Telecommunications Industry Ombudsman Submission on the Structure of Australia s Telephone Numbering Plan
Contents About the TIO 1 TIO Approach to the Consultation Paper 2 Complaints to the TIO 3 Jurisdiction of the TIO 3 Likely impact of changes to the Numbering Plan on Complaints 3 Complaints relevant to the Numbering Plan 4 General observations about the Numbering Plan 8 Integrated Public Number Database 8 1300/1800 numbers 9 Numbering for Outbound Services 9 Geographical Numbering 10 Assumptions made in the Consultation Paper 11 Contiguous numbers on different exchanges 11 Mobile phone pricing having no distinction between local and long distance calls 11 Increasing take up of capped plans for fixed services 11 Call forwarding out of geographical areas 12 Further considerations and suggestions 12 Appendix A 14 Page i
About the TIO The Telecommunications Industry Ombudsman (TIO) is a free and independent alternative dispute resolution service for small business and residential consumers in Australia who have a complaint about their telecommunications services. We aim to resolve these complaints quickly in a fair, independent and informal way, having regard not only to the law and to good industry practice, but also to what is fair and reasonable in all the circumstances. Before the TIO becomes involved in a complaint, the service provider is given the first opportunity to resolve the complaint with its customer. The TIO is the largest industry Ombudsman Scheme in Australia we receive an average of 5,000 to 6,000 calls each week and record around 150,000 to 170,000 new complaints each year 1. Most complaints to the TIO are resolved quickly and effectively through a process of referral to designated contact points within the service providers, or by the TIO facilitating a fair and reasonable outcome between the two parties. Complaints that cannot be resolved by facilitation are escalated for formal investigation by the TIO. If the complaint remains unresolved after formal investigation and the TIO is of the view that it would be fair and reasonable to do so, the TIO can make binding determinations up to a value of $30,000 and non-binding recommendations up to a value of $85,000 in respect of each complaint. We are independent of telecommunications companies, consumer groups and government. However, we provide information and assistance to regulators or other organisations where this is required by law or where this will help the industry and consumers to resolve complaints. Further information about the TIO is available at www.tio.com.au. We record complaints according to the types of issues that these complaints present. These include provisioning/connection delays, credit management disputes, contractual disputes, customer service/complaint handling and billing disputes. Every complaint involves at least one complaint issue. Some complaints can involve multiple complaint issues for example, a complaint about a delay in rectifying a faulty landline service may also involve a claim that the consumer s complaint about this fault was not acknowledged or escalated (a complaint handling issue). TIO complaints are broadly classified according to service types internet, mobile, landline and mobile premium services (MPS) and are investigated according to the types of issues they present. More information about TIO complaints and complaint issues is available at www.tio.com.au. 1 A complaint is defined as an expression of grievance or dissatisfaction about a matter within the TIO s jurisdiction that the TIO Member concerned has had an opportunity to consider. Page 1
TIO Approach to the Consultation Paper In considering the Consultation Paper on the Structure of Australia s Telephone Numbering Plan (the Numbering Plan), the TIO has focused primarily on the potential impact that changes to the structure of the Numbering Plan would have on telecommunications products/services and consequently on consumers. In the TIO s experience, any significant change to pricing or policy, or the release of a new product onto the market can result in detriment to consumers and complaints to the TIO. This is primarily driven by consumers who: 1. do not fully understand what the policy, product or service is. This can result in a disconnect between what the consumer is seeking and what they have purchased 2. are unaware of other options in the market that may better suit their needs, both from functionality and pricing perspectives, and are unaware of where to obtain this information 3. receive and are charged for services for which they did not provide informed consent. The TIO considers it critical that all consumers be able to make fully informed decisions about their telecommunications services, in particular that consumers have the necessary tools to choose between the range of services available to them, and the full range of costs that may be applied to those services. Any changes to the Numbering Plan will likely result in changes to how consumers will need to use services in order to obtain maximum cost efficiency. The TIO is therefore pleased to see that the principles of price transparency and clarity will remain integral to the design of the Numbering Plan. We set out in this submission: a brief overview of complaints that the TIO commonly receives that are relevant to the Numbering Plan observations that we believe merit consideration before changes are made to the structure of the Numbering Plan so that any consumer detriment is minimised our comments, where relevant, on some of the assumptions made in the Consultation Paper some suggestions for consideration by the Australian Communications and Media Authority (the ACMA) in its future work program for the Numbering Plan. Page 2
Complaints to the TIO Jurisdiction of the TIO The jurisdiction of the TIO is set out in the TIO Constitution (available at www.tio.com.au), a summary of which is set out in Appendix A. This jurisdiction includes investigating and facilitating the resolution of complaints about standard telephone services, mobile and internet services, directory assistance, White Pages listings, and billing for these services. Complaints relating to, among others, the 000 emergency service, business directories, the setting of tariffs, matters of telecommunications policy, or commercial activities of service providers are outside the TIO s functions. Likely impact of changes to the Numbering Plan on Complaints There are a number of areas in which changes to the Numbering Plan may affect consumers and hence complaints to the TIO. Based on our experience in dealing with complaints about numbering, while matters relating to disputed charges are perhaps the most common, the TIO would also envisage an increase in complaints relating to: directory assistance o where a consumer requests a listing for a geographically local service but is given information for something within the geographic number range, but outside the local area, or o where a consumer is told that a personal listing is not available for the geographic area in which they are looking, or is given a service number they believe to be incorrect as it is outside the expected geographic numbering range printed and electronic White Pages o where a listing appears in an incorrect printed directory because of a mismatch in number and/or address data o where a consumer is unable to list their number in the White Pages as it is a nongeographic number. This could include where the number has previously been listed as a geographic number but has been altered by the VoIP provider and may no longer be listed see Case Study #1 below Yellow Pages complaints o whilst Section 4.3(c) of the TIO Constitution states that the TIO has no jurisdiction over business directories, the TIO does investigate complaints where a consumer claims to have contacted the Yellow Pages and been charged incorrectly, or charged for services they did not receive for example, for incorrect directory information. As indicated above, the TIO does not have jurisdiction to investigate complaints relating to the setting of tariffs or commercial activities of service providers. In the TIO s experience, when service Page 3
providers implement significant changes to pricing, the TIO receives an increased number of contacts from consumers which we record as out of jurisdiction enquiries relating to commercial decisions/tariffs set by these providers. Likewise, the TIO does not have jurisdiction to investigate complaints relating to matters of telecommunications policy. Where a consumer has a concern relating to a change in numbering policy, in many cases the TIO would likely view them as enquiries that are out of our jurisdiction. However, the TIO may investigate claims by consumers that they have been charged for services in a manner which is inconsistent with the service agreements they have with their suppliers where, for example, they have not been informed of pricing changes. For this reason, the TIO sees the provision of information to consumers as critical for any proposed changes to the Numbering Plan. Case Study #1 Ms Weaver contacted the TIO after being advised that she was unable to list her telephone number in the White Pages, despite the number having been listed in her name at the same address for the last 7 years. Ms Weaver claimed that approximately six months previously, she had transferred her telephone number from a standard telephone service to a VoIP service provider. Ms Weaver claimed that she was now advised that as her number was no longer a geographical number, it could not be included in the White Pages. The TIO has had no further contact from Ms Weaver since referring her to the senior level of complaint with her VoIP service provider. Complaints relevant to the Numbering Plan The TIO captures complaints related to numbering under 2 categories in its complaints management system, namely Billing and Payments and Provisioning. In 2009-10, the TIO recorded 37,318 complaint issues about Billing and Payments for landline services and 51,687 for mobile services. Of these, 2,234 related specifically to disputed usage charges for timed calls from a landline service, and 3,212 for disputed usage charges for timed calls from a mobile service. Graph 1 shows the number of complaint issues recorded about disputed usage charges for timed calls over the past four years. Page 4
Graph 1: Disputed Usage Charges for Timed Calls by Service Type Complaint Issues 4000 3000 2000 1000 0 Disputed Usage Charges for Timed Calls by Service Type 2006/07 2007/08 2008/09 2009/10 Mobile Landline In 2009-10, the TIO recorded 6,426 complaint issues relating to provisioning of landline services and 1,440 for mobile services. Of these, 8.9% of landline provisioning issues and 38.7% of mobile provisioning issues related to number allocation. Graph 2 shows the number of complaint issues recorded about number allocation issues over the past four years. Graph 2: Number Allocation Issues by Service Type 800 Number Allocation Issues by Service Type Complaint Issues 600 400 200 0 2006/07 2007/08 2008/09 2009/10 Mobile Landline The TIO s complaint handling system does not identify how many of these types of complaints relate to errors in numbering, such as consumers claiming they have been charged long distance rates for calling a number they believed to be local. However, on reviewing the complaint handling notes for these complaints, we have identified some common issues that may be relevant to the Numbering Plan: Disputed call charges for long distance call rates to a service that the consumer believed to be a local call. Complaints of this nature were historically seen in relation to dial in numbers to internet Points of Presence, and have decreased significantly with the decrease in dial up Page 5
services. The TIO is also starting to see more of these complaints as consumers dispute call charges to non-geographic VoIP services. Number allocation complaints range from claims that the consumer was given a different number to that which they agreed to at point of sale, to claims the number allocated is outside the normal number range in their geographic location, resulting in long distance charges for calling what the consumer believed should have been a local call. The TIO believes that the latter type of complaint most commonly occur when geographic numbers are allocated to VoIP services. A large number of mobile number allocation complaints appear related to difficulties in porting mobile service numbers (MSN) between mobile providers as well as changing from pre-paid to post paid with the same providers. A common theme appears that when some consumers port their service, rather than their original MSN porting across, a new MSN is connected on the gaining service provider s network. As the consumer is able to continue making outgoing calls, the problem is identified when they realise they are not receiving incoming calls. By this time, their original number is either not available on the gaining service provider s network, has been quarantined by the losing service provider as a disconnected number, or has been allocated and connected to a new consumer. A large number of landline number allocation complaints appear related to delays in porting landline numbers between networks. In a number of complaints, the gaining service provider has experienced some delays in porting the service number, and allocated an interim number until such time as the original number is ported. When the consumer questions when their original number will be available, they are told that the number is not available on the new network as it was allocated to their previous provider, and that they can no longer have their original number. Complaints of this nature may also be further compounded when the consumer ports back to their original provider for the purposes of reclaiming their original number, only to be advised that the number is either in quarantine, or has already been allocated to another consumer. Disputed call charges to 1300 numbers under fixed service capped pricing plans. With the introduction of capped pricing plans, or plans that include free local calls, for fixed services, the TIO has recorded a number of complaints where consumers are charged for calls to 1300 numbers that they believed should have been free calls within their capped pricing plan. Whilst the TIO accepts that the pricing of 1300 services is largely a commercial matter for service providers, the TIO does have the power to investigate complaints where the consumer claims they were given incorrect information at point of sale. The TIO is is also approached by consumers who do not understand that calls to 1300 services are not local calls. Page 6
As we are not able to provide specific complaint data regarding the above issues, we outline below, a few case studies to demonstrate the nature of these complaints and the impact these issues may have on consumers. Case Study #2 Mr Darcy contacted the TIO after experiencing problems with transferring his telephone number from a fixed landline service to a wireless service with the gaining service provider. Mr Darcy claimed that despite being told he would be able to keep his phone number on the wireless service, as the number had originally been issued by another provider, he would be unable to transfer it. Mr Darcy claimed that when he agreed to transfer his service, the gaining service provider advised him that in order to keep his telephone number, he would need to transfer his telephone number to Telstra, and then to the gaining service provider. In order to utilise the pricing of the new wireless service whilst the number transfer took place, Mr Darcy was allocated a temporary number. Mr Darcy claims that the gaining service provider then asked him to keep the temporary number as it was unable to connect his original number to the wireless service. The TIO raised the complaint with the gaining service provider. In resolution to the complaint, the gaining service provider eventually connected Mr Darcy s original service number to the wireless service. Case Study #3 Ms Rutherford contacted the TIO and disputed STD call rates to connect with her ISP s point of presence number. The complainant claimed that after experiencing drop outs with her internet connection, her 15 year old daughter contacted her ISP and was given an alternative number to connect to the internet. Ms Rutherford claimed that, whilst the ISP asked if Sydney was a local call, her daughter would have assumed Sydney was local as they do not need to enter a 02 prefix and was unaware of the implications of dialling a long distance number. In its response, the ISP advised that it had not acted improperly in giving information to someone other than the account holder, as the information was not of a personal or sensitive nature. It also claimed that that it was not responsible for expenses incurred as a result of the information as it had asked Ms Rutherford s daughter whether Sydney was a local call, and was not in a position to know that the daughter was 15. The TIO found that the ISP was aware that Ms Rutherford lived in the Central Coast of New South Wales and it ought to have reasonably known that calling a Sydney number would not be a local call from Ms Rutherford s home. After raising this issue with the ISP, the ISP agreed to reimburse Ms Rutherford for the STD charges she incurred as a result of connecting to the Sydney based point of presence number for her internet service. Page 7
Case Study #4 Mr Ishak was on a plan that included a set number of local calls per month at no charge. He contacted the TIO claiming that for the last 18 months he has been billed STD call rates for calling a number that was only 7km from his home in Canberra. In its response, Mr Ishak s telephone company advised that he had been correctly charged as the number he was calling from was located in the Marsden Zone, and the called number was in the Albury Zone. It further advised that a call from Marsden to Albury is classed as STD as the zones are non-adjacent in the ACMA Numbering Plan (between 165-500 km apart). The telephone company further advised that the information it was able to obtain on the number came via the ACMA s online numbering system, and that it was unable to provide further information as the number was connected via a separate network. As a gesture of goodwill, the telephone company refunded all disputed charges to Mr Ishak. General observations about the Numbering Plan Integrated Public Number Database The rollout of the National Broadband Network may result in different pricing approaches from service providers as reliance on the copper network reduces. Pricing over fibre has more potential to resemble VoIP pricing, potentially removing the cost differential for timed versus untimed calls. If this were the case, the key issue that would need to be addressed if cost differential is no longer critical to the structure of the Numbering Plan, is the value in the numbering information to users which includes not only consumers, but users of the Integrated Public Number Database (IPND). The TIO understands that the ACMA has, in the course of its previous proposal around geographic numbers (the Geographic Numbering Amendments Discussion Paper) considered the context of calls to emergency numbers. The TIO, too, has considered the implications for consumers with geographic numbers who have cause to dial the emergency services. The TIO has come across complaints where the IPND does not feature the most up to date information and it is likely that, in circumstances where a consumer has a geographic number that varies from their physical location and where the IPND does not reflect this, consumers nominating such a number may need to be aware of potential delays in accessing emergency services in their area. This may be of particular concern for consumers who have life-threatening medical conditions. Page 8
1300/1800 numbers The TIO has some concerns in relation to: a. the routing of calls from consumers to 1300 and 1800 numbers b. the accuracy and usefulness of information provided to consumers who contact directory services looking for local services c. charging for calls to 1300/1800 numbers from mobile services. 1800/1300 account holders are able to tailor the services they receive calls from, not only distinguishing between accepting calls from mobiles or fixed services, but based on the geographic location of the calling party, which are predominantly determined by the originating service number. The TIO sees a potential for complaints both from callers to 1300/1800 numbers who have been routed to an incorrect answering point, and from small business consumers with 1300/1800 numbers who have incurred charges for calls received from outside their agreed call catchment areas. The TIO notes the increasing use of 1300/1800 numbers by business, essential services and community organisations. With more and more consumers using mobile phones as their primary telephone, the TIO is aware that these consumers incur timed call charges to contact numbers that would otherwise be an untimed, or free, call. This can be of particular concern for vulnerable consumers or those in financial difficulties who may be trying to access various counselling or support services, or those who may be trying to resolve a dispute or negotiate a payment arrangement with their service provider. To ensure fair access to critical services, the TIO strongly supports removing any distinction between calls from mobile services or from landline services to 1300/1800 numbers. Consumers should, in our view, incur the same untimed, or free, call to 1300/1800 numbers regardless of whether the call is from a mobile or landline service. Numbering for Outbound Services The TIO notes that changes to the Numbering Plan may allow service providers to allocate geographical and Location Independent Communication Service (LICS) numbers to VoIP-out and other outbound calls only services. Whilst the TIO considers that such changes may have benefit to consumers, this is only provided that consumers are fully informed of any and all limitations associated with their particular choice of telephone number. Page 9
Geographical Numbering The TIO has previously acknowledged the advantages of the ACMA s proposed changes to the Numbering Plan (Geographic Numbering Amendments Discussion Paper) especially since a number of these changes reflect current (and unregulated) numbering practices. The introduction of mandatory communication of information to consumers who are allocated geographic numbers outside their physical location will, in the TIO s view, introduce a valuable safeguard for these consumers. However, the TIO is concerned about the financial impact that proposed changes may have on consumers who make calls to services which have been allocated numbers that do not correspond with the physical location of the people they are calling. In the TIO s opinion, many consumers may struggle to understand the intricacies of how Australia s geographic numbering works. Most consumers will recognise a telephone number as belonging to another geographical location by virtue of the area code attached to that number. Based on the nature of the area code, they will subsequently make an informed choice as to either make or not make the call. In the TIO s experience, the majority of consumers would not expect that the geographic number they are calling perhaps to a friend or family member residing in their local area would be charged at rates other than local call rates. The TIO believes that at least in the initial period before awareness of these implications is raised, some consumers are likely to face financial detriment. Such a mechanism of charging may also pose challenges for any service provider or agency seeking to assist consumers to understand that calls terminating in their local area could attract charges over and above those applicable to a local call. In this respect, and based on our experience handling a range of different billing complaints, the TIO is concerned that it may be difficult for consumers to identify charges for calls made to geographic numbers because: there does not appear to be common understanding amongst consumers that service providers can allocate geographic numbers that do not correspond with the physical location of the service landline bills are becoming more simplified and call charges are often not itemised, meaning that consumers may not realise they have been charged at rates other than local call rates. In addition, were a consumer to identify that they had been billed at long distance rates for making what they believed to be a local call, the TIO anticipates that queries or complaints arising out of such circumstances may be difficult to resolve. Long distance call charges to reach people who live in the same locality would, for many consumers, appear counter-intuitive. Page 10
Assumptions made in the Consultation Paper Contiguous numbers on different exchanges The Consultation Paper makes reference to consumers being currently able to keep their geographic number when moving from one service provider to another, causing numbers within a contiguous block to no longer necessarily be within the same exchange. Whilst this is the case and consumers porting between providers may take a geographic number from one exchange to another, under current practice the exchanges of both providers must still be within the immediate geographic location. At present, local number portability does not allow for consumers to move outside of their local exchange area. Allowing ports outside of a local exchange area will likely require new processes among carriage service providers and education for all users of telecommunications services. Mobile phone pricing having no distinction between local and long distance calls The ACMA has made reference to the increasing dominance of mobile phones in the Australian market, that mobile phone pricing does not differentiate between local and long distance calls and that the use of capped plans further reduces this distinction. Whilst the TIO accepts that there is frequently no distinction between calls to local or long distance numbers, the TIO also notes that the cost of calls from mobile phones is driven by the technological capabilities of the call, specifically the ability of the mobile caller to move between mobile zones whilst retaining the call connection. The TIO is of the view that the most important aspect of mobile charging regimes is that consumers still have the discretion to decide what calls to make based on the type of service, the network utilised (for example, global roaming, network roaming) and the cost treatments of these options under their plans. Increasing take up of capped plans for fixed services The Consultation Paper makes reference to an increasing number of consumers taking up capped plans on fixed services, and that the distinction between local and long distance is muted due to both types of calls frequently being included in call allowances. The TIO notes that many capped plans have a nominated dollar amount or value, with individual calls being calculated according to any underlying price structure. Once the consumer exceeds the value allowed under their plan, they incur additional call charges. Consumers therefore still make decisions as to what types of calls to make, using the underlying pricing as a tool to best utilise the plan s cap. For example, some consumers prefer to use a local call number over a 1300 number for a business in their area as local calls are included in their plan s cap and 1300 calls are not. Conversely, some consumers will elect to incur a 30 cent call charge to a 1300 number when it Page 11
would otherwise be a long distance call charge and have greater impact on their included call allowance. Call forwarding out of geographical areas Whilst the ability for consumers to forward incoming calls to their geographic number to any other chosen number does mean that the calling party cannot reliably predict the final destination of the call, they can make an informed pricing decision about the cost of the call. This is because, under current pricing practices for call forwarding, the calling party only pays the cost of the call to the number they originally called, as the called party pays for the costs associated with forwarding the call. Further considerations and suggestions To minimise consumer confusion, the TIO suggests that effective measures to improve general consumer awareness about the workings of any revised Numbering Plan would be necessary. Such measures might include a mechanism by which consumers can identify when particular calls are going to attract long distance or timed-call charges. One such measure could be to require a message to be played to a consumer if they dial a geographic number that is outside the physical location of the service to alert them before higher call rates begin to accrue. There are also a number of key measures that service providers could employ to minimise any consumer detriment arising from any changes to the Numbering Plan. These include: simplicity ensuring that all marketing and pricing structures are simple, accessible and easy to understand for all consumers, whether new or existing informed decision making ensuring that any changes to current practices can be easily communicated well in advance of implementation to allow all consumers to make informed decisions prior to incurring charges effective complaint handling ensuring that all potential complaints are able to be quickly identified and resolved, with processes in place to ensure that service providers have ready access to all information required to quickly resolve issues. At present, when users of telecommunications services make a call they are able to select their preferred method of communication based on a number of factors, including cost, reliability of service, quality of service, and the likelihood of being able to contact the called party on the chosen service. These options are provided to a large extent by the current numbering system which allows consumers who contact mobiles to choose higher call costs for greater likelihood of reaching the Page 12
called party, but at the risk of call dropouts, depending on where the called party is at the time of the call. Likewise, calling a local call number may be cheaper with no chance of call drop out, but with greater likelihood the called party will not answer, that the call with go to voicemail, or the call will be answered by someone other than the person they are trying to reach. By removing the current numbering parameters, and by allocating geographic numbers to VoIP services, consumers would have less information regarding the destination of the service they are dialling and the costs that their calls with their incur. A further concern is the varied quality of VoIP. Whilst the ACMA has stated in its Consultation Paper that the quality of VoIP services are in some cases higher than that of fixed services, in the TIO s experience, there are VoIP services that are of a lower quality. The TIO is of the view that where there is no cost differential for a call, no quality differential should exist either. Page 13
Appendix A Extracted from the TIO Constitution available at www.tio.com.au: 4.1 The functions of the TIO include, but are not limited to, investigating and facilitating the resolution of complaints as the following: the standard telephone service; the provision of access to the Internet or another public electronic communications network (including complaints relating to billing for such a service); public mobile telecommunications services; operator services; directory assistance; fault reporting and repair and maintenance services; printed and electronic white pages; billing not in accordance with a tariff or terms and conditions which are, under Part 23 of The Telecommunications Act 1997, applicable; failure to supply a good or service in accordance with a tariff or terms and conditions which are, under Part 23 of The Telecommunications Act 1997, applicable; interference with the privacy of an individual in terms of non-compliance with the Information Privacy Principles contained in s.14 of the Privacy Act 1988 or any industry specific privacy standards which may apply from time to time; an end-user, or an intended end-user, of a carriage service being unable to access that carriage service as a result of a failure to supply or a defect in any mobile phone handset, or other equipment designed to facilitate access to a carriage service, where that handset or other equipment is, or is to be, supplied by a member who supplies or has agreed to supply the carriage service, a related entity of such a member, or an entity which has a contractual relationship with such a member or with a related entity of such a member under which that other entity solicits, or received applications for, persons to become end-users of the carriage service; and the recovery of debts owed or allegedly owed by customers whether by members, their agents or factors. 4.3 The functions of the TIO do not extend to complaints relating to: (a) the provision or supply of customer premises equipment, other than the non-switching handset that terminates the standard telephone service and auxiliary goods supplied under a tariff or in accordance with terms and conditions applicable under Part 23 of The Telecommunications Act 1997; (b) cabling beyond the network termination point, other than cabling from the network termination point to the first telephone and, in the case of residential carriage services, cabling to other extensions of that service within the residential premises; Page 14
(c) business directories, including but not limited to "Yellow Pages"; (d) commercial activities which do not include the provision of carriage services; (e) the setting of tariffs; (f) the 000 emergency service; (g) Universal Service Obligation policy matters; (h) matters of telecommunications policy; (i) matters which may involve anti-competitive behaviour or restrictive practices potentially in breach of the Trade Practices Act 1974; (j) matters which are specifically under consideration by the Australian Communications Authority, the Australian Competition and Consumer Commission or any court or tribunal, or which have been considered by any of those bodies previously; (k) the content of a content service (as defined in The Telecommunications Act 1997); (l) an alleged breach of an industry code or industry standard by a member of the Telecommunications Industry Ombudsman Limited, where the complaint is made by a member of the Telecommunications Industry Ombudsman Limited or another industry participant; and (m) the billing of a carriage service or of a content service supplied by a carriage service or relating to a credit management action including debt recovery action, by a member, unless the person complaining has paid all undisputed charges or such amount of charges as, in the opinion of the Ombudsman, are reasonable. Page 15