Ofwat consultation on Customer Licence Condition workshop

Our response to the revised Principles of the proposed Customer Licence Condition Ofwat presented at its November 2022 workshop

Executive Summary

We support Ofwat’s proposed Customer Licence Condition as it will focus water company boards on doing the right thing for customers.

We welcome that Ofwat has agreed with the suggestions we have made on creating high level principles, which can then be underpinned by more responsive Codes of Practice that can adjust easily as customers’ expectations change.

We broadly agree with the draft Principles, but must the Principles must ensure that companies are clear of their need to consult with CCW on issues that matter to customers. There is a danger that this could be lost if Condition G is removed. P3 therefore needs to have strong linkage to CCW’s role so that concept is clear.

Our response to Ofwat draft principles and questions

P1 The Appointee must: P1.1 meet the principles for customer care set out in paragraph P2

Agree

P1.2 explain in a manner that is effective, accessible and clear how it is meeting the principles set out in paragraph

Agree with including this. CCW is open to taking a role auditing the compliance with the Principles.

P2.1 The Appointee is proactive in its communications so that customers receive the right information at the right time, including during incidents.

Agree

P2.2 The Appointee makes it easy for customers to contact them and provide easy to access contact information.

Agree

P2.3 The Appointee provides appropriate support when things go wrong and helps to put things right.

Agree

P2.4 The Appointee learns from past experiences and demonstrates continual improvement to prevent foreseeable customer harm

Agree

P2.5 The Appointee understands the needs of its customers and provides appropriate support [including/especially customers in vulnerable circumstances].

Remove bracketed section as covered in P2.6

P2.6 The Appointee provides appropriate support for customers in vulnerable circumstances.

Agree

P2.7 The Appointee provides a range of appropriate support options for customers who are struggling to pay; and to customers in debt.

Agree

P3 Ofwat may issue and revise guidance to support attainment of the principles. The Appointee shall have regard to, but not be limited by, such guidance in meeting the principles...

…[Guidance issued by Ofwat under this condition may include a requirement that the Appointee consult the Consumer Council for Water and take its representations into account before making or revising any policies or processes which relate to matters covered by that guidance.]

Remove the bracket.
Change ‘may include a requirement’ to ‘will include a requirement’
Add to ‘matters covered by’ “the Principles or that guidance.”

Condition G – Core customer information Clear overlap between this condition and our suggested condition, and its principles 2.1, 2.2 and 2.3. Our initial thinking is to make revise condition G into a customer-focussed, principle-based condition, with the current detail in guidance.

If Condition G is removed, there needs to be strong linkage to CCW’s role in P3, so companies are clear of their need to consider CCW’s views when considering
issues that affect customers.

Role of a compliance statement

We support Boards submitting a compliance statement as it will ensure Boards are focused on delivering for customers through this licence condition

Ofwat consultation on Customer Licence Condition workshop

Executive Summary

Our response to Ofwat draft principles and questions

Customers in England

Customers in Wales