PhonepayPlus consultation on Part 4 (Investigations and Sanctions) of the code

PhonepayPlus launched their consultation on its 14th edition of the Code of Practice following a review of Part 4 of the Code.

Part 4 is the area of the Code which sets out the procedures PhonepayPlus uses when investigating, adjudicating and where appropriate imposing sanctions in response to allegations of consumer harm. Part 4 also currently sets out procedures for appeals following any adjudication.

AIMEs response to the consultation is to support the broad concepts of a fair, proportionate, accessible and negotiable process, but we have concerns on the details of the process viewed through a cynical lens and we believe that the process needs an accessible review or appeals process to ensure that providers are not denied the justice that a Judicial Review could bring but at great cost to themselves and obviously to industry, if PhonepayPlus lose the review.

While AIME members do not anticipate being subject to a Track 2 investigation, we urge familiarity with both the process and our recommendations to PhonepayPlus.