Four delivery propositions. No new legislation required. Each maps 1:1 to a section of evidence underneath. Status reflects real-world delivery maturity, not lever toggle state.
Four sections, one per principle. Numbers are a mix of live operational data, trial-evidenced findings (from the energy-sector AfA trial), operational targets, and modelled ranges. Caveats named, not hidden.
The principle. Mutual Data Sharing is the principle that the sector works together to share data — both ways — for mutual good. CO and providers exchange structured information at the deadlock interface: CO shares pre-deadlock intelligence with providers (PITOR); providers share case data with CO at deadlock (the portal upload).
No new legislation is required. What is needed is industry collaboration to design and adopt the framework within existing data protection and regulatory structures. Two-way sharing works only when the sector designs it as a shared framework — both flows are designed to operate together.
Flow A — PITOR (CO → Provider). CO shares aggregated insights drawn from past casework with providers before their next case escalates to deadlock — patterns, similar-case learning, likely root causes. The provider uses that intelligence to resolve cases at source. The consumer never needs to engage with CO.
Consent basis. Aggregated and anonymised insights from CO casework, shared with providers on legitimate interest grounds. Individual case-level data is not transferred back to the originating provider through PITOR. Consumer consent boundaries from the original case scope are respected throughout.
PITOR volume in 2025. CO live operational data, all sectors. Of 190,217 cases created in 2025, 35,841 (18.84%) entered PITOR — close to the “1 in 5” opportunity framing used throughout the tool.
Flow B — AfA v2 (Provider → CO portal). At deadlock, the provider uploads structured case data to a secure staging portal that CO has built and operates. The consumer's QR scan releases the case into CO's active workflow. v1 (direct transfer) was redesigned to v2 (passive staging repository) to address the GDPR concern providers raised — that outbound CO contact based on provider-shared data could create a direct marketing risk.
Mutual Data Sharing is the gate because both flows above rest on the same sector framework. They are designed to operate together as one collaborative framework. Consumer evidence (0.52% opt-out behaviour, 69% comfortable, 68% expecting it) shows people don't object to the principle of structured sharing with an ADR body. Flow A (PITOR) operates on legitimate interest grounds with aggregated insights; Flow B (AfA v2) operates on QR-as-consent with the consumer activating their own case.
Three touches removed from the consumer's path. The QR scan replaces the "search → reach → build" sequence with a single deliberate action that also serves as consent.
Only 31% of consumers had prior awareness of CO — the access barrier is real. With the QR letter, only 15% sought further information; the journey was clear enough on its own.
Because the letter stays on provider letterhead, the CSAT uplift reflects on the provider who initiated the journey — not just CO. The brand value of a well-handled deadlock sits with both parties.
“Investigation initiated by British Gas and they sent me a link to register my dispute.”
“Initiated by my energy provider.”
“Simple online form to submit.”
“Quick and easy to do online.”
“The system was able to access my mobile phone files.”
“Easy to do.”
“I spoke to a very well informed lady Louise who explained everything and made the process very easy.”
“My case handler got in touch with me really quickly and explained the process well.”
“Case handler was empathetic and understanding, took time to listen and note the issue, clearly advised on next steps.”
The Stage 04 Consumer Access lever makes the process better (CX metrics improved across CSAT, Effort, and Comms-sat) and removes steps (engagement compresses from a 14-day BAU median to ~48 hours). The Cohort 3 comparator (no QR, 2.6% conversion) shows the QR-letter design as the active ingredient, separating its effect from a simple reminder.
The Investigation Period lever makes the process better by compressing time-to-resolution by 14 days. Delivered independently of provider engagement through case prep, taxonomy work, provider-facing teams and decision-quality QA. The lever is an active CO programme.
The Remedies framework makes the process better by replacing single-SLA enforcement with remedy-type precision — matching realistic timeframes to the actual remedy. The 1–12% range is a placeholder for discussion; the <1% target is a Stage 06 commitment in build with the regulator. The lever sits later in the journey and does not depend on Data Sharing, so can be delivered independently.
Subtitle
The provider uploads data at deadlock. It sits dormant — CO does not act on it — until the consumer scans the QR or clicks the link. That is the architectural change in AfA v2.
The provider uploads case data to a secure staging portal that CO has built and operates. CO has technical access to the portal but does not proactively contact, market to, or act on consumers based on the staged data. The consumer's QR scan or click activates an active case.
This is the critical departure from v1: providers argued that under v1, outbound CO contact based on provider-shared data could create a direct marketing risk under GDPR. v2 removes that risk by making CO a passive recipient until the consumer initiates via QR scan.
One narrow exception: if a consumer reaches CO through a non-QR route (e.g. by phone), CO may check the staging portal to see whether a case already exists — to avoid duplication and confirm the matter falls within CO's Terms of Reference. This is a legitimate operational check, not proactive outreach.
If the consumer never acts, the data is deleted after a defined period and no case is created at CO.
Providers raised privacy concerns at v1, attributing them to consumers. The trial opt-out rate and national survey both indicate consumers, when asked, overwhelmingly choose to participate.
Sent at deadlock on provider letterhead. Carries the QR code, the link, and — crucially — the consent-by-action strapline. Scanning is the consent moment.
Data sits locked in TAG's portal until the consumer's QR scan unlocks it · empty cells show inactivity by design
Both the CO → Provider flow (PITOR) and the Provider → CO flow (Stage 04) rest on the same sector framework: Mutual Data Sharing. They are designed to operate together as one collaborative framework — two-way sharing designed as a shared way of working.
Turn on Mutual Data Sharing (Stage 03 on the chip row) to unlock this lever.
A true three-tier structure: broad categories, organised by the consumer's own voice, resolving to specific complaint details. Each detail carries its own regulatory anchor, remedy guidance and evidence prompts. This is the shared language CO and BT can investigate and report against.
Beyond the consumer-facing tiers, an investigator tags every detail with three controlled fields. These picklists are common across the whole taxonomy, so they sit here once rather than repeating on every row.
This is not a standalone reference. The same structure underpins three of the four principles in the plan — it is the classification layer that makes faster, fairer, more consistent resolution possible.