Do existing consumers have to opt-in before I can consider they ‘envisage’ receiving unsolicited real time promotions?
For a consumer with whom a firm has an established existing customer relationship with, to ‘envisage receiving unsolicited real time promotions’ the firm must point out that its policy is to call consumers from time to time. It is unacceptable for a firm to hide this information in standard terms and conditions – it must specifically bring it to the consumer’s attention. The consumer must expect to be called in the future to discuss the mortgage (or qualifying credit) arrangements; there must be an element of prior knowledge or consciousness of the likelihood of being called (or visited). We believe firms should allow consumers to opt-out of receiving such calls, and that this should be easy for the consumer to do. For our view on the effect of Telephone Preference Service (TPS) registration on a firm’s ability to call consumers, see below.
