Guidance

PSTN non-voluntary migration checklist

Published 18 November 2024

We, as Communications Providers (CPs), recognise that the non-voluntary migrations from analogue to digital landlines may put vulnerable customers at risk unless significant customer protections are included in business processes. Our preference is always to gain customers’ full consent prior to migrating them.  

However, it will never be possible to engage every single customer, and as the PSTN network decays, there is a safety need to move everyone to new networks.  

With this in mind, we as CPs will not undertake any non-voluntary migrations from analogue to digital landlines, until we have completed the following mitigatory steps:

1. We will meet with the Minister of State for Data Protection and Telecoms (or relevant officials, depending on the Minister’s preference) to explain our approach to keeping customers safe throughout our non-voluntary migration journey.

2. We will contact customers well in advance of their non-voluntary migration. As per Ofcom’s General Conditions, communication with customers will be made in a format that reflects their needs, including accessible communications where required. Wherever possible, we will issue at least two different forms of communication, e.g. via emails, SMS, physical letters, phone calls, and/or door knocking. Communication with customers will clearly state the proposed migration date and will explicitly request that the customer confirms whether they are a telecare user. Communication will also clearly signpost means for customers to get in touch and speak to someone if they have questions or concerns.

3. We will make exhaustive efforts to sign data sharing agreements with all local authorities that serve our customers, and put in place other checks (such as assessing whether customer lines have dialled Alarm Receiving Centre (ARC) numbers) so that we can identify as many telecare users as possible. 

4. We will work to identify users who may need additional support through the migration, as per the supported journeys definition. If a customer is identified as being in need of additional support, we will offer them an engineer visit, free to the end customer, to support them through the transition.

5. If a customer raises a complaint that their telephone line has been disconnected and/or that their telecare device does not function as a result of the migration from PSTN to VoIP, we will ensure that their telephone and/or telecare service is restored as a priority. In certain circumstances – where there are no alternative solutions and where this is technically feasible – this can include reinstating the PSTN temporarily.

6. In all supported migration journeys where resilience solutions (including battery back-up units) are provided, we will provide solutions that go beyond the Ofcom minimum of 1 hour of continued, uninterrupted access to emergency services in the event of a power outage. Instead, we will aim to have solutions which maximise resilience as far as is possible.

7. We will (re)start non-voluntary migrations with a smaller cohort to ensure our business processes are robust, before rolling out the practice at scale. The first non-voluntary migrations will be focusing on customer groups who are least likely to come to harm (e.g. those who are highly infrequent landline users and have no vulnerability flags). 

8Z. Known telecare users will only undergo unsupported non-voluntary migrations as an absolute last resort – we will take exhaustive steps to avoid this.

Technical notes 

1. By non-voluntary migrations to digital landlines, we mean migrations where: 

a. any action needs to be taken by the consumer in order for their telephony service to continue functioning in full, and
b. the consumer has not engaged in the process of transition, and
c. the consumer has used the landline in the last 12 months 

2. Government commits to helping CPs with their engagement with Local Authorities (LAs) in order to enable CPs to take exhaustive steps to sign data sharing agreements (DSAs). This includes central Government officials having direct engagement with non-cooperative LAs, and seeking assurances from the Information Commissioner’s Office (ICO) that it is appropriate for LAs to sign DSAs.

3. We expect Network Operators (NOs) to work with CPs to ensure non-voluntary migrations are safe and secure. In particular, we expect Network Operators and CPs to work together to enable engineering visits for customers who need additional support in migration journeys that require them to take some form of setup action^{[footnote 1]}, where practicable. We also expect Network Operators to assist CPs where practicable with priority restoration of landlines for customers who raise an issue about experiencing a loss of telephone service, and/or a non-functioning telecare device, within a month following their migration.

4. Government acknowledges the risks associated with customers - particularly telecare users – remaining on the PSTN as outages and failures increase over time. It is therefore expected that telecare users should be migrated where there is sufficient support and guardrails in place to do so safely, and not left on the PSTN for longer than necessary. 

1. Certain migration journeys may require the customer themselves to change their connectivity setup, e.g. by plugging a telephone cable into a router, and/or amend which socket their telecare device is plugged into. This will depend on the type of underlying technology used to provide voice connectivity.  As a result, we do not expect this checklist to apply to migrations whereby consumers do not need to take any action and the shift happens at an exchange level or in the core network. Examples include, but are not limited to, when a customer is moved to Single Order Transitional Access Product (SOTAP); when a customer is moved to Metallic Path Facility (MPF); or when a customer is moved to Pre-Digital Phone Line (PDPL) once this product is launched. ↩