Customer Support and Hardship Policy

1. Purpose

We recognise that residential and small business customers may experience financial difficulty at times. Everyone’s circumstances are different and financial difficulties can impact people in different ways.

As an essential service provider, we actively support customers who are experiencing financial difficulty. We recognise that our support is one part of a wider support network for customers, and we proactively work to strengthen this support network through collaboration with other organisations.

These guidelines set out our customer support and hardship policy for customers who are experiencing financial difficulty.

2. Scope

These guidelines apply to residential and small business customers who are experiencing financial difficulty. The key elements covered in this policy guideline include:

Early identification of financial difficulty
Customer support including payment assistance, case management, referrals and water efficiency
Communication options
Training and awareness for staff
Dispute resolution
Internal responsibilities
Continuous improvement.

3. Definitions

Customer experiencing payment difficulty

Residential or small business customers who would like to pay on time but don’t have the financial capacity to do so. They may identify themselves as having financial difficulties, or they may be identified by us, an independent accredited financial counsellor or a qualified accountant.

Small business

A business with no employees, including sole proprietorship and partnerships, or a business employing fewer than 20 people which has an active Australian Business Number.

4. Policy summary

We ensure customers, regardless of their circumstances will face no judgement, and will be treated with understanding, dignity and respect.

Our policy and associated programs are based on shared responsibility between us and our customers.  They’re delivered in a way that supports customers to self-determine the best options for their needs.  Our staff are trained to ensure customers experiencing financial difficulty are treated with sensitivity and respect and receive support in line with this policy.

We believe that customers are better able to gain control of their bills when they’re supported and given the opportunity to actively manage their debt. We listen to our customers to understand what’s going on for them and ensure payment arrangements are realistic and affordable for their individual financial situation. These solutions aim to reduce debt levels and effectively transition customers back to mainstream billing and payment processes.

We take a holistic and proactive approach when working with customers in financial difficulty. This includes focusing on early identification so we can direct customers to appropriate support pathways as early as possible. Our customers receive information on our support programs as well as referrals to external agencies, where appropriate.

While customers are engaged with our WaterCare support and hardship programs, we will not pursue them through our normal debt collection process, restrict their water supply, take legal action or impose any other recovery costs including interest on their account.

We offer a range of assistance options that can be tailored to customers’ individual circumstances – including the amount of time they need to become financially stable.
We’re committed to continuous improvement through our learnings from working with customers, partners and experts in financial vulnerability. This ensures we continue to evolve and be responsive to our customers’ needs.

5. Early identification

We endeavour to identify customers who are experiencing financial difficulty early in the payment collection cycle.

5.1 Indicators

Some indicators that highlight a customer’s need for additional assistance are:

A history of frequent requests for payment extensions or payment arrangements that haven’t been met.
Inability to afford the cost of current usage and debt, even when smoothed over a 12-month period.  
A payment history that indicates difficulty paying their account.
Previous application for a Utility Relief Grant (irrespective of whether or not the application was successful).
Eligibility for Government funded concessions (e.g. Health Care Card, Centrelink benefit).
A sudden change of circumstances that adversely affects their financial capacity to pay.
A referral from an independent financial counselling agency, community organisation or qualified accountant.
Self-identifying as having affordability issues.
Being affected by family violence. We refer customers affected by family violence immediately into our WaterCare Support team (refer to our Family Violence Policy).
An asylum seeker or refugee who has limited access to financial stability.  
Experience of health issues or mental ill-health.
A low level of income, that is unlikely to change.
Unemployment.

5.2 Sensitive and respectful conversations

We understand that customers experiencing payment difficulties may have a range of pressures that limit their ability to openly engage with us about their personal circumstances.

We endeavour to create an open and supportive environment where customers feel comfortable telling us what they need from us. Proactive and empathetic communication is crucial when engaging with customers in financial difficulty.

We’re committed to listening to customers without judgement to achieve an outcome that meets their needs and our business needs.

5.3 Collections process

Throughout our collections process, we communicate to customers that support is available if needed.

All customer facing staff including our external debt collection contractors are trained to listen for vulnerability indicators and refer customers directly to the WaterCare Support team.

5.4 Referrals

There’s a range of referral pathways that help us identify and support customers experiencing financial difficulty early:

Employees from any area of our business may refer customers to the WaterCare Support team.
Community workers and advocates are given our WaterCare Support team’s contact details.
Referrals from other service providers through the One Stop One Story Hub.

5.5 Awareness and access

We recognise that there are many barriers that limit customers’ ability to, or likelihood of, accessing the support they’re entitled to, as early as possible.

We proactively raise awareness and address barriers to accessing support by:

Providing appropriate self-service options for customers.
Using a 1800 telephone number to ensure customers don’t incur additional costs when they contact us.
Promoting the support available to customers, community and advocate organisations and other service providers.
Understanding and responding to the unique needs of different customers.
Using language that minimises any stigma associated with payment difficulty and vulnerability and normalises accessing support.
Detailing the available assistance and referral pathways on our website, including in diverse languages.
Putting our Customer Support and Hardship Policy Guidelines on our website, at our office and sharing it with customers and community organisations on request.

5.6 Payment methods

We provide a range of payment methods:

In person at any Australia Post office
BPAY
EFT
Direct debit
Credit card
Centrepay – regular deduction from Centrelink payments
Flexible payment plan.

6. Support for residential customers

We don’t use formal assessment criteria to determine a customer’s eligibility for support under this policy. We take people at their word and work towards supporting customers in a timely and tailored manner, that’s appropriate to their capacity to pay.

6.1 Payment assistance

Support customers may be eligible to access includes:

Affordable, flexible payment arrangements.
Ability to extend the due date for some or all of the amount owed.
More frequent billing or payment options.
Waived fees.
Conducting regular meter readings and frequently reporting to customers on their water use.
Redirecting a bill to another person for payment if the person agrees in writing.
Access to government concession and grants including the Utility Relief Grant.
Assistance over the phone completing the online Utility Relief Grant application and submitting it on the customers’ behalf. Depending on the customers’ preference, we can also fill out the application form as much as possible and send it to the customer with instructions for completing the remainder and submitting it.

Flexible payment plans

We’ll work with customers or their representative to agree on an affordable payment plan regardless of whether it’s sufficient to cover current usage and outstanding arrears.
Customers can renegotiate the amount of their payment plan if there’s a change in their personal circumstances.
We’ll provide written confirmation to customers of the payment plan they agreed on, including a schedule of payments.
We may not offer customers a flexible payment plan if they have, in the previous 12 months, had 2 flexible payment plans cancelled due to non-payment unless the customer provides a fair and reasonable assurance (based on the circumstances) to us that they’ll comply with the plan.

Arrange and Save incentive scheme

Customers can access our Arrange and Save incentive scheme, if the payment amount they can reasonably afford isn’t adequate to cover both arrears and future estimated water accounts.
Customers receive bonus credits in accordance with approved business rules under the Arrange and Save incentive scheme if they meet their payments consistently, on time and in full. If customers continue to meet their payments over an extended period of time, they may receive a write off of their long-term debt.

Support person or chosen representative

Customers can choose to authorise a support person or representative to talk with us about their account. We’ll let customers know this is possible directly or through their financial counsellor. We also communicate this option in the Customer Charter.

Interest payments, late fees and sale of debt

We don’t charge interest on any overdue amounts, charge late fees or sell debt for customers who are experiencing payment difficulties and receiving support in line with this policy.

Exemptions while engaging with us

While customers are actively engaging with our WaterCare Support programs, we will not:

Refer their account to external debt collectors.
Restrict their water supply.
Take legal action.
Impose any other debt collection costs on their account.

6.2 Case management

We work with customers to find appropriate solutions to their individual circumstances. Where required, we provide case managed support. Our WaterCare Support team:

Has the capability and skills to provide the required support and solutions.
Is appropriately resourced and empowered to manage the situation and negotiate suitable outcomes.
Understands that some complex situations require specialist support. In these instances, they’ll refer customers to specialist partners including independent financial counselling.
Has financial authority to effectively manage customer accounts. This includes suspending payments, reducing payment arrangements, and providing credits and write offs in accordance with their delegated authority levels.

6.3 Referrals

We understand that customers experiencing payment difficulty may have complex situations that require specialist support.

We can refer customers for free to our specialist partner, CareRing, which offers independent financial counselling.

We can also refer customers to the One Stop One Story Hub. This means customers experiencing family violence or financial hardship only have to tell their story once to get access to holistic support from multiple service providers.

6.4 Water efficiency focus

Managing water use is another way customers can gain control of their bill.

When assessing a customer’s situation, the WaterCare Support team reviews the need for water efficiency advice and the customer’s eligibility for water conservation and retrofit programs.

If customers need plumbing work that’s over and above the government programs available, we’ll provide options to suit their situation.

7. Support for small business customers

We recognise that the effects of financial difficulty are unique to each business. We encourage small business customers experiencing financial difficulty, to stay connected with us. We’ll work with customers on a case-by-case basis.

7.1 Payment assistance

Support customers may be eligible to access includes:

Flexible payment plans.
Ability to extend the due date for some or all of the amount owed.
More frequent billing or payment options.
Redirecting a bill to another person for payment if the person agrees in writing.
Waived debt.
Referrals to government funded assistance programs where appropriate.
Referrals to Partners in Wellbeing, a free external support for small businesses.

Where a payment plan is agreed with a customer, we’ll provide written confirmation of the agreed payment arrangement, including a schedule of payments.

We may not offer customers a flexible payment plan if they have, in the previous 12 months, had 2 flexible payment plans cancelled due to non-payment unless the customer provides a fair and reasonable assurance (based on the circumstances) to us that they’ll comply with the plan.

Interest payments and sale of debt

We don’t charge interest on any overdue amounts, charge late fees or sell debt. This , includes customers who are experiencing payment difficulties and receiving support in line with this policy.

Exemptions while engaging with us

While customers are actively engaging with our Commercial Services team, we won’t:

Refer their account to external debt collectors.
Restrict their water supply.
Take legal action.
Impose any other debt collection costs on their account.

7.2 Water efficiency focus

Managing water use is another way customers can gain control of their bill. We can provide information or help small business customers manage their water use.

8. Accessible communications

We’ll provide clear communication to our customers or their advocate. Our Customer Support and Hardship Policy is available on our website and on request.

We’ll translate this policy on request, and ensure we have information about the support available to customers in diverse languages.

It’s important customers can talk to us in the way they prefer. Customers who are deaf or hard of hearing can access:

TTY/Voice calls: call 133 677
Speak and Listen: call 1300 555 727
National Relay Service: visit accesshub.gov.au.

Customers who need language assistance:

Call our free interpreter service on 9046 4173: Monday to Friday, 8:30 am – 5 pm.

9. Dispute resolution

To protect customers’ rights, we have appropriate escalation procedures to deal with customer complaints regarding this policy.

This includes offering customers information about our dispute resolution policy and their right to lodge a complaint with the Energy and Water Ombudsman of Victoria.

10. Ongoing staff training and awareness

Staff training and awareness

We provide training for staff to ensure that customers experiencing payment difficulty are treated with sensitivity and respect, and in line with this policy. To ensure that the training remains current, relevant and appropriate, we seek advice from our financial counselling industry partners on the content and delivery of our training programs.

We communicate our approach to customer support and hardship to all employees to raise awareness and understanding of customer vulnerability.

Specialised trained staff – “people who get it”

All staff in our WaterCare Support team are trained to recognise and respond respectfully to the complex issues associated with hardship, so they can work with customers in a respectful and appropriate manner, including referring them to external specialist support.

External partners

We provide training programs and procedure manuals to external partners, including debt collection agencies and our plumbing contractor. This ensures they deliver a level of service to customers experiencing payment difficulties in accordance with our operating procedures. These requirements are commercially based and documented in the terms and conditions of the contract.

11. Internal responsibilities

Different areas of our organisation are responsible for applying this policy.
Senior management is responsible for the strategic direction, operation and management of our Customer Support and Hardship policy and programs. This ensures we maintain a strong management focus on supporting customers experiencing financial difficulty.

Supporting customers with financial difficulty is a responsibility shared by many teams and functions, including strategic policy, planning, design and development of systems and processes, marketing and communications, learning and development as well as frontline customer facing roles.

12. Continual improvement

We work closely with key partners to ensure our policy, programs and processes are appropriate, responsive to community needs and reflect best practice.

We review these policy guidelines and the support available to customers annually or more frequently as needed.