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Vulnerable Consumer

Terms and Conditions

Vulnerable Consumer - home phone

The 111 Contact Code came into effect on 1 February 2021

The purpose of this code is to ensure "Vulnerable Consumers" of internet-based phone services have access to an appropriate means of calling 111 emergency service in the event of a power failure or broadband outage.

If you, or someone in your household, relies on a landline connection for medical, safety or disability reasons, you may be able to apply to be listed as a Vulnerable Consumer. Information on who can qualify as a Vulnerable Consumer and how to apply is set out further below.


Using your home phone during a power outage

Our naked broadband service or Voip service will also not be available during a power outage, as your modem/router requires power to work, which means you won’t be able to use your home phone to make 111 calls during a power or broadband outage.

We strongly recommend you maintain or have access to a mobile phone service and keep a charged mobile phone at your premises in case you need to call 111 during a power outage or service disruption.


Using other devices during a power outage

Some of your existing or future telecommunication devices that require power to work, but which do not have an inbuilt battery, may also stop working during a power outage. These could include:

  • Medical alarms
  • Monitored security alarms
  • Landline phones using a copper connection that also require power to work (e.g. cordless DECT phones)

We strongly recommend you contact the person or company that supplied the device if you are unsure.


Are you a Vulnerable Consumer?

To be eligible for Vulnerable Consumer status under the 111 Contact Code, you must be a consumer of a "retail landline service" (i.e. our VoIP service) who:

  • a. is at particular risk of requiring the 111 emergency service; and
  • b. does not have an alternative means to contact 111 (that can operate for 8 continuous hours) in the event of a power failure.

Who is at "particular risk" of requiring the 111 emergency service?

A person who is "at particular risk" of requiring the 111 emergency service means anyone who is more likely than others to require the 111 emergency service because of a specific circumstance applicable to that person – e.g. for reasons of health, safety or disability.

A person may be at “particular risk” now, or sometime in the near future, or on a temporary basis.

Do you already have an alternative means to contact 111?

If you’re “at particular risk” but you already have an alternative means for contacting 111, then you are not considered a Vulnerable Consumer under the Code.

You may already have an alternative means to contact 111 if any of the following apply:

  • you have unrestricted access to a mobile phone and the premises where you live has adequate mobile coverage; or
  • your premises receives a copper landline service; or
  • you have an uninterruptable power supply (e.g. a battery back-up or generator) that will allow our VoIP home phone service to continue to operate during a power failure.

To register as a Vulnerable Consumer

We understand that some customers of our VoIP service may not have access to a mobile phone and could be at particular risk of needing to call emergency services for health, security or disability reasons.


If you, or anyone in your household, might be vulnerable, it’s really important that you let us know. We’ll record this against your account and work with you to provide appropriate extra support.


If you feel this applies to you, please let us know as soon as possible by following these steps:


What happens next?

Once we receive your fully completed application, we'll review your application and advise you of the outcome within 10 working days.


If you, or someone in your household, qualifies as a Vulnerable Consumer, we will work with you to determine an appropriate alternative means for you to contact the 111 emergency service that meets your particular needs.


This alternative means will be:

  • able to operate for 8 continuous hours in the event of a power failure at your premises;
  • provided to you at no cost on or after 1 August 2021 (as per the Code).

Frequent questions


What device will I be sent?

Devices will be provided based on each vulnerable consumer’s needs on or after 1 August 2021.
We are in the process of working out and sourcing these device solutions. The device provided will also depend on your requirements. For example if a mobile device is not suitable for your property’s location, then a battery pack may be provided.


Can a customer be provided with more than one device?

We are only required to provide one means for contacting 111 emergency services to vulnerable customers per property. However, we will work with you to ensure an appropriate solution is provided for your household’s circumstances.


If I cancel my phone service do I need to return the device?

Yes, if you cease our home phone services for any reason you will be required to return the device. We will contact you if this applies.