Special Assistance Schemes Review Water Industry Consumer Council for Water

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 1

Content

Page

2 Executive Summary

3 Why it is important we focus on this work

4 Key Findings

5 Recommendations – National strategic level

7 Recommendations – Company level

8 Core Assistance to be offered to consumers

9 Local Partnership Organisations

10 Background information on Ofwat Guidance to companies

17 Priority Services & other non-financial assistance in Energy

18 Annex 1 – CCWater Special Assistance Questionnaire

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 2

Executive Summary

In our Forward Work Programme 2016 – 2019 we have committed to “work with other organisations and

the industry to identify good practice for assisting consumers in vulnerable circumstances and press

companies to provide access to an inclusive service for all water consumers”.

As part of this work, we are focussing on the assistance companies offer consumers and how they make

their services easy to access for all. As the voice of the consumer, CCWater has an important role in

monitoring how well companies are acting on the Ofwat guidance regarding special assistance provision,

and that the assistance available is easily found and recognisable by consumers and advice agencies. To

inform our work, we carried out a desk based review of company websites and asked companies to

complete a questionnaire detailing the assistance they presently offer and where this is promoted to

consumers. This report contains our observations and recommendations.

We are aware that the topic of vulnerability and getting the right help to people who need it, is one that is

being considered by the UK Regulators Network, Water UK, and also that the National Audit Office is

presently conducting a Vulnerability Study. We hope both our national and company level

recommendations will help to contribute to the overarching aim of all aforementioned organisations and

secure more positive outcomes for consumers.

Next Steps

We will be following up this report with individual discussions with companies which will focus on their

response to the questionnaire and our observations from our desk based research. The aim is to help

facilitate good practice and collaborative working between companies.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 3

Why is it important we focus on this work?

Water companies have already made a good start in offering consumers a tailored service based on

individual needs, but more can be done.

Our Water Matters research 2015-20161 indicates that awareness of additional services offered by

companies has increased in England by +1% but has decreased in Wales by -1%. Significantly fewer

consumers in Wales are aware of the additional services (45%) compared to England (50%).

Companies reported to CCWater that 280,324 people were registered as receiving one or more special

assistance services in 2015-16. But this represents a small proportion of the people who could benefit

from the extra help available from water companies.

There are almost two million people in the UK living with sight loss. This figure includes those that have

uncorrected refractive error or cataract that may be reversed. This figure also includes around 360,000

people registered as blind or partially sighted who have severe and irreversible sight loss2.

There are more than 11 million people in the UK with some form of hearing loss. More than 900,000

people in the UK are severely or profoundly deaf3.

10% of the population are dyslexic; 4% severely so4.

In 2014 Welsh Health Survey, 12% of adults living in Wales had received treatment for mental health

problem. 1 in 4 people in England will experience a mental health problem in any given year5.

There are over 10 million disabled people in Britain. Of these, 5 million are over state pension age6.

During 2014-2015 an estimated total of 465,000 adults in England 7 received domiciliary homecare.

During 2015-2016 23,012 adults in Wales received domiciliary homecare.8

The statistics provided by national bodies demonstrate that water companies are not reaching enough of

the people who would benefit from the assistance available, and the water industry needs to do better.

1 Water Matters Report 2015-2016

2 http://www.rnib.org.uk/sites/default/files/Sight%20loss%20stats%20postcard.pdf

3 https://www.actiononhearingloss.org.uk/your-hearing/about-deafness-and-hearing-loss/statistics.aspx

4 http://www.bdadyslexia.org.uk/about

5 https://www.mentalhealth.org.uk/sites/default/files/fundamental-facts-15.pdf

6 http://www.dlf.org.uk/content/key-facts

7 http://www.ukhca.co.uk/pdfs/DomiciliaryCareMarketOverview2015.pdf

8 http://gov.wales/docs/statistics/2016/160907-assessments-social-services-adults-2015-16-en.pdf

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 4

Key Findings

Company Assistance Schemes Review

CCWater believes that “Vulnerability occurs when a consumer may not have reasonable opportunity to

access and receive an inclusive, safe service from a company, resulting in a permanent or temporary

detrimental impact on their well-being, finances or health”.

Water companies have already made a good start in offering consumers a tailored service based on

individual needs, but more can be done.

Our Water Matters research 2015-20169 indicates that awareness of additional services offered by

companies has increased in England by +1% but has decreased in Wales by -1%. Significantly fewer

consumers in Wales are aware of the additional services (45%) compared to England (50%).

CCWater carried out desk based website research in June 2016, searching for details of assistance schemes

on each company website. We also compared assistance offerings between the water industry and energy

industry. Our observations are:

In the main, the assistance schemes were difficult to locate on company websites mainly because

the terminology used or the location of the information was not obvious. Only eight companies

had details of assistance schemes on the home/landing page of their website.

Each company has named their own scheme so there is no consistent branding unlike in the energy

sector where companies are encouraged by Ofgem to use the branding “Priority Services Register”.

This makes it difficult for a consumer or their representative to find out whether their water

company offers anything similar.

There is an inconsistent level of assistance offered within the industry with some companies

offering more assistance based on the Ofwat guidance than others.

The water industry has already moved away from making the assistance available to just those

customers who meet a set eligibility criteria whereas the energy industry is just commencing to do

so.

Following the desk-based research we asked companies to complete our special assistance questionnaire,

which provided companies with the opportunity to reflect on how they consider they are meeting the

Ofwat guidance. Our observations are:

All companies completed the questionnaire and were open and transparent in their self assessment

against meeting the guidance.

Companies found the exercise useful as it helped them to identify opportunities for improvement

and they are keen to learn of any good practice recommendations that they could use as they

develop their vulnerability strategies.

Companies have already made a good start in progressing local partnerships; a list of the examples

of local partnerships is on page 8 but there is scope for a national level of partnership working.

Some companies are developing partnership working with local energy suppliers to help improve

awareness of the assistance schemes and to explore if data sharing is possible.

9 Water Matters research 2015-2016

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 5

Recommendations

National Strategic Level

There are many organisations trying to make contact with the same consumers in vulnerable

circumstances to establish what additional assistance they need and how this can be provided to them. To

enable a more effective and efficient process we need to look to a more collaborative approach.

Partnership working is key. CCWater should work with UKRN, ESAN and Water UK to establish an

efficient and effective engagement process with national bodies to devise and promote assistance

for consumers/customers in vulnerable circumstances. This could include but is not limited to

creating a national working group to help consumers in vulnerable circumstances. This will avoid

duplication of work for both companies and national bodies. Such national bodies could include

(but is not limited to):

o AbilityNet

o Action on Hearing Loss

o Action with Communities in Rural England

o Age UK / Age Cymru

o Alzheimers Society

o British Dyslexia Association

o British Red Cross

o Carers Trust/Carers UK

o Citizens Advice

o Dementia Action

o Department of Work and Pensions

o Disabled Living Foundation

o Disability Rights UK

o Groundwork Green Doctor

o Health Watch England

o Local Government

o Marie Curie

o MENCAP

o Migrant help

o Mind

o Mumsnet – emergency water supply for baby bottles etc.

o Office of Public Guardian

o Public Health England - Make Every Contact Count

o Refuge

o Royal National Institute of Blind People

o SeeAbility

o Scope

o Shelter

o The Royal British Legion

o The Wales Rural Network Support Unit

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 6

A single name for non-financial assistance schemes. This will help consumers/customers in

vulnerable circumstances and advice agencies recognise the scheme and to easily find available

help. It is our recommendation that water companies transition the name of their schemes to

“Priority Services”. The brand is already used in Energy and this will support the joined up help for

consumers/customers we consider is appropriate. As a result of their own research, United Utilities

and South West Water have already proactively changed their scheme names to “Priority Services”

and Wessex Water is in the process of making this change. Northumbrian Water, Essex and Suffolk

Water, South Staffs Water and Cambridge Water have all indicated they are also considering

changing their assistance scheme name to “Priority Services”.

An annual national “Priority Services” awareness campaign should take place. The campaign

should reach out to national and regional media as well as partner organisations and companies to

promote the assistance available across utilities and other regulated industries. This will assist

companies’ local efforts to engage with consumers/customers on the assistance available,

Make registering and accessing assistance easier for consumers. At present there is a burden

placed upon consumers or their representatives which is caused by the need for them to contact

each individual organisation to register for assistance. A national level solution, in particular for

regulated industries, should be sought. This could include but is not limited to a formal data share

arrangement supported by legislation between regulated companies. We are aware that the UK

Regulators Network is presently exploring if data sharing regarding “Priority Services” data is

possible between Water and Energy companies.

Ofwat’s special assistance guidance should be followed by retailers and wholesalers. This would

apply should a household retail market be introduced.

Community Vulnerability Strategies should be developed. Events such as flooding, boil water

notices and drought can put or have potential to put whole communities in vulnerable

circumstances and as such companies cannot rely solely on the information held on their registers

to identify who may need additional help during the event. The strategies should identify high risk

areas, plans put in place to ensure the residents of the community are aware of what help is

available to them and how to access such help.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 7

Recommendations

Good Practice Recommendations

Company level

Collaborative working is key. Water companies and other utilities would benefit from working

collaboratively to make assistance schemes more consistent for consumers and to promote

awareness of the schemes. This would help companies demonstrate how they are making an

inclusive service available to all consumers, increase the number of consumers registered on the

schemes, and also to help improve awareness of special assistance schemes as measured in our

Water Matters research10.

A consistent level of core assistance should be offered. Companies should work towards offering

(as a minimum) the core assistance detailed on page 8. CCWater should monitor water

companies’ progress against this, and continue to facilitate the sharing of good practice.

The application process should primarily focus on the help/services that the customer needs and

not, for example, the customer’s medical condition. This is in line with the Ofwat guidance that

the register should be open to anyone who needs one of the services that a company offers

regardless of age, health, disability, or indeed lack of disability.

Assistance scheme information on a company website should be easy to find, in one place and

include all assistance services offered. This will help customers, or their representatives, (including

partnership organisations such as advice agencies) look at all offerings to determine what may

meet their needs.

Companies should seek to make every contact count by making customers aware of available

assistance at available opportunities such as: a leaflet sent with bills, welcome to new home/new

account packs, during and after an incident event such as flooding, boil water notice or drought.

Companies should also make assistance scheme information available in other formats and

languages to meet the needs of all their customers.

Companies should consider who the schemes may benefit when looking at forming partnerships.

Promotion of the schemes at partner organisations would target awareness, and potentially

increase the number of people registered on the scheme. A list of types of partner organisations

that companies identified as using is included in page 9.

10

CCWater Water Matters Report

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 8

Core Assistance presently offered

Core Assistance to also be offered

Water Industry

Energy Supplier

Energy Network Operator Safety

Advance supply interruption notice Priority reconnection if supply interrupted Personal supply interruption notice Emergency water supply (for those who medically need it, need to take lots of medication, have

mobility restrictions, nursing mothers, have children living in the house who need regular bottle feeds).

Alternative facilities for cooking and heating Free annual gas safety check (see note on page 18)

Password Scheme Identity Check of employees Company follows the principles of UK Water Industry Distraction Protocol Company follows the principals of National Cold Call Protocol

Mobility

Knock and Wait – giving a longer time to answer the door

Help if flooding (caused by a company asset) occurs

Meter moved if you cannot read the meter in its present location

Help reading the water meter

Quarterly meter read

Move a prepayment meter (refer to footnote 12 on page 17)

Accessible Communications

Accessible website

Help understanding your water bill

Help to make arrangements to pay your water bill

Nominated contact – e.g. friend, relative or carer Home visits

Large print

Braille

CD

Audio tape

Text phone

Type talk/Text relay

Minicom

Personalised call assistance e.g. Speaking slower/giving longer thinking/response time

Web chat (ideally with a “still here” button if it’s a timed transaction).

Alternate colour background documents

Sign language/subtitled videos on website

Sign language home visits

Alternative language formats Interpreter services

Signposting to other assistance

Signpost to help for those struggling to pay

Signpost to where to get water devices and water aids

Signpost to energy & telecom priority services

Signpost to approved plumbers scheme

Accessibility

Promotion of accessible public buildings (where relevant)

Promotion of accessible leisure facilities (where relevant)

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 9

Partners for company promotion of Non-Financial Assistance

Local Third Party Groups Social services Landlords Infrastructure groups

e.g. infrastructure north

GP surgeries/health centres/pharmacies Mobile home park owners VONNE (voluntary organisations network North East)

Libraries Sheltered accommodation/private retirement living providers

Community Centres Collection or Billing agreement providers

Residents’ Associations Company Trust Fund providers Community Vulnerability

Local Housing Associations Resilience Direct system used

Parish Councils MP constituency offices Job Centre Plus

Fire Association (when conducting home safety checks)

Community or specialist magazines For example: * Living with Disability * Halton Carers * Making Space * All Together now (local newspaper in hospitals, health centres, GP’s and supermarkets) * Golden guide * 50 plus magazine

Local radio

Community Events

Local Community/charity groups (face to face and online)

Children’s centres/toddler groups/ parents and babies groups.

Over 50’s clubs

Adult day care centres

Green doctor (and other home energy assessors)

Food banks

Carers Associations

Local independent living councils

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 10

Background information on Ofwat guidance to companies

Ofwat’s guidance to companies on the special assistance companies should offer was last updated in

November 2013. A link to the full document can be found here:

http://www.ofwat.gov.uk/wp-content/uploads/2015/10/gud_pro_specialassistsept08.pdf

Main points of note from the document

The register

All companies should maintain an accurate and up to date record of consumers who have

expressed a need for specific help or service.

Companies should make sure that control of and access to the register complies with the Data

Protection Act 1998.

Companies should check with consumers at regular intervals that additional services are still

required, and update the register accordingly.

Companies should use the register to make sure that consumers receive the specialised services

they need at all times.

The register should be open to anyone who needs one of the services that a company offers

regardless of their age, health, disability, or indeed their lack of disability.

The register should include, but is not limited to those who :

Are particularly vulnerable during supply interruptions.

E.g. health could be put at risk, have mobility problems and cannot reach alternative supplies. Could also include: Having a child under the age of one who needs regular bottle feeds. Or someone is convalescing from a serious illness.

Are particularly vulnerable during actual or potential drinking contamination incidents, when advice to boil water for drinking or advice not to use water for drinking or cooking is issued.

E.g. health could be put at risk, have mobility problems and cannot reach alternative supplies or boil water. Could also include having a child under the age of one who needs regular bottle feeds. Or someone is convalescing from a serious illness.

May have problems in communicating or receiving information in the formats that the company usually provides.

E.g. deaf, partially deaf, blind, partially sighted, vocally impaired, or consumers with mental health problems or learning difficulties. Could also include English not the first language, dyslexia, dyspraxia, colour vision deficiency (commonly called colour blindness).

May be vulnerable to bogus callers. Anyone concerned about personal security in their home.

May need help reading their meter. E.g. blind, partially sighted, learning difficulties, mobility problems

May need help to understand their bills. E.g. learning difficulties, mental health problems, low level of financial understanding, dementia.

May need help to make arrangements to pay their bills.

E.g. Learning difficulties, mobility problems if travel needed to make the payment, mental health problems, and low level of financial understanding.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 11

Companies should accept applications made on behalf of the customers by the customer’s

nominated representative or advice agency (customer consent should be given).

Where consumers are billed through a third party (for example a local authority or housing

association), consumers should be able to register directly with the company (and be made directly

aware).

Where consumers are billed by a third party (for example a resale situation such as a mobile home

park) companies should accept applications made by the third party.

Companies should consider reminding consumers at the time of registration to their register of the

availability of similar services in the energy and telecoms sectors.

Companies could also consider the value of working with other utility companies to make reciprocal

arrangements which will allow as many consumers as possible to become aware of the special

assistance available in all sectors.

Applying for special assistance

The application process should be accessible, easy to understand, simple to complete, administered quickly and easy to find.

The option of registering by telephone (preferably Freephone and area numbers), e-mail, text phone, Minicom or via the website should be provided and mentioned in any literature.

Application forms should be simple and clear on how to complete (use tick boxes where possible)

Application forms should make clear the application process where the customer receives water and sewerage services from different companies. The process should be either:

Customer needs to register with both providers; or

Give their permission for one company to share the information with the other.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 12

What assistance should be provided?

Communicating essential company information

Each company should make sure all consumers have access to all essential information in a format they can

use and understand.

14 point font minimum to be used to advise customers of alternative formats.

Companies should have arrangements in place for communicating with sight and hearing impaired customers and those with learning difficulties in the case of an emergency (such as boil water notice or planned supply interruptions). Companies should tell the registered customers for this service what the special arrangements are.

For blind and partially sighted consumers, the usual alternatives are large print, braille or disc. Some companies also offer a free magnifying strip.

When using a disc format, customers will want the most important information first (e.g. for a bill customers want to know how much they owe before they want to know details of their account number or how much water they have used).

Home visits or personal phone calls are preferred by some customers. Companies should consider whether they are able to offer such services.

Websites are a useful communication tool for some customers with hearing or sight impairments. Essential information could be provided as sign language web clips on company websites. RNIB also has guidance on ensuring websites are accessible to consumers with sight impairments.

Companies could register with a text relay service, provide real-time text, Minicom or e-mail services. Staff should be sufficiently trained and the equipment placed in a location where it will be noticed and answered promptly. Ideally consumer facing staff should be as easy to contact by real time text as by phone.

Companies should follow Ofcom's guidance for making call centres accessible.

Companies should make sure when literature or other information is reviewed and updated, the versions available in alternative formats are also updated. CCWater should be given the opportunity to comment on any substantive changes.

Companies should also consider consulting with national organisations such as RNIB and RNID and give them the opportunity to comment on literature or other information when it is reviewed.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 13

Bills

Companies should make sure all customers know the amount of their bill and when payment is due.

Bills should be available in alternative formats such as large print, braille, disc or a reading service whereby details of the bill are read out to the bill payer over the phone before the bill is issued.

Companies should allow a nominated contact to be appointed on behalf of the customer to receive the bill and be contacted first should non payment of the bill arise. Companies cannot hold the nominated contact liable for if the bill is not paid.

If the bill is not paid on time, companies should allow more time in the debt collection process for the nominated contact to sort things out.

Companies should not contract debt to third party recovery agents where the bill payer is registered as requiring special assistance, unless the agent is able to demonstrate that the same level of assistance can be provided.

Access to consumers’ homes

Companies should make sure their password scheme is available to any consumer who wishes to use it.

Companies should make sure that deaf customers who wish to use the password scheme can do so either through a written password or other communication arrangements set up for their specific use.

To hep customers who may find it difficult to remember passwords, companies should consider confirming the password registered in writing or issue a prompt question to assist these customers.

Companies should sign up to UK Water Industry Distraction Burglary protocol and make sure any contractors working on their behalf also comply with its principles.

Companies should allow enough time for consumers registered for special assistance to answer the door. Those with mobility problems, for example, may need more time.

Water Meters

All metered bill payers should be able to check their water consumption at reasonable intervals

Where a bill payer cannot read their meter, companies should consider re-siting the meter or providing a more frequent meter read service (e.g. quarterly).

Companies should ensure when fitting a meter for the first time in a visually impaired, elderly or disabled bill payers premises that the meter is accessible to them. This may mean siting the meter in a different location to the company’s preferred one, for no additional charge.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 14

Access to buildings and recreational facilities

Disabled consumers should know which of the company’s public buildings and recreational facilities are equipped to cope with their needs.

Information on access to public buildings should be made available on companies’ websites and brief details should be included in any literature aimed at consumers requiring special assistance.

Appropriate facilities should be provided at the public building these could include:

Wheelchair access

Tactile signs for blind consumers

Facilities for deaf consumers

Toilets for disabled consumers

Lifestyle aids

Companies should be able to signpost customers to where help can be found regarding lifestyle aids and adaptions (for example to kitchen and bathroom equipment).

Staff Training

All company staff (including office based and field based) should be fully aware of the potential needs of, and services available for, disabled, chronically ill or elderly consumers.

All company staff (including office based and field based) should be trained regularly to:

Make sure their knowledge of available assistance is kept up to date

Make sure they know how to identify those consumers that would potentially benefit from available assistance and offer such services proactively

Be aware of how to communicate sensitively and effectively with these consumers

Consider using specialist external organisations to deliver staff training (e.g. MIND, RNID etc.)

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 15

Promotion of assistance available

Companies should make sure all consumers are informed of the assistance available.

Companies should have a strategy for making sure all its consumers are informed about assistance available and how to register for assistance.

If a customer receives a bill through a third party (e.g. local authority) then companies should make sure those customers receive information of assistance available directly or by the third party in a suitable format.

Companies should send information to bill payers on an annual basis consisting of:

A leaflet outlining main assistance available

Information explaining assistance can be provided free of charge, with a clearly signposted reference to where further details can be found. This may be included in standard billing literature.

This information should be in appropriate print size and colours such as those recommended by the RNIB.

To supplement basic literature, more detailed information should be available on request, explaining the specific services the company offers and how to apply. Companies should review this annually.

Information on services that are offered should be easily accessible from companies’ websites.

Where possible, copies of literature should be distributed to local authorities and small locally based support groups as these groups are frequently closer to those who require assistance.

Communication links should be established with local offices of national organisations such as RNIB, RNID, MENCAP, Mind, Alzheimer’s Society, and Age UK.

Many deaf consumers will have sign language as their first language. Communicating with their representative organisations, such as British Deaf Association or local deaf societies will help companies make provision for these consumers. Sign language videos to workshops for local signers may also prove useful.

New Homeowner packs should include a copy of a leaflet about assistance available or a reference to a leaflet and how to obtain it.

Companies should consider other methods of promotion of available assistance such as local free newspapers, radio, libraries, CAB offices, GP surgeries and community centres.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 16

Ofwat’s website contains the following information regarding customer assistance:

You, or someone you know, may benefit from assistance with paying water bills or with accessing water or

sewerage company services. This may be short-term or long-term and because of factors like age,

disability, numeracy or digital literacy, significant life events or changes in wider society or economy.

The following sections provide an overview of some of the schemes that are available to help customers.

Your water company may offer special assistance to help meet your particular need in the way that you receive your water and sewerage services

The WaterSure scheme is available for certain customers with a water meter. It allows them to have their bills capped.

If you are facing genuine financial difficulty, your water company may be able to offer you help with your water bill through a charitable trust.

Water Direct is a scheme run by the Department for Work and Pensions (DWP) where payment for water bills is deducted directly from benefits.

We understand that anyone can find themselves in a situation of vulnerability where they need extra help.

So we encourage water companies to understand all their customers and their circumstances, and better

tailor support. This approach is essential to good company performance and benefits everyone.

Our vulnerability section has more information about this area of our work

Ofwat’s website contains the following information regarding special assistance:

There may be factors in your life which mean that you need extra help from your water companies in the

way that you receive your water and sewerage services.

Special assistance register. We have provided guidance to companies stating that special assistance should be provided to any customer regardless of their age, health, disability or their lack of disability.

Bills and other literature in accessible formats. You can ask for large print, disc or braille communications, and have your bill read out to you over the phone before they send it.

More warning of supply interruptions. Sometimes water companies need to turn off the water supply to do work in your area. Tell them now if you have special medical needs – for example, kidney dialysis at home – and they will give you early warning of their plans.

Create a password. You can set a password that any water company employee will use if they knock on your door.

Moving your meter. If you have a meter and it’s difficult to reach and read, your water company may agree to move it for you. Alternatively, your company may offer help with meter reading so that you can monitor your water consumption.

If you think that you would benefit from these kinds of services, you can contact your water company for

more information.

We have set out guidance to the water companies on the services they should offer to customers who

need extra help. The guidelines make sure that you are not put at a disadvantage because of your age,

disability or illness in comparison with other customers.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 17

Priority Services in Energy

The Priority Services Register in Energy was primarily created to provide assistance for specific groups of

customers who met one or more of the following eligibility criteria:

Pensionable Age

Disabled

Chronically Sick

Live with children aged under five11

Companies are also obliged to offer specific services for customers who are blind or partially sighted; or deaf or hearing impaired.

The services currently offered on the Priority Services Register are:

Assistance offered Supplier Network Operator

Safety

Advance supply interruption notice Personal supply interruption notice Priority reconnection if supply interrupted Alternative facilities for cooking and heating Password Scheme Mobility

Quarterly meter read

Move a prepayment meter 12

Communications13

Large print

Braille

CD

Audio tape

Text phone

Type talk

Alternative language formats Other

Nominated Contact

11 This is a new ‘core group’ in network operator licence conditions 12 Suppliers are required to move the prepayment meter if the customer is unable to make payments through that meter due to infirmity. Under the new licence conditions from January 2017, suppliers will be required to offer appropriate arrangements to enable the functionality of the Domestic Customer’s Prepayment Meter which is Safe and Reasonably Practicable in all the Circumstances of the Case 13 When asked to do so by, or by someone acting on behalf of, a blind or partially sighted Domestic Customer, the licensee must, by means that are readily accessible to such customers, provide information free of charge about any Bill or statement of account relating to the supply of gas or any other service provided to the customer by the licensee. As such companies may offer more assistance than what is listed here.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 18

Ofgem recognised that there was a need to move away from making the assistance available to just those who met the eligibility criteria and have consulted14 and decided15 on a new principles based approach WEF: 1 January 2017 which will allow companies more flexibility to achieve positive consumer outcomes and address the needs of consumers in vulnerable situations.

In addition to the priority service registers, Energy suppliers are also obliged to offer free gas safety checks.

To qualify the customer must own their own home, have not had a gas safety check carried out in the last 12 months, be on a means-tested benefit and either they:

Live in a household where at least one of the occupants is under five years old;

or

Are of pensionable age, disabled or chronically sick and either they:

Live alone; or

Live with others all of whom are either of pensionable age, or disabled, or chronically sick, or under 18 years.

If the customer lives in rented accommodation, it’s their landlord’s duty to ensure an annual gas safety

check is done.

14 https://www.ofgem.gov.uk/publications-and-updates/priority-services-register-review-statutory-consultation-and-notices 15

https://www.ofgem.gov.uk/publications-and-updates/decision-modify-gas-and-electricity-supply-electricity-distribution-and-gas-transporter-licences-psr-arrangements

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 19

Annex 1 – Special Assistance Questionnaire

CCWater Special Assistance Questionnaire

Name of company:

Topic and Questions Company Response

Q1 Please provide details of all the additional assistance (whether offered as part of your special assistance scheme or not) that the company presently makes available to consumers.

Q2 What is the name of the company's special assistance scheme?

Application process

Q3 Please explain how the company considers that the application process for obtaining additional help is: a: easy to find b: accessible c: easy to understand d: simple to complete e: administered quickly

Q4 Does the company provide the option of registering for the assistance by: a: telephone b: Freephone c: regional area numbers d: e-mail e: text phone f: Minicom g: via the website Please also provide details of where on the website these options are promoted and also submit to CCWater a copy of the literature which contains the promotion of these options.

Q5 If applicable, does the company consider the application form makes clear the application process for what the consumer needs to do if they have two different companies providing services (one for water and one for sewerage)? Could you please submit a copy of the application form to CCWater.

Communicating Essential Information

Q6 Is a 14 point font minimum used to advise customers of alternative formats?

Q7 Please explain how you promote the availability of large print, braille or disc formats. Please also provide a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q8 Does the company promote a free magnifying strip? If so, please explain how the company promotes the availability of this. Please also provide a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 20

Q9 Does the company promote home visits? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q10 Does the company promote personal telephone calls to discuss essential information such as a bill? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q11 Does the company promote a text relay service, real-time text, Minicom or direct e-mail services? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q12 Do you consider your company website is accessible for consumers with hearing or sight impairments who have accessibility needs?

Q13 Please explain your process for consulting with CCWater on amended versions of essential information literature. Please also advise when you last consulted with CCWater regarding this.

Q14 Does the company offer alternative format versions of essential information? If so, please explain how you promote this including relevant links to webpage and copies of the literature which contains the information to CCWater.

Bills

Q15 Does the company allow a nominated contact to be appointed on behalf of the customer to receive the bill and be contacted first should non payment of the bill arise? If so, please explain how the company promotes this including relevant links to webpage and copies of the literature which contains the information to CCWater.

Q16 If the bill is not paid on time, does the company allow more time in the debt collection process for the nominated contact to sort things out? If so, please explain how this works in practice.

Q17 Does the company contract debt to third party recovery agents where the bill payer is registered as requiring special assistance? If so, please explain how the company checks the agent is able to demonstrate that the same level of special assistance can be provided.

Emergencies – Water or Sewerage

Q18 Please explain the arrangements the company has in place for communicating with sight and hearing impaired customers and those with learning difficulties in the case of planned water supply or sewerage disposal interruptions or an emergency (such as boil water notice, or flooding caused by a company asset).

Q19 Please explain how the company informs the registered customers for this service of the special arrangements.

Q20 Please explain the arrangements in place for providing an emergency supply of water to those consumers whose health could be put at risk by not having a safe and reliable supply of water.

Q21 Please explain the procedures the company has in place in case of an emergency for linking in with other organisations regarding access to information about consumers who may be in vulnerable circumstances.

Q22 Does the company conduct research after key events to seek consumers views on whether they consider their needs were met during the event? If so, please explain how the company acts on the insight from the research.

Water Meter

Q23 Does the company ensure when fitting a meter for the first time in a visually impaired, elderly or disabled bill payers premises that the meter is accessible to them (this may mean siting the meter in a different location to the company’s preferred one, for no additional charge)? If so, please explain the process for how this happens.

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 21

Q24 If a bill payer cannot read their meter does the company offer to re-site the meter for free? If so, please explain the process for how this happens.

Q25 Where a bill payer cannot read their meter does the company offer to provide a more frequent meter read service (e.g. quarterly)? If so, please explain the process for how this happens.

Access to consumer’s homes

Q26 Is the password scheme available to all consumers? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q27 Does the company offer hearing impaired consumers who wish to use the password scheme the means to do so either through a written password or other communication arrangements set up for their specific use? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q28 Does the company offer a prompt question to assist consumers who may find it difficult to remember passwords? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q29 Has the company signed up to UK Water Industry Distraction Burglary protocol and made sure any contractors working on their behalf also comply with its principles? If so, please explain how the company checks that contractors comply with the principles.

Q30 Does the company offer a “knock and wait” service (or the same service under a different name) which allows consumers to register with the company that they need more time to answer the door? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Access to buildings and recreational facilities

Q31 Does the company promote which of the company’s public buildings and recreational facilities are equipped to cope with needs of disabled people? If so, please explain how the company promotes the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Q32 Is information on access to public buildings available on the company website? If so, can you please detail where on the website it can be found?

Q33 Is information on access to public buildings included in any literature aimed at consumers requiring special assistance? If so, please send copies of the literature which contains the information to CCWater.

Lifestyle aids

Q34 On the company website and in literature aimed at consumers requiring special assistance, does the company signpost consumers to where help can be found regarding lifestyle aids and adaptions (for example to kitchen and bathroom equipment)? If so, please explain how you promote the availability of this. Please also include a link to the relevant webpage and submit a copy of the literature which contains the information to CCWater.

Staff training

Q35 Please explain how the company trains all staff (including office based and field based) regularly to: a: Make sure their knowledge of available assistance is kept up to date b: Make sure they know how to identify those consumers that would potentially benefit from available assistance and offer such services proactively c: Be aware of how to communicate sensitively and effectively with these consumers

Author: Janine Shackleton, Consumer Council for Water. November 2016 Page 22

Promotion of assistance available

Q36 Does the company send information to bill payers (whether they manage their account on line or manually) on an annual basis consisting of: a: A leaflet outlining main assistance available? If so, please send a copy of the literature to CCWater b: Information explaining assistance can be provided free of charge, with a clearly signposted reference to where further details can be found? If so, please send a copy of the literature to CCWater.

Q37 Does the company consider the information is in an appropriate print size and colours such as those recommended by the RNIB?

Q38 Does the company consider that information on all assistance services that it offers is easy to find (e.g. in one place, under a clear, relevant heading) and easily accessible from the company’s website? Please provide a link to where this is held on the website.

Q39 Does the company distribute copies of literature regarding available assistance to local authorities, local offices of national organisations such as Age UK, CAB and locally based support groups? If so, please explain which partners you distribute such literature to.

Q40 Does the company have sign language videos on their website? If so, please provide a link to the relevant webpages.

Q41 Does the company issue “new homeowner packs” which include a copy of a leaflet about assistance available or a reference to a leaflet and how to obtain it? If so, please provide a copy of the "new homeowner pack".

Q42 Please explain how the company promotes available assistance in local free newspapers, libraries, CAB offices, GP surgeries, community centres or on the radio.

Other services/initiatives to help consumers have access to and receive a fair and inclusive service for all

Q43 Are there any other services or initiatives which the company is considering implementing?