Stop Sell and Migration Guidance
BACKGROUND
Since the commencement of Stop Sells in June of 2021, the Digital Office has been monitoring and helping to advise affected partnerships, with the surge in bulk or forced migrations in late Autumn of 2021 it was decided to issue advice on both these issues at the same time.
STOP SELL
What is Stop Sell?
When an exchange goes into Stop Sell it means that any customer (Corporate, public or telecare user) whose phone line connects to that exchange will no longer be able to purchase an analogue line.
Essentially, anyone looking to move house into the area, change Telecom supplier, have their line reconnected or make an upgrade to their existing phone or broadband supply will only be able to choose digital lines from that point forward.
If a customer chooses to continue with their line and make no changes there will be no immediate effect and it’s likely that neither they nor their telecare service will see any changes until something else happens.
When will Stop Sell affect us?
The Stop Sell programme leads from June 2021 up to September 2023, over that time period every telephone exchange in the UK will enter Stop Sell, with most likely to be in the last year of that period.
Therefore is has already begun to affect some Telecare Service Providers across Scotland, with new exchanges entering this phase every 3 months. A list of the exchanges set to go into Stop Sell has been provided up to a year in advance and is hosted on the Telecare Playbook (for Playbook members) here:
Analogue Telephone Switch Off Update
How will this affect Telecare?
As stated, in many cases it likely won’t, however it is an important milestone for a number of reasons;
- Many telecom companies make annual price increases in April and there is a surge of people looking to move provider after those are published. Should one of these users be in a Stop Sell area, then it is likely that the TSP will need to act as the user will have to move to a digital line.
- If there is a service user who is given notice of a ‘forced migration’ ( see Migration section) then there may be no option to roll this back and the customers digital line will remain in place.
It is important to note that while this change will be significant and not something to take lightly, the areas that have already seen exchanges move in to Stop Sell have reported that it has not yet caused them any difficulties. Conversely, it is important to keep momentum in the digital transition even if there are no stop sells announced in a set region.
How will this affect ARC’s?
At some point the ARC’s themselves will be within areas that go into Stop Sell and the first of these is scheduled to happen in April 2022, as with service users however it is unlikely to significantly impact operations unless the ARC for some reason were to require a sudden increase in lines after migration that couldn’t be handled by digital lines. This scenario remains unlikely however the Digital Office will continue consulting with partners to ensure all options are considered here.
Are there any resources to assist in identifying stop sell areas?
Not at present, we have asked regulators to look at tools to identify the map boundaries for exchange areas, but have been told tools to determine who have been affected en masse are not viable due to data being held by the various different telecom companies.
A website checker to identify if individual phone numbers are digital lines is available however at:
MIGRATION
Background
In order to manage the mass transition of British households from Analogue to Digital Telephony by end of 2025, it is clear that an ongoing migration strategy would be needed by the Telecom companies and this has now begun to rollout.
Each of the main Telecom companies (BT, Sky, Virgin, Vodafone, Talk Talk etc.) have their own slightly different strategy based on their own customer base and technology needs and therefore will also have differing timetables. Openreach are the company in charge of carrying out the work and physical upgrades to the phone network on behalf of most of those telecom companies.
Ofcom, as the industry regulator and the Department of Digital, Culture, Media and Sport (DCMS) have an overview of the process and have a role in monitoring both progress and issues.
From a telecare point of view, service users are intended to be protected from the initial stages of migration to allow Telecare Service Providers (TSP) the time to get Digital telecare solutions in place. Despite the industry and Ofcom putting provision in place to ensure this protection, there was a risk of some service users being migrated along with the general population before such provisions were in place and this is what we are seeing happen now.
As of Late November 2021 there are 3 mechanisms for migration in Scotland
- Switching - Customers approach their own or another telecom company seeking new products or a better package deal.
- Direct Sales - The Telecom Company approaches its own analogue customer base and offers them a package.
- Forced Migration – Telecom Company approaches their customers to inform them they will be migrated to digital lines on a set date, no selling or new services are involved beyond the migration. Also referred to as bulk migration.
There is likely some grey area in 1. above, as this is generally driven by customer choice and it is unlikely that many companies will turn away custom although they should at least warn of a risk and ask that a customer who is also a telecare service user speak to their alarm provider.
2 and 3 should not currently be happening, so it is difficult to ask the telecom companies to change procedures when this is in effect breaching their own guidelines. These issues have however been raised with BT and they have begun to investigate how this is happening and how to fix the issue.
In this particular set of issues BT have been identified as the principal, due in part to their brand identity with older service users and their decision to start wider migrations sooner than competitors, however there have been some few reports of the same issues with other telecom providers. However Ofcom are also being regularly updated and it is hoped that the lessons learned by BT will inform the subsequent telecom providers and prevent repetitions during their migration programmes.
What can Telecare Providers do to protect their service users and their service?
Firstly escalate the issue and ensure your senior management/governance structure are aware and that this is captured on a risk and issues register for the migration.
The simplest step to protecting the service users is to ensure that digital telecare migration is carried out in as little time as possible, as that negates any of the issues with service users being inadvertently moved to digital lines; however it will not be possible to accelerate most DT programmes.
If a service user is migrated to a digital line it may be possible for the bill payer or nominated representative to request this be rolled back to an analogue option, though this has in some cases been refused and likely will not be an option once a Stop Sell is in place.
The installation of GSM devices is the main option to replace the analogue alarm in this case as the current devices on the market can operate in digital or analogue modes and can be switched remotely to digital mode once the ARC is ready to receive signals of that kind.
In areas with a mobile blackspot this has proven more difficult and will likely require some coordination with the ARC to determine whether an unsecured Digital broadband solution is an option until such time as Encrypted Telecare alarms are available. Broadband based telecare is still a less favoured solution due to network and power resiliency options however.
Should an unencrypted broadband option be the only viable solution, The Digital Office will be able to assist with risk assessing this to ensure proper consideration of risks and issues for senior management teams.
Despite claims from suppliers that analogue alarms plugged into digital solutions will be functional, there has been no evidence provided to substantiate these claims. There is a resiliency risk as well as the potential for the signal to corrupt or be lost when transferring through phone networks. Therefore the advice from the Digital Office and from Openreach is to avoid the use of Analogue alarms into digital routers unless there is no other option. They may work when tested, but we are unable to guarantee how long they may work after that point. Further Guidance on this is available (for Playbook members) here:
Analogue Telecare in a Digital World
Communication with service users on the migration process is becoming even more important, and emphasising that they should contact their Telecare service to inform any changes or developments to their line or any messaging from the Telecoms that their line will be changing. The Digital Playbook has material to help with this if required and the DT team are happy to help adapt and brand material for individual TSP’s.
Further material will be added through template documents donated by other TSP’s and additional media such as videos is also being investigated.
East Renfrewshire have successfully trialled stickers to be placed on existing alarms and/or alarm plugs alerting Telecom engineers to the nature of the alarm and asking them to contact the ARC or other nominated number before removing or unplugging the alarm. This has proven successful at least in alerting the service when engineers have entered the house, however in a small number of cases the phone lines may be switched without a house visit.
BT have stated that their main method for identifying ( and therefore ring-fencing) Telecare Clients is to interrogate phone records and isolate anyone who has been in contact with recognised ARC phone numbers in the past 12 months ( they are currently limited to 12 months for privacy reasons). Therefore it may be beneficial if TSP’s are able to check their own records and identify any users who have not contacted them in 10-12 months or more (to allow for flex in the rolling migration pattern).
We can’t guarantee that anyone who has been in touch recently won’t be missed, but it would be virtually certain that anyone who hasn’t been in touch will be up for migration with the general population.
Digital Office Actions and Next Steps:
- Developed an online reporting process to allow service providers to report cases and build a national picture
- Attended the national Telecare Technical forum to raise awareness of the issues and risks and engage with technical teams
- Met Ofcom regularly throughout 2021 to monitor the PSTN switch off and escalate specific cases which have been raised by service providers
- Provided tactical and technical support to affected areas to identify mitigation and resolution
- Developed a range of materials and guidance for the Digital Telecare Playbook
- Liaised with Openreach to monitor progress and activity of PSTN switchover and escalate issues / concerns. Openreach provided an update to the Telecare Service Provider Forum in September 2021
- Escalated these issues to the TAG, Telecare Delivery Board and Scottish Government TEC Programme to raise awareness
- Worked with Telecare Service Providers to develop a range of guidance and resources designed to advice telecare users of the situation
The Digital Office have asked both Ofcom and BT for tools and resources to meet the challenge of both the Stop Sell and these unexpected forced migrations. We will continue to meet with them and to push them for solutions and will share any learning or updates through the regular meetings or emailed updates.
The DT team remain ready to meet with any of the TSP’s and discuss or help to develop solutions to this and other issues that will arise throughout the Digital Telecare Migration.
As of Late November 2021 we had logged 60-70 of these forced migrations across Scotland, an average of 6 for affected HSCP areas. There is clearly every probability that there are more still unaccounted and the concern is with identifying these and preventing full scale migrations until resources and digital systems are in place to accommodate them.
