PhonepayPlus 'can't give straightforward answers' to basic questions about new rules, says UK content provider.
ME has been deluged with comments from UK firms worried about the extent and nature of the watchdog's new rules on content subs. We decided to publish the following comments, from an anonymous source, in full..."We operate a mobile subscription service which costs users £6/month to join and remain a member (subscribers receive
unlimited downloads in return). Because this equates to only £1.50/week, our service should be exempt from the new PPP rules, but since we levy the charge only once monthly, each user is charged £6 for the next four weeks usage in one go.
"In order to clarify the situation, and find out if we should or should not pre-register as per the new 'Pre-Sub SMS' procedure, we contacted PPP directly for a response. It's worth noting that we use an accredited UK billing aggregator and are already a PPP signatory in our own right.
"So we asked two questions of PPP:
1) Are we covered by our aggregator in respect of the new rules?
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2) Does the £6/month charged in advance subscription mean we have to pre-register, or not, since it equates to only £1.50 a week?
"We were astonished to learn that PPP remained unable to answer either question.
"On the first point, fair enough. We can check with our partner directly, but confirmation would have been welcome, and the
fact that PPP had no idea if we would or would not be covered did not instill confidence.
"The PPP response to our second question, however, went beyond disappointing, and could even be unfairly damaging.
"Their answer was, "we do not know if levelling 4 x weekly charges of £1.50 into a single monthly charge of £6 will mean that you must use the new rules or not, but we suggest that you do so anyway, just to be on the safe side".
"This, of course, is entirely unhelpful. The onerous new rules will inevitably damage conversions and revenue will suffer. As ME has pointed out, the new PPP subscription rules serve only to make life more difficult than it already is for providers who scrupulously follow the rules, and trade well within the legal, moral and regulatory framework.
"The crooks, criminals and con-men that the new rules are meant to inhibit take not the slightest bit of notice of them, and just disappear and re-appear under different guises to avoid detection.
"We would have at least expected to have received a straightforward and unambiguous answer to our question, but not having received one puts even the most scrupulously compliant among us in an invidious position.
"Damned if we do, damned if we don't is seems. A position that does not sit well with us and erodes our confidence in the powers that govern us.
"This just does not seem to have been thought through at all well, does it? The entire exercise smacks of 'the need to be seen to be doing something' without the 'thing' itself being fully considered, and we call for greater clarity on the matter."
You can read PPP's response to the points raised in this article by clicking here.
