Please be advised we have received the below notification from Vodafone regarding an update to their code of practice.
Vodafone has worked hard with industry over the last years to improve the mechanics for consumers to charge digital items to their mobile phone’s bill and the ongoing compliance monitoring program with Empello delivers consistently high results showing the work and Due Diligence exercised by L1s and L2s when delivering advertising of services to potential customers.
We continue to look forward to a bright future and the latest drive to keep the mechanic of Charge to Bill relevant in a fast paced and competitive market was the introduction of the Security Research Project conducted jointly with other MNOs and the PSA.
This has created new understanding of the potential frauds being perpetrated against consumers, merchants and partners which result in complaints into the PSA and Vodafone requiring redress. Off the back of this security research work Vodafone is introducing a number of new measures that will further protect the value chain from fraud.
1. Partners are to remove the Merchant hosted payment pages and move entirely to partner hosted payment pages. Services covered by regulation of the Gambling Commission are exempt and these services must fully comply with PSA regulations. Further exemptions are only by written agreement. If you have a current exemption please re-validate it with the team.
2. The requirement of immediate opt outs continue to give VF concern and therefore we require that the billing of all 3rd party Subscription Services are subject to a 24 hour delay prior to charging action thus creating a mandated ‘Free Period’. This will allow those customers who inadvertently subscribe to such services to opt-out without financial consequence. It is also important to note that VF requires that:
a. The mandated welcome message remains as being sent immediately the payment pages are completed
b. A new requirement of sending the spend reminder message immediately the Free Period has ended as specified in the Scheme rules
c. The ‘Free first 24 Hours’ is not the lead marketing message rather it is a point of information.
3. As the issue of “no consent to charge” increases in CTB and Vodafone wishes to preserve the 2 step authentication flow currently in use, Vodafone is mandating the use of the tokenisation product supplied by Empello for all partners.
4. Many Vodafone customers happily use the services supplied by our market however when they do require post-sales support then Merchants need to be encouraged to take the calls of Vodafone customers seriously. To that end Vodafone will now be clawing back credits applied to customers who have come into the support team for a second time on the assumption that post-sale support was not adequately supplied by the Merchant when given the opportunity.
Vodafone has great confidence in the 3rd party services supplied to our customers and we are under continued scrutiny from regulators, customers and the media and we hope you see these new measures simply as ways that we can continue to ensure the long term prosperity of the market.
Please do not hesitate to contact us if you have any questions.
Kind regards
Fonix Compliance Team
Posted Apr 24, 2019 - 13:30 BST
This scheduled maintenance affected: Direct Billing and Compliance.