Beware schemes that offer apparently too good to be true savings. And beware, too, schemes that so lack transparency that the consumer may even feel unaware of having joined them.
A relative of mine recently contacted me to advise that she was being charged £18 a month for no obvious reason. When she looked back over an extended period, it became clear that the payment had previously been £15 a month and she calculated this had accumulated a total payment of £465 for no apparent benefit. My relative was unsure of how the charge was initiated and could not recall having ever authorised the payments. The beneficiary was Complete Savings, a brand name of Webloyalty International Ltd.
My relative – who we will call Ciara, to avoid identifying her – said: “I thought it was a scam. It was embarrassingly late when I realised – more than a year after it was initiated, two years or so later. I realised because my balance was declining and I wasn’t spending as loosely as that. And the price of the payments increased. To be fair, they did say in an email the payments were increasing.
“I don’t know how the payments arose. They must have come up through another transaction and that must have been from a pop up, which I did not understand. It was definitely online. It is embarrassing as I like to be responsible with my money and I don’t like to spend on unnecessary things and I don’t like my money going to something that I don’t even know what that business is. I was angry that I was losing money and not getting anything back from it.”
Research revealed that Ciara was not alone, with many other consumers having also inadvertently triggered the charges, similarly accumulating to hundreds of pounds of payments. Costs were initiated through online transactions with Argos, Iceland and other retailers, Papa John’s Pizzas, as well as Trainline, an online seller of train tickets. The trading practices of Complete Savings have been widely criticised, leading to a complaint being lodged by Martin Lewis’s Money Savings Expert website to the Advertising Standards Authority.
That complaint was upheld by the ASA at the end of last year and was one of several related to various traders and what the ASA described as issues of “online choice architecture” – in other words lack of clarity in transaction authorisations for some online payments.
The ASA described how the transaction authorisations for Complete Savings worked with regard to Argos orders. Having purchased an item online, a consumer was offered a ‘welcome reward’ of £20.87 ‘cash back credited onto your card’. Smaller text underneath stated, ‘To claim following this order at Argos, Terms and Conditions Apply.’ A payment would be ‘credited onto your card, by signing up for all the cashback rewards of Complete Savings…. FREE for the first 30 days and only £18 per month thereafter’. Consumers were then asked to submit their payment details.
ASA’s description of the payment process continued: “Underneath was a grey box which contained text in bold type outlining ‘the benefits of Complete Savings’, and stated, ‘£20.87 Welcome Reward. Just send Complete Savings your receipt within the next 90 days and we’ll send you the Cash’.”
The complaint to the ASA argued that it was unclear that the cashback reward was available only after further steps had been completed by the consumer and suggested the online advertisements were misleading. Both Complete Savings and Argos rejected these suggestions, arguing that the advertisements were clear and should not lead to a misunderstanding.
Argos confirmed that it received a commission fee for each consumer signed up and believed that the description of the scheme as being a ‘reward’ indicated that the consumer needed to take actions to become a member.
Complete Savings pointed out that membership required the use of a password, which should make clear to consumers that they had registered for an account, not simply a one-off cashback offer.
However, in upholding the complaint, the ASA concluded that there is a requirement under the advertising code for marketing communications to make clear the extent of the commitment the consumer must engage in to take advantage of a ‘free’ offer. It considered the Complete Savings advertisements did not make sufficiently clear the extent of the commitment required by consumers.
The ASA decided that the advertisements implied that consumers had already fulfilled the necessary requirements to receive the ‘Welcome Reward’ and therefore the advertisements breached the advertising code. As a result, the ASA banned the advertisements in their prior form, with instructions to online retailers to make their marketing communications clearer in future.
I was unaware of the complaint to the ASA and its decision when I initially contacted Complete Savings on behalf of Ciara. However, I stressed to the company that as an occasional contributor to the Belfast Telegraph I was interested in writing about Ciara’s experience.
Complete Savings responded to my emails by agreeing a series of refunds to Ciara: an initial two payments of £15 – which were apparently already made and not the result of my enquires – to be followed by nine credits of £18 and 23 credits of £15. This produces a total refund of £537, part paid with the rest to follow. This was in fact more than Ciara had calculated she had unintentionally paid into the scheme.
In its response, Complete Savings has again justified its programme, explaining that membership involves a four stage process that includes providing a name and address, credit or debit card details, creating and verifying a password and then submitting a sign-up form.
A spokeswoman for Complete Savings said: “Please be assured that we would never use credit or debit card details without appropriate permission from the person who signed up for the membership. In the same way that many other subscription-based services operate, when they joined Complete Savings they authorised us to take a recurring monthly payment for their membership fee from the credit or debit card that they provide.
“This is not an annual or fixed-term contract and you’re free to cancel…. at any time by contacting our customer service team.”
The spokeswoman added: “We work with a number of leading ecommerce businesses in the retail and travel sectors. We can confirm that Trainline and Iceland are businesses that we currently partner with. Partners are the companies we work with directly, offering their customers the opportunity to join our savings programme. Customers who choose to join can then make cashback savings when they shop at over 1000 online retailers.”
Argos is now owned by Sainsbury’s, a spokesman for which stated “Argos no longer features ads for Complete Savings.” Iceland was contacted but did not provide a statement. A spokesman for Trainline declined to comment, bar explaining that its only operation in Northern Ireland is to offer tickets for the Belfast to Dublin Enterprise service.
Other consumers may wish to check if they have inadvertently signed-up with Webloyalty International through its Complete Savings brand, which also operates through variations of the name and website completesave.co.uk. Consumers can cancel a membership by contacting the company directly (0800 389 6960 or by email, customerservice@completesavings.co.uk) and if they believe they were misled into taking out a membership they may want to request a full refund, making reference to the ASA findings.
Paul Gosling