PhonePayPlus publishes responses to latest consulatation

[mike99]

PhonepayPlus has today published the responses it has received to its public consultation 'Mobile Phone-paid Services & Their Marketing' which closed on 11 September. This consultation proposed a series of measures to protect the public from harm in the mobile premium content market.

PhonepayPlus received 27 responses to the consultation and will consider each of these carefully [that would be a first ], before issuing a statement later this year.

I've only read a few:

Executive summary of Zamano/O2/Opera AKA responses:

We should be allowed to continue stealing money from phone users just as we have always been able to!

[Slight oversimplification on my part here I admit, but only slight.]

Executive summary of ICO response:

We have never done anything in the past to enforce the 2003 Act and we are not going to do anything in the future.

[Again. a slight oversimplification on my part here I admit, but only slight.]

Executive summary of Dr Mike Ward response:

Please stop the PRS industry stealing from us.

Executive summary of MDA response:

We agree with Mike that you are a bit mixed up about "unsolicited" versus "promotions" versus "services" versus "reverse charged" - all separate, though interlocking, issues.

[mike99]

I've read a few more of these.

AIME basically says "There's no problem, just leave our members to carry on robbing and defrauding as usual.

Orange's response is more interesting. There's a certain amount of the same nonsense peddled by AIME, O2, Zamano etc, but some intelligent and detailed analyses of the "unsolicited" versus "promotions" versus "services" versus "reverse charged" issues and various other technical issues to do with "opt in".

Many make the point that is is inappropriate for PP+ to mandate specific mechanisms.

When the PRS companies argue this in relation to (say) the "STOP" mechanism - "We should be able to choose whatever subscription ending method we wish as long as we make it clear to the consumer." it is obvious that their motives are entirely ulterior.

When the PRS companies argue this in relation to (say) double opt in, they may have a point. What should it matter what the mechanism is (perhaps yet to be invented) as long as it is robust and verifiable?

This brings me on to a more general point. I think it is a big mistake (pretending for the moment that PP+ really wish to end PRS crime - a moot point of course) for PP+ to get dragged into too much detail. It was, for example, a big mistake for them to become embroiled in the IP v SP debate.

The network providers are not like the royal mail. They bill customers for services which they always deliver and sometime provide. PP+ should deal with them and only them and hold them responsible for everything. If O2 choose to do business with Zamano, that's their lookout not the O2 customers' - even if O2 allow Zamano to recruit "customers" themselves.

PP+ should simply instruct all NPs to allow us to opt out of all PRS.

If customers do opt in to PRS, PP+ should mandate all NPs to inform those customers what they are going to be paying and give them the opportunity to avoid paying anything BEFORE a service begins.

If there is any dispute between a customer and an NP about a service, the onus should be on the NP to prove that the customer asked for the service, they received the service, and the service was fit for purpose - PP+ could act as an ADR service in such cases.

The whole question of SPs and IPs, and the various technologies they use to deceive the public and confuse the issues, would then be for the NPs to worry about.

As soon as PRS crime started hitting NP profits, it would come to an abrupt end and PP+ would no longer have to worry about being one step ahead of the crooks - or (more realistically) two steps behind.

[silver]

it's already murky enough for the average consumer to understand what the heck they are letting themselves in for when they text something,. removing the universal (?) "STOP" or is it now "STOP ALL" can't possibly benefit the end user

[mike99]

it's already murky enough for the average consumer to understand what the heck they are letting themselves in for when they text something,. removing the universal (?) "STOP" or is it now "STOP ALL" can't possibly benefit the end user

Originally Posted by silver

Well, just to explain how murky things are ..... you can have more than one service on one number so "STOP ALL" is best if you wish to stop all of them - which you normally will. This of course begs the question as to how they know which service to stop when you simply text "STOP"; but since they often simply take no notice of either command, this is probably not a big issue.

Another complication is that WAP "services" work if a different way and the service providers argue "Why can't the user just click on the WAP site to stop the services instead of texting "STOP" to a shortcode?"

"Because you are a bunch of thieving robbing scum bags and if we give you any rope at all you will use it to try and hang us" I am tempted to reply; but instead I shall simply argue that it is best to have a simple single standard mechanism that everyone knows about.

[El Gringo]

Executive summary of Dr Mike Ward response:

Please stop the PRS industry stealing from us.

i take my hat off to that person