Ofwat - an MCA blog

Featured article - 14 December 2017
By Dannii Leivers, Senior Associate, Strategy and Policy, Ofwat

The world we live in is increasingly driven by technology and data. Regulators want utility companies to use this data and insight to understand their customers, to ensure they receive a tailored, seamless and stress-free customer experience. This is more important than ever because vulnerability is an issue facing customers across all sectors … and it is here to stay. We know that customers move in and out of vulnerable situations. Therefore, identifying those who might need extra support is a challenge.

Ofwat, the economic regulator for the water and waste water sector in England and Wales, and Ofgem, the UK energy regulator, through the UK Regulators Network (UKRN) have published a report which sets out how our two sectors can work together to make better use of customer data to support those who may be vulnerable.

The Mental Capacity Act1 is in place to empower people to make decisions, and to support them if their capacity to make decisions is impaired. Customers should always understand why their data is being collected and, if applicable, with whom it is being shared. Customers are more empowered when there is transparency, and they have access to and control over the data held on them by companies. For some customers control is an essential factor that determines their choices and empowers them to make informed decisions about how their data is used and shared.

Water and energy companies offer free, non-financial support (such as accessible bills, help with water meter readings, or targeted support in case of an emergency) to their customers through their respective special assistance registers and priority services registers (PSRs). These services in water and energy are very similar – customers who need support from their water company often need the support from their energy company too, and vice versa.

If water and energy companies share the non-financial data they hold about their customers who would benefit from extra support, they will be able to provide better support and a seamless, stress-free experience. This should limit the need for customers to have the same, potentially upsetting conversation, divulging sensitive personal information on repeated occasions. We understand this can be especially difficult where the issues faced by customers are less widely understood, for example, where customers have certain mental health challenges. We are pleased to see that all companies have ensured their staff are mindful of the The Mental Capacity Act and the five principles which underpin it.2 Some water companies have also implemented training for their staff covering dementia awareness and mental health. This is a great start but we’d like to see all companies go further. We encourage companies to introduce a cultural change within their organisations and ensure their staff are empathetic and trained to help those who need it most.

Our report highlights the positive collaboration already taking place between water and energy companies and sets out expectations for how they can work towards cross-sector sharing of non-financial vulnerability data. We will be contributing to and monitoring the progress of a joint working group, established by Water UK and the Energy Network Association, who are launching a vulnerability data-sharing pilot programme in the North West and will be working towards developing data sharing arrangements across the two sectors by 2020. The working group will report on their progress on a quarterly basis from January 2018. Ofwat and Ofgem, through the UKRN, will publish a follow-up paper with updates on company progress in autumn 2018.

If you are interested in this work or in engaging with us further, please contact vulnerability@ofgem.gov.uk or ukrn@ofwat.gsi.gov.uk. For further information on the UKRN, please contact sophie.richings@ofcom.org.uk.

1 Mental Capacity Act 2005, source: https://www.legislation.gov.uk/ukpga/2005/9/contents, page accessed on 12/12/2017 2 Source: The Consumer Council for Water (CCW)

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