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Vulnerable Consumers

About the 111 Contact Code

The Commerce Commission's 111 Contact Code is created to make sure that vulnerable consumers have reasonable access to an appropriate means of calling 111 emergency services in the event of a power cut.

The Code supports consumers who can no longer call 111 emergency services in a power cut because they have moved to new home phone technologies like a Fibre or Wireless Landline service. These technologies need a power supply in the home to work, meaning they will not work in a power cut, without an independent power source.

Under the Code, telecommunications service providers must tell new customers, and remind existing customers at least once a year, that their home phone may not work in a power cut. Providers must also tell their customers how they can protect themselves and where to go for further support.

Landline customers who don’t have an alternative way to contact 111 emergency services in a power cut can apply to their provider if they are at particular risk of needing to call emergency services for health, safety or disability reasons. If you, or someone in your household, qualifies, Spark will work with you to determine the right product for your particular needs, at no cost to you.

Spark will be contacting its customers from February 2021 about their options for calling 111 emergency services in a power cut. Providers have until August 2021 to make extra support available to vulnerable consumers.

Using your phone in a power cut

Your phone line may not work in a power cut

If your landline service is provided over a Fibre or Wireless Landline service, then it may not work in a power cut. This is because these technologies rely on power in your home to operate. This means that if there is a power cut in your home you will not be able to make calls to 111 emergency services on your landline (unless you have a backup power source).

If your landline is provided by copper, this technology does not rely on power in the home and will continue to work in a power cut. So long as you have a compatible device (see below) you will still be able to make calls to 111 emergency services on your landline.

Your devices may not work in a power cut

Some equipment in your home needs power to work, regardless of whether you have a copper, Fibre, or Wireless Landline service connection. For example, cordless phones such as DECT phones usually need power to continue to work (even on a copper connection). You will not be able to use them to make 111 emergency services calls in a power cut. However, there are some phones/handsets, which when used on a copper connection, will continue to operate in a power cut, we recommend you check with your phone manufacturer if you are unsure.

Some medical alarms may also not work in a power cut – you should speak to the company that provided the device if you are unsure.

Make sure you have another way to access 111 emergency services in an emergency.

We recommend you have an alternative means of contacting 111 emergency services in the event of a power cut such as a charged mobile phone. Remember to keep the mobile phone charged, make sure everyone at your place has access to it and knows how to use it in an emergency.

Vulnerable consumers

If you, or someone in your household, relies on your landline service for medical, safety or disability reasons, you may be able to apply to be listed as a vulnerable consumer. 

If you qualify, Spark will provide you with a means to call 111 emergency services in the event of a power cut. This will be provided at no cost. 

You can read more about how to apply further down this page.

It’s important that every New Zealander feels safe. And under the Commerce Commission’s 111 Contact Code, it’s our responsibility to provide extra support to people who qualify for it, for health, disability or safety reasons. Whatever the situation, we’ll never refuse to provide you with a landline just because you need this extra support.

Download the Vulnerable Consumer Application form

Who can apply?

You can register with Spark as a vulnerable consumer if all of the following apply:

  1. You (or someone in your household) is at particular risk of needing to call 111 emergency services for health, safety, or disability reasons. 
  2. You have a landline service provided over Fibre or Wireless Landline service. This is because these services will not operate in the event of a power cut and, if this happens, you will not be able to use it to make calls to 111 emergency services.

    Note:
    The Code only applies to Fibre and Wireless services which include a landline voice service. This is because copper landline services will continue to work in a power cut. Broadband only customers cannot apply.
  3. You (or a person in your household) have no other way to call 111 emergency services in the event of a power cut. For example, if you have access to a mobile phone and are able to make calls to 111 emergency services, or your services are already protected by a backup generator or battery, then you will not qualify. 

If you do not meet the criteria to be part of Spark’s Vulnerable Consumer Register and you or someone in your household has a medical, safety or disability condition, you can still apply to be placed on Spark’s Medical Dependency Register. This will ensure the medically dependant person is not unduly placed at risk when connecting, disconnecting, maintaining, or repairing faults with their telecommunications service, but you won't be provided with a device by Spark. To apply you'll need to download and complete a medical dependency form with your medical practitioner.
Download medical dependency form

Note: If you qualify as a vulnerable consumer then we will automatically apply the same considerations as we do for our Medical Dependant Register. 

  1. You will also need to provide sufficient evidence to support that you, or a person from your household you are applying on behalf of, are at particular risk of requiring 111 emergency services.
    Example of documents/examples you can use as evidence:
    • A completed Electricity Authority ‘Notice of Potential Medically Dependant Consumer (MDC) Status’ form, which includes a certification from a DHB, private hospital or GP. Go to Electricity Authority: Medically dependant and vulnerable customers
    • A protection order
    • A letter from a health practitioner (e.g., a GP)
    • Documentation of impairment (e.g., an ID card)
  2. Alternatively, you could also provide us with details of a nominated person who we can contact to verify that you, or the person in your household, are at risk of requiring 111 emergency services. We recommend that before you make your application to us, you (or the person from your household) first contact the nominated person to discuss the application.

    Examples of nominated persons you could use:

    A nominated person must be someone who, by virtue of their occupation, is competent to give an opinion on whether you (or the person you are applying on behalf of) is at particular risk of requiring the 111 emergency service. For example:

  • If the health or disability category has been ticked in the form, then a health practitioner (such as a GP) could be a nominated person.
  • If the safety category has been ticked, then a police officer, a currently registered social worker, a lawyer (with a current practising certificate), or a family court judge could be a nominated person.

How to apply?

Download the Vulnerable Consumer Application form

You need to be a Spark account holder, or someone authorised on a Spark account, with an active landline service, to be able to apply. You can apply either for yourself or on behalf of someone who normally resides at the address where the Fibre or Wireless Landline service is provided. 

If you are an account holder or an authority on the account, and the vulnerable user has no backup device (e.g., mobile phone or power back-up) to use in a power cut, you will need to download and complete the Vulnerable Consumer Application form and email it to vulnerable@spark.co.nz.

Alternatively, you could post the form to:

Freepost 10053
Vulnerable Consumer
Spark New Zealand
P O Box 1473
Christchurch

If you (or the person in your household) are unable to email or send a printed form, please call us on 0800 800 123. One of our team can assist with filling in the form on your behalf. Please ensure you have all relevant information with you when you call, including the nominated person’s contact details.

Complaints and disputes

We have specific responsibilities under the Commerce Commission’s 111 Contact Code. If you don’t think we’ve done a great job, or met these responsibilities, please let us know by calling 0800 800 123 or email vulnerable@spark.co.nz. One of our team will then contact the account holder to discuss and attempt to resolve any issues.

You can check Spark's Complaints Policy which includes your rights as a Spark customer and ways to raise a complaint.

You can also raise a complaint to:

  • The Telecommunications Dispute Resolutions Scheme (TDR). Spark has been a member of the TDR since it was established in 2007, and we fully support this industry initiative. TDR offers a free independent service to residential and small business customers. The account holder can raise a dispute with Spark or the TDR on behalf of themselves or another person from the same household. You can do this at tdr.org.nz
  • Or, if you can't resolve the matter through the TDR, you can make a complaint to the Commerce Commission. You can do so at comcom.govt.nz

Frequently asked questions

A vulnerable consumer is someone who is at particular risk of needing to call 111 emergency services and is unable to do so in a power cut. If you, or someone in your household, relies on your landline service for medical, safety or disability reasons, you may be able to apply to be listed as a vulnerable consumer. 

To qualify you must:

  • Have either a Fibre or Wireless Landline voice service (broadband only customers are not eligible) and the vulnerable consumer must not have access to another means to access 111 emergency services in a power cut (such as a mobile phone or a battery backup device).
  • Be the Spark account holder or someone authorised on a Spark account, with active service, to be able to apply. You can apply either for yourself or on behalf of someone who normally resides at the address where the landline service is provided.
  • Reside at the address where the Fibre or Wireless Landline is connected (this includes a residential home or some small businesses where a customer resides, for example, a Dairy store).

You can only apply to be a vulnerable consumer if you have a landline service provided over a Fibre or Wireless Landline service. This is because these services need mains power in the home to operate. Copper landline services will continue to work in a power cut if you’re using a compatible home phone. Customers with copper landline connections therefore do not qualify.

However, if you are a Spark account holder and you or someone in your household has a medical condition that depends on copper landline telephone access for critical medical support, you can apply to be placed on Spark’s Medically Dependency Register. This will ensure the medically dependent person is not unduly placed at risk when connecting, disconnecting, maintaining, or repairing faults with their telecommunications service. To apply you'll need to download and complete a medical dependency form with your medical practitioner. Download medical dependency form

Note: If you have applied to be part of Spark’s Vulnerable Consumer Register and the application is approved, you will be given the same considerations as a medically dependant customer.

Fibre or Wireless technology will stop working in a power cut, unless it is plugged into a power backup device like an Uninterruptible Power Supply (UPS). For Fibre landlines the ONT (Fibre box) must be plugged into the UPS, and for Wireless landlines the modem must be plugged into the UPS. Copper landlines will continue to work in a power cut and do not need a power backup.

Any device that requires power to operate will not work in a power cut. This includes certain portable/cordless phones, modems, ONTs and some special accessibility devices for the hearing/visually impaired. There are some types of handsets that do not require power or may include their own inbuilt battery backup that will continue to operate in a power outage. Contact your local consumer electronics store for more information.

Devices will be provided to customers based on the vulnerable consumer’s needs. We are in the process of working out the best solution for vulnerable consumers. The device provided will also depend on the mobile coverage at the address and the ability of the consumer to use a mobile device. If a mobile device is not suitable, then an UPS (uninterrupted power supply) may be provided. 

Note: The first devices will not be dispatched to customers until approximately 1 August 2021.

Spark is only required to provide, at any one time, one means for contacting the 111 emergency services per premises. If there is more than one vulnerable consumer at a premises the means provided must be appropriate for the needs of all vulnerable consumers at that premises. In practice, if there is more than one vulnerable consumer in the same household, we will work with you to ensure that the means for calling 111 in a power cut is appropriate for everyone to use.

Spark is required to provide a method for customers to apply to be part of Spark’s Vulnerable Consumer Register from 1 February 2021 and provide devices to customers whose applications are approved by 1 August 2021. We will send a notification to approved vulnerable consumers when the device is on its way.

We are working on a solution for vulnerable consumers who might need help with setting things up in their home. Details on what this process will be communicated once its finalised, closer to August 2021. You will not bear any costs for installation.

No, we will not cover any costs that you (or someone in your household) may incur to obtain supporting information for an application. You can inform your medical practitioner that Spark will call to verify your application details rather than having to go and visit to get the documentation, if that is easier for you. If you want to do this, please complete the Nominated Person section of the application form and advise your medical practitioner that they have permission to verify your situation to Spark.

Spark will only use the information collected on the form to process an application. Beyond this, Spark has a requirement to securely store this information as required by the Code in the event we are asked by the Commission to provide information supporting an application. This requires us to store your information for a period of 5 years or more after you stop being a Spark customer, your application is declined, or the person stopped being a vulnerable consumer.

If you send us additional information in support of your application (for example a certificate confirming your medical status) we will record that we have seen and reviewed these. We will then destroy any supporting documents you have sent us. Therefore, it is important that you only send us copies of these documents and you keep the originals safe yourself.

Yes, if you disconnect or port your landline to another provider, Spark will contact you to arrange the return of the device. You will also be removed as an active connection on the Vulnerable Consumer Register.

Spark will hold the information we have received to date for 30 days to allow time for you to re-apply. After this period, we will only retain the information that we have under the 111 Contact Code and safely destroy anything not required. This means when re-applying after this time you will need to resubmit with all of the required information for us to process the application.

If you have any questions about your application, you can contact us on vulnerable@spark.co.nz or call 0800 800 123.

If you want to raise a complaint about the process or how your application was handled, the account holder should email vulnerable@spark.co.nz , call 0800 800 123 or write to us at the below address, our support team will contact the customer to discuss and attempt to resolve any issues.

Freepost 10053
Vulnerable Consumer
Spark New Zealand
P O Box 1473
Christchurch

If you are not happy with the response from the Vulnerable Consumer Support team, please check Spark’s Complaints Policy which includes your rights as a Spark customer and ways to raise a complaint. This includes referring your complaint to the Telecommunications Dispute Resolutions Scheme (TDR). TDR offers a free independent service to residential and small business customers.

The account holder can raise a dispute with Spark or the TDR on behalf of themselves or another person who normally lives at the same house.

If you think that Spark is not complying with the 111 Contact Code you can raise a complaint directly with the Commerce Commission, but the primary method for making a complaint is to refer a dispute to TDR.

No. Only retail landlines that are in the premises where a vulnerable person normally resides are covered by the 111 Contact Code. A landline that is connected into a lift or elevator in a building does not qualify because it is outside the premise. If you have a Wireless or Fibre landline connected to the lift, we recommend you speak with your lift supplier or maintenance company to discuss the best backup options in the event of a power outage.

We recommend that you speak with your medical or personal safety alarm provider to discuss if your device will work in a power cut, and what your backup options are. If you are unable to contact your alarm provider, Spark can do this on your behalf if you give permission for us to request on your behalf in writing.

Spark will check:

  • What make/model device you have
  • If the device has battery back up in the event of a power cut
  • How long battery backup will last
  • Confirm that your provider can put you through to Fire/Police/Ambulance if needed

Under the Commerce Commission’s 111 Contact Code, Spark is only required to ensure Vulnerable Consumers have an appropriate means to make a voice call to 111 emergency services in the event of a power cut in their home. If your current medical alarm/personal safety alarm is able to contact 111 in the event of a power cut, you will not be eligible for our Vulnerable Consumer Register. However, we recommend you apply for our Medical Dependent Register, which will ensure you are not unduly placed at risk when connecting, disconnecting, maintaining, or repairing faults with the telecommunication service. For more information on the Medical Dependent Register and how to apply please refer to www.spark.co.nz/accessibility

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