Supported journeys: defining vulnerability during the PSTN migration
Guidance for communication providers on how to identify and support 'vulnerable' customers when their landline migrates from analogue to digital networks.
This guidance aims to help communication providers identify customers that will require additional support when their landline migrates from analogue to digital networks.
In December 2023, the major UK communications providers signed a “Public Switched Telephone Network (PSTN) Charter” committing to improve protections for vulnerable people throughout the migration from analogue to digital landlines (“the PSTN migration”). The UK’s largest Network Operators signed a complementary charter in March 2024. Both charters contain a commitment to work to agree on a shared definition of vulnerability in the context of the PSTN migration.
Defining ‘supported journeys’
The commitment in the PSTN charter refers to agreeing a definition of ‘vulnerability’. However, it has been agreed collectively that ‘vulnerability’ is not the most suitable term to use in this guidance. This is because not all people who require additional support with the migration consider themselves to be vulnerable, and also to avoid confusing this guidance with what has already been issued by Ofcom regarding telecoms and vulnerability. Instead, the focus on this document is on those who will, or will be likely to, require additional support (also referred to as “supported journeys”) specifically in the context of their landlines being migrated from analogue to digital. In addition to agreeing a shared identification criteria for consumers who may require additional support during the PSTN migration, we will work with telecoms companies; members’ organisations; charities; key non-telecoms sectors (such as telecare service providers); other government departments; and others to discuss approaches for mitigating risks to different vulnerable groups.
We define ‘supported journeys’ as applicable to users that may be at a heightened risk of suffering harmful outcomes. This includes, but is not limited to incidents posing risks to life or risks of injury. It also includes issues like a heightened sense of anxiety, stress or loneliness as part of the migration, where additional support and protection is required to mitigate or avoid the risk of these outcomes occurring.
To illustrate this further, certain customers may require additional support to install upgraded devices. Certain customers are more likely to need quick access to emergency services and may require additional mitigations to ensure continued access to these services in the event of a power cut, such as a battery back-up unit.
We acknowledge that identifying customers who may be exposed to a heightened risk during the PSTN migration is a complex and multidimensional process. An individual may experience one factor, and/or a combination of factors, which puts them in a position of risk. These factors can be:
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intrinsic (where customers may suffer from e.g. a permanent health condition or disability that increases their need for additional support)
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temporary (where customers may be at a heightened stage of risk for a time-bound period)
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circumstantial (where customers who are otherwise not at risk may be reliant on their landline as their only means of communication).
Identifying customers who need a supported journey
We recognise that many customers may be at risk due to several factors, whilst also acknowledging the rights of individuals, their sensitive data and the limitations of communication providers to accurately identify such customers in this context.
We therefore propose 2 categories of individuals: Those that communications providers should identify; and those who may wish to self-identify.
Should identify
These are individuals that communication providers should be reasonably able to identify, either because the communication provider holds this information on their records or can access it through other parties like alarm receiving centres (ARC) and Local Authorities (LAs).
These include:
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Users of telecare/social alarm/medical equipment: customers that are most likely to require the assistance of a caregiver or emergency services.
Information can be accessed through ARC or Local Authorities (via data sharing agreements), and by asking customers directly if they use telecare devices. Find guidance from the Local Government Association (LGA) about digital switchover telecare data sharing.
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Landline dependency: customers that may not have access to other communication alternatives, either because they live in a mobile not-spot area, or because they have opted against taking up other forms of connectivity (e.g. broadband or a mobile phone). These customers may be at risk of not having any methods of contacting emergency services specifically because of and during the PSTN migration.
Information that can reasonably be expected to be held on record by communication providers including service usage, service subscriptions, and publicly available datasets like Ofcom’s wireless connectivity coverage. The direct consumers might also choose to flag their landline dependency as part of self-identification (self-identifying as being exposed to a heightened risk).
Self-identify
Individuals self-identifying as being exposed to a heightened risk and requiring a supported journey.
Given the complexity of categorising customers who may require additional support during the PSTN migration, we believe customers must be given an opportunity to self-identify and (should they wish) provide details as to why they believe they require additional support. DSIT notes that many communication providers already use customer self-identification to understand who needs additional support for other operational matters.
Customers may self-identify for various reasons, including but not limited to:
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Permanent mental/physical disability or serious illness or age-related risks: this includes individuals who experience permanent conditions like visual, auditory, learning, or physical impediments, or other chronic illnesses. This also include individuals who suffer from age related risks and health conditions.
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Temporary mental/physical disability or serious illness: this includes individuals who experience significant impediments for a period of time, for example those recovering from significant surgery.
It is recognised that – as well as complying with Ofcom’s broader expectations in relation to vulnerable customers – many communication providers already have processes in place to provide customers with additional support. This includes keeping records of customers:
- with known entitlement to priority fault repair
- who use relay services
- with third party bill management in place
The above guidance is intended to be supplementary to existing processes, with a specific focus on the PSTN migration.
What we expect of communication providers
We expect communication providers to ensure they have adequate processes to identify customers in need of additional support as part of the migration from analogue to digital landlines. We also expect communication providers to continue to comply with Ofcom’s expectations in relation to vulnerable customers, as set out in Ofcom’s General Conditions of Entitlement and Ofcom’s guide for providers on treating vulnerable customers fairly. These guides ensure vulnerable people receive the right support and services that meet their needs.
Ofcom’s General Conditions of Entitlement require communications providers to have clear and effective policies in place for the fair and appropriate treatment of vulnerable customers. The conditions also set out a number of specific services that communication providers must offer to people with disabilities to ensure they can engage with communications services. In addition, Ofcom’s guide to treating vulnerable customers fairly suggests practical measures that providers could adopt to ensure that they treat their vulnerable customers fairly, covering a range of areas. Ofcom expects communications providers to consider the measures suggested within their practice.
This guidance has been collectively drafted by the:
- Department for Science, Innovation and Technology (DSIT)
- Department for Health and Social Care (DHSC)
- Ministry for Housing, Communities and Local Government (MHCLG)
- Ofcom
- TEC Services Association (TSA)
- Independent Networks Cooperative Association (INCA)
- Communication providers who are signatories of the PSTN charter
- Charities working in the care domain