Vulnerable Consumers

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.

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 that will operate for a minimum continuous period of 8 hours in the event of a power cut. This will be provided at no cost to you. 

We’ll also ensure the vulnerable consumer is not placed at undue risk when connecting, disconnecting, maintaining or repairing faults with their service.

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

1. You (or someone in your household) are at particular risk of needing to call 111 emergency services for health, safety, or disability reasons. You’ll need to provide evidence of this.
2. You have a Fibre or Wireless landline service. These services won’t work in the event of a power cut. This means if there’s a power cut, you won’t be able to use it to make 111 calls to emergency services.
3. You (or a person in your household) have no other way to call 111 emergency services in the event of a power cut.

You won’t qualify if any of the following apply:

• You have a copper landline service. Copper landlines will continue to work in a power cut (so long as you have a compatible device – see below for more information).
• You have a broadband service without a landline.
• You already have another way to call 111 emergency services in the event of a power cut. For example, if you have access to a mobile phone, or your services are are already protected by a backup generator or battery.
• The vulnerable consumer doesn’t live at the address where the Fibre or Wireless landline service is connected.

Medical Dependency Register

If you don’t qualify to be registered as a vulnerable consumer, you can apply to be placed on Spark’s Medical Dependency Register instead.

This register is for customers who rely on their services for health, safety or disability reasons. It ensures the medically dependent person is not placed at undue risk when connecting, disconnecting, maintaining or repairing faults with their service.

To apply, you'll need to download and complete a medical dependency form with your medical practitioner.

Download medical dependency form

If your application is approved, we will provide a device to allow you to call 111 emergency services based on your needs. What device we provide will also depend on the mobile coverage at your address and your ability to use a mobile device. If a mobile device is not suitable, then a battery backup device may be provided instead.

One device will be provided per household. If there is more than one vulnerable consumer in your household we will work with you to ensure that the means for calling 111 in a power cut is appropriate for everyone to use.

1. Download the vulnerable consumer application form
2. You need to be the Spark account holder, or someone authorised on the Spark account. 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 connected.
3. Complete the application form.
4. Attach sufficient evidence to support that you (or the person in your household you are applying on behalf of) are at particular risk of requiring 111 emergency services. Alternatively, you could also provide us with details of a nominated person who we can contact to verify that instead (see below for more information on who can be a nominated person).
   • Email it to: vulnerable@spark.co.nz
   • Or post it to:
     
     Freepost 10053
     Vulnerable Consumer
     Spark New Zealand
     P O Box 1473
     Christchurch

5. Send your completed application form to us by email or post.

If you 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.

6. If anything on the application is missing, we may contact you for more information and add it to the application on your behalf after you have signed it.

Examples of documents you can use as evidence:

• A completed Electricity Authority ‘Notice of Potential Medically Dependant Consumer (MDC) Status’ form, which includes a certification from Te Whatu Ora Health New Zealand, a private hospital or a GP.
  Go to Electricity Authority: Consumer care & medically dependent
• A protection order.
• A letter from a health practitioner (such as a GP).
• Documentation of impairment (such as an ID card).

Please note, Spark will not cover any costs that you (or someone in your household) 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.

Examples of nominated persons you could use:

• 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.

We recommend that before you make your application to us, you first contact the nominated person to discuss the application and let them know they have your permission to speak to us.

If your application is approved, one of Spark’s Vulnerable Consumer support team will contact you to discuss your needs.

If you are being provided with a mobile device it will then be shipped and we will talk to you about timelines for dispatch and delivery. If you need help setting up the mobile device in your home, please ask the Vulnerable Consumer support team member and they can arrange an in-home visit if needed.

If you are receiving a battery backup instead, we will discuss the process with you. A technician will need to visit your house to set up the device. This is because they are heavy and need to be connected in a specific way. The technician will ensure everything is working and take a photo of the installation before they leave.

If you later disconnect your landline or move it to another service 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.

The Commerce Commission's 111 Contact Code makes 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 their home phone landline uses a technology like a Fibre or Fixed Wireless. 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 device for your particular needs, at no cost to you.

Landlines

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.

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.

Broadband

Fibre or Wireless broadband 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 broadband the ONT (Fibre box) must be plugged into the UPS, and for Wireless broadband the modem must be plugged into the UPS.

With copper broadband the modem will stop working in a power cut unless it is plugged into a UPS. Copper landlines will continue to work in a power cut and do not need a power backup.

Devices

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 or device manufacturer for more information.

Medical or personal safety alarms

We recommend that you speak with your medical or personal safety alarm provider to discuss if your device will continue to 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. You will need to give us permission in writing for us to make the request.

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 the battery backup will last.
• Whether your provider can put you through to Fire/Police/Ambulance if needed.

What Spark will do with your information

Spark will only use the information collected on the Vulnerable Consumer application 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 five 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.

If anything on the application is missing, we may contact you for more information and add it to the application on your behalf after you have signed it.

The information regarding the application status, Vulnerable Consumer status and the device provided will be available on the account and accessible by the account holder and all authorities on the account.

The Vulnerable Consumer status will be used by Spark and trusted third parties to ensure you are not unduly put at risk when connecting, disconnecting, maintaining or repairing faults with your Spark services.

Updating your information

If your circumstances change or you are no longer vulnerable, please let us know.

If you need to update any information that was provided on the application form, you can send an email to vulnerable@spark.co.nz or call 0800 337 722.

If the specific circumstance of the Vulnerable Consumer was specified as “temporary” on the application form, Spark’s Vulnerable Consumer Support Team will follow up with you at the end of this period to reconfirm your situation. Alternatively, you can email vulnerable@spark.co.nz or call 0800 337 722.

If you’d like to view or update other personal information Spark holds about you, our 'Ask about your personal information' page can tell you how to do this. See the Ask about your personal information page

If your Vulnerable Consumer application is declined, 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 information that we need to keep under the 111 Contact Code and safely destroy anything not required. This means that if you re-apply after 30 days you will need to resubmit all of the required information for us to process the application.

Spark requires minimal evidence in addition to the application form to confirm the Vulnerable Consumer status. For example, a single document (such as a letter from a GP, a protection order or a document of impairment) or the contact details of a nominated person are often enough. The application form has more information about this. You can provide minimal information with the assurance that if more is required, it can be added to your application within 30 days without the need to re-apply.

Making a complaint

If you have any questions about your application, 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.