Response to Call for Input – Digital Regulation Co-operation Forum Workplan 2025/6

Thank you for the opportunity to comment on the DRCF Workplan for 2025/2026. Below is background to the Communications Ombudsman and The Internet Commission, followed by our comments on the call for input on the forthcoming workplan.

Background to Communications Ombudsman and The Internet Commission

Trust Alliance Group (TAG) is a private limited company established in 2002 which runs a range of discrete national Alternative Dispute Resolution (ADR) schemes across different sectors, including the Communications Ombudsman, approved by Ofcom, and the Ofgem-approved Energy Ombudsman.

Our purpose is to build, maintain and restore trust and confidence between consumers and businesses and we’re developing diverse capabilities and expertise in a range of areas including digital alternative dispute resolution and case management technology.

The Communications Ombudsman provides independent dispute resolution services, aiming to put consumers back into the position they were in before the issue occurred, whilst helping providers understand their customers and improve their experience.

With over 1,450 telecommunications companies signed up to our scheme - and over 15 years’ experience in the communications sector - we are one of two alternative dispute resolution (ADR) schemes approved by Ofcom to impartially and independently handle disputes between consumers and providers.

In 2023 we accepted 25,000 disputes about providers in the communications sector and, using our insight, we continue to help providers improve their customer service.

TAG has transformed its ADR offering to deliver a service that puts the consumer first and delivers a more personalised and streamlined consumer journey. We have achieved this by changing our operational procedures to ensure consumers deal with a single point of contact – from first raising their concern, right through to resolution.

We are pleased to see that, since June, our Customer Satisfaction score of 83% has risen to 84.4% and our Net Promoter Score has increased from 64.3 to 67.5.

TAG is also developing a “Future ADR” operating model which will ensure we continue to deliver on our purpose and remain relevant as markets evolve, ensuring that we meet changing consumer and supplier needs over time.

Our aim is to deliver an enhanced proposition through tech-powered people so that we can more easily extend our reach and remit whilst delivering increasing value to all stakeholders.

The Internet Commission – which promotes ethical business practice to counter online harms whilst protecting privacy and freedom of expression and increase platform accountability – was acquired by the Trust Alliance Group in 2022.

The Internet Commission offers:

• Support to organisations who want to achieve high standards in online trust and safety.
• Knowledge exchange where companies can discuss challenges and solutions related to tackling online harms.
• A bank of good practices and reporting on the state-of-the art regarding governance and procedures of moderation of user-generated content online.
  
  

Our comments

1. Which digital policy interactions or technologies would you like the DRCF to consider as it develops its workplan for 2025/26? Why are these important?

The five elements to the DRCF three-year vision remain relevant and important in ensuring the UK can deal with benefits and challenges of prevalent and emerging technologies, while supporting and enabling the economic growth of digital industries.

With any policy intention around digital technologies, it’s important to consider how to build consumer trust and confidence through robust regulation, clear advice, advocacy and routes to redress. We believe markets work well when they are underpinned by these pillars. We have responded to Ofcom consultations around the implementation of the Online Safety Act codes of practice and guidance.

TAG’s experience in operating the Communications Ombudsman and the Energy Ombudsman shows us that companies with robust and effective complaint handling processes generate a smaller volume of complaints ending in ADR. We continue to believe that the lack of ADR provision in the digital marketplace leaves a gap in transparency and leaves consumers in a situation where they are unable to challenge decisions, they feel are unfair or inaccurate.

If, in the future, it is deemed there is a need for Digital ADR under the Online Safety Act, we would be happy to work closely with Ofcom to help design a fair, efficient and effective scheme. Our experience of delivering ADR services in the energy and communications markets – coupled with our ongoing engagement with EU stakeholders developing Out of Court Dispute Settlement (ODS) under the Digital Services Act – would help us cooperate to deliver a system which offers:

• Independent redress for users to challenge disputes.
• A complete overview of issues emerging in digital markets.
• The opportunity to spot issues of concern with individual platforms.
• Clear and transparent categorisation of complaint types.
• The capture and measurement of consumer experiences and detriment.
• The ability to share information with platforms and regulators to drive improvements.

While regulation, guidance and oversight can set the standards by which the market should operate, first-hand evidence of actual user experience will not be captured and consumers will remain unable to challenge final decisions made by providers, even if they are incorrect.

2. What specific joint action would you like to see? What shared guidance, service or other outputs would you find useful?

The regulatory landscape can be shaped to account for different sources of information. In answer to both questions, we think that key component of the workplan is ensuring that voices from across industry are heard and to share data and insights to help shape and inform policy decisions. This works alongside horizon scanning and other research which seeks to identify emerging regulatory risks.

Please do not hesitate to contact us should you wish to discuss our response in more detail. We would welcome further discussions on how we can support as your workplan progresses.