DPA responded to the Commerce Commission request for views for its 111 Contact Code Review.

We put out a call to our members via this newsletter seeking feedback on the Code and, while we didn't receive many responses, the responses we received informed our submission.

Most of the responses we received said that people didn’t know about the Code or the duty to provide other means of contacting the emergency services during a power outage.

The responses we got from our members would suggest that there is an issue in regards to what is deemed to be ‘proof of vulnerability’.  

DPA recommends:

  • The Code refers to ‘disabled people / consumers’ rather than ‘vulnerable consumers’
  • The Commerce Commission mandates telecommunications providers to provide all consumers with the Code and information on their duty to provide access to emergency services during a power outage.  Furthermore, the Commerce Commission should monitor the uptake of such alternative means of contacting the emergency services.
  • That all information pertaining to the 111 Contact code be made available in alternative formats including: New Zealand Sign Language, Braille, Easy Read, audio and large print.
  • The Code make it clear that ‘demonstrating vulnerability’ shouldn’t be too cumbersome or intrusive and that there are ways other than a doctor’s certificate to demonstrate need.


Read DPA's submission for the 111 Contact Code Review

111 Contact Code - extra support for people unable to contact 111 during a power cut


If you meet the criteria of a 'vulnerable consumer' under the Commerce Commission’s 111 Contact Code you will be provided with a way to contact 111 emergency services in a power cut.

What is a 'vulnerable consumer'?
Under the 111 Contact Code a vulnerable consumer is somebody who:

  • Relies on a home phone through a fibre, wireless network or VoIP to call 111; and
  • Doesn’t have an alternative way to contact 111, such as a mobile phone; and
  • Can demonstrate they are at particular risk of requiring 111 emergency services for health (for example a known medical condition), safety (for example family violence) or disability (for example sensory, intellectual or physical impairment) reasons.

How do I apply?
If you, or someone in your household believes they would qualify as a vulnerable consumer, the next step is to contact your telecommunications service provider and follow their 'vulnerable consumer registration process'.


How will I be supported?
Your service provider will offer a solution to enable you to contact 111 emergency services in the event of a power cut. The solution will best suit your needs either a mobile phone device or, if your home has limited or no mobile coverage, a battery back-up device could be more suitable.

For more information, including about which technologies need power to work, tips for being prepared, and about the Emergency TXT service for people with hearing or speech difficulties see: Home phone technology and calling 111 factsheet [PDF]