Katrina Anderson / Katrina Anderson

Customers must be given a ‘straightforward’ way of cancelling their subscription online – broadly understood to mean having an on-platform cancellation button – Katrina Anderson is principal associate at law firm, Mills and Reeve

CHECKLIST FOR OPERATORS

1. Check that all advertised prices include all mandatory charges, such as booking or admin fees and joining fees

2. If people can sign up online, review the sign-up journey to remove misleading prices or examples where full pricing information has been omitted 

3. Make sure optional extra charges are always presented clearly and separately from mandatory charges. Care should be taken not to represent these as mandatory

4. Where using ‘from...’ or indicative pricing, only use these when they’re available for a significant proportion of people and be upfront about any conditions, such as discounted student membership

5. Be aware of auto-renewal terms in contracts.  Consumers should be informed about how these will work and they should ideally be provided as part of the offer details on the ‘product’ page

PREPARING FOR THE SUBSCRIPTIONS REGIME

1. Create a summary of the additional pre-contract information required for each subscription offer. This will include key details such as charges, duration, termination, and cancellation rights 

2. Consider how you’re going to show the new pre-contract information to consumers, bearing in mind there are specific presentation requirements that will depend on how the subscription contract is entered into (eg, online, in-person, or over the phone)

3. Establish a process for sending the information needed for renewals, mid-year reminders and at the end of any discounted period. This is most likely to be an automated email system

4. Train staff in how to deal with the new cooling-off rights that allow members to cancel on the expiry of an initial free or discounted period, or when a contract renews

5. Build an online system to allow an easy process for consumers to terminate or cancel

6. Create a process to acknowledge termination and deliver refunds.  An end of contract notice should be sent within 24 hours for online cancellations or three working days for other methods.  Any overpayments should be refunded promptly

Members have new powers following the implementation of the Act / Shutterstock / Impact Photography