUS team said in response to the Commission’s questions. If there are other questions that you would like to see our answer to, please ask them.
Changes to contracts
- Our nationwide policy today is that if we were to make a change that increases our customer’s obligations or reduces ours, the customer can “walk away” without paying any cancellation fees or device balance. Like any service business, from time to time we need to change general terms of service – sometimes in response to regulatory or policy changes – and sometimes rates for services that are not the subject of term commitments. When we do so, we give customers 30 days’ advance notice and if they have concerns, we try to work with them to find the solution that works best for them.
- In response to questions about why we lock phones in the first place, our representatives explained that it’s to protect us from fraud (and the costs that result).
- When the newest devices come out, they are in high demand. We want to be sure that as many of our customers as possible can get them. If we had to sell unlocked devices, “scalpers” could buy the devices from us and turn around and sell them at a much higher price (either in Canada or other countries). No carrier wants its limited supply of a hot new device to be activated on one of its competitors’ networks.
- TELUS supports the needs of those of our customers who want to use a local SIM card when they travel internationally to save on roaming costs. We allow unlocking after 90 days, and on a cost-recovery basis. That’s the right balance, we believe. Our unlocking policy is here. It’s important to remember that not all phones work on all networks – you should check first.
Three-year contracts and cancellation fees
- If there’s one thing that customers hate, it’s having to pay an arbitrary cancellation fee when they need to get out of a term contract.
- That’s why TELUS did away with cancellation fees in 2010 and replaced them with our Device Balance approach, which has enabled our Anytime Upgrades and our more recent Trade-In Program. Since doing so, we’ve seen a strong preference for three-year contract terms from our customers – they remain the most popular choice, even when customers can buy a phone outright and go month-to-month with no obligation. At the same time, we’ve also seen complaints about cancellation fees drop, because customers like how transparent and friendly our approach is. This eliminates the need to regulate the length of term contracts.
- With the Device Balance approach, customers can get out of a term contract whenever they want, and they don’t even need to sign a multi-year contract in the first place. Consumers have many options for getting a new device, including buying it outright and financing it on their own, getting one with a smaller up-front payment on a two or three-year term contract with TELUS, and buying one used and going month-to-month for service.
- As the Commission itself has noted, three-year contracts are an option that many consumers choose and therefore the code should not take that option away.
Spending caps on post-paid plans
- TELUS does not support the proposal for a general cap on usage-sensitive charges. The reality is that consumers who want a strict limit on what they spend on wireless services every month already have the option of pre-paid service, which gives them complete control over their monthly spending.
- For customers on post-paid plans, our view is that so long as their carrier is providing adequate notifications of when additional data or roaming charges might be incurred, and provides online and on-device ways to monitor usage, as we do, then there should be no need to impose spending caps on all services.
- One big issue with the proposed $50 spending cap is it’s just not high enough for most users. It’s very common for customers to go over $50 in optional charges in a month – but these are charges that they choose to incur for things like long distance calling, downloading applications, texting donations to a charity or paying for parking on their device. It would be a shame to make it harder for people to do these things. We ought to be encouraging mobile payment innovations, not stifling them.
“Bill shock” from international data roaming charges
- To help our customers protect themselves from big bills upon their return home from overseas travel, we do the following:
- As soon as a customer connects to a network outside Canada, we send them a free text message with the rates for voice, texts, and data use as well as information about how to block data roaming if they want.
- We send regular updates on data use, starting at just 1 megabyte.
- We block data usage at reasonable thresholds and ask the customer by text message to confirm that they want to continue data roaming and incurring additional charges.
- When they get home, we send another text message summarizing their out-of-country data usage.
- To achieve the right balance between being helpful and annoying, our international data blocks kick in at $200 and continue at various thresholds thereafter.
Status of provincial wireless regulation
- Telecommunications services are subject to exclusive federal legislative and regulatory jurisdiction. TELUS’ view is that once the CRTC has acted to regulate the aspects of consumer wireless service covered by the Code, “the field will have been occupied,” for constitutional purposes, and there will be no room for provincial regulation of wireless services.
- This doesn’t mean that the standard of consumer protection would go down. Rather, it would ensure that consumers across the country benefit from the same standards and carriers would be able to serve them more efficiently.
You can read TELUS’ opening remarks here. They close with our Customer Declaration, an open and honest commitment to customers:
TELUS’ Customer Declaration
We’re not perfect, but our employees are deeply motivated to consistently delight our customers. We know that getting better means making sure we’re listening to you.
That’s why we’re embracing new ideas that will make your TELUS experience better, everyday. We’re on a journey to build on your trust by being clear, helpful and dependable.
In other words, at TELUS, we put you first.