CHOICE membership

ACCC seeks comment on Loyalty/Reward programs - T&Cs, unfair contracts, privacy


#1

An article regarding the ACCC draft report on loyalty programs.

And the ACCC draft report.

https://www.accc.gov.au/focus-areas/market-studies/customer-loyalty-schemes-review/draft-report-for-consultation


Loyalty Programs
#2

The ACCC’s draft report into loyalty programs might be of interest to some of our policy buffs (thanks for sharing it @Fred123 :+1: )

I’ve copied a summary of the draft recommendations below for further discussion, visit the ACCC site to make a submission online and read the full report.

Draft recommendation 1: Improve how loyalty schemes communicate with customers Loyalty scheme operators need to review their approach to presenting terms and conditions of loyalty schemes and ensure changes are fair and adequately notified.

Draft recommendation 2: Prohibition against unfair contract terms and certain unfair trading practices The ACCC’s findings in this draft report reinforce the Digital Platforms Inquiry Final Report’s recommendations for the need for a prohibition against unfair contract terms and certain unfair trading practices.

Draft recommendation 3: Improve the data practices of loyalty schemes Loyalty schemes need to review their approach to presenting consumers with information about how they handle consumer data and provide consumers with meaningful control over their data.

Draft recommendation 4: Strengthen protections in the Privacy Act and broader reform of Australian privacy law The ACCC’s findings in this draft report reinforce the Digital Platforms Inquiry Final Report’s recommendations for privacy law reform.


#3

The horse has bolted in the case of the larger programs. As the data has been gathered for so very long and shared/sold that the vast majority of the damage has been done to current users and how will that now be managed retrospectively. Nothing like being retroactive rather than proactive is there? :frowning:

For all new users of the proposed protections there may be some benefit with what they term meaningful control in DR 3. But if your “soul” has already been disseminated it’s seems a little more than patching one leak in a roof with a thousand leaks.


#4

I think that further to those recommendations the loyalty programmes need to disclose
5: What they are offering customers. What is the return on investment eg $0.001 for every dollar you spend, or discounts of X% on homebrand, etc.
6. The market price of the items they are selling to customers as they are usually much more expensive than the same products are available elsewhere.
7: The ownership of the loyalty programme, and the relationship of that business to the one offering the loyalty programme
8. The benefits (financial, marketting benefit, business intelligence, etc.) obtained by the business offering the loyalty programme


#5

An article regarding Virgin Australia planning to buy back the 35% of their Velocity program that they previously sold.

https://www.msn.com/en-au/money/company-news/virgin-australia-in-talks-to-buy-back-rest-of-frequent-flyer-programme-source/ar-AAHiRzE?ocid=spartandhp

Obviously the frequent flyer schemes are more lucrative that operating aircraft.