Display of Pricing Information
21. The Scottish Government wants to make it as easy as possible for people to access information about funeral costs. To help achieve this, the draft guidance set out a range of measures about the display, accessibility and transparency of pricing information.
22. Among these measures was a recommendation that local authorities should publish fee information in the bereavement services (or equivalent) section of the local authority's website and that this be clearly signposted. Local authorities are already required under Sections 20 and 63 of the Burial and Cremation (Scotland) Act 2016 to publish their fees in paper form and online. However, in the course of developing the draft guidance, some stakeholders described difficulties in locating this information on local authority websites, especially where burial and cremation charges were included in documents covering charges for a range of other services.
23. The draft guidance also included measures recommending the display of pricing online. The consultation asked whether the guidance should include measures which encourage private cemeteries and crematoriums and funeral directors with a website to display their pricing information online.
24. There was strong support for this proposal, with 45 (92%) respondents agreeing with the question. Some respondents commented that the online pricing information would increase transparency, allow easier comparison across different providers and may also help people to plan in advance. A number of these responses included caveats including that pricing should be set out consistently across all providers, and that prices be broken down into individual components. Some responses instead suggested that packages of services and single, top-line prices are more helpful.
25. Some respondents also suggested that in the absence of agreed cross-industry descriptors for items and services, consumers could not be certain that they were comparing like-for-like across different providers. However, given the voluntary nature of the guidance, we do not think it is realistic to use it to try to establish or impose such standard descriptors.
26. Some respondents suggested that pricing information should be made available in a variety of formats, including non-digital, Easy Read, braille or audio. The Scottish Government will make the guidance available in alternative formats if requested, and local authorities will have to consider their duties under the Equality Act 2010 in respect of making information accessible. While some private businesses may choose to make their pricing information available in alternative formats, they are not obliged to do so.
27. The draft guidance included a measure encouraging burial and cremation authorities to display pricing information in a format that could be downloaded by members of the public, such as Portable Document Format (PDF). Some consultation responses pointed out that this format might not be suitable for people accessing the internet using a mobile phone, and that downloading the pricing information would require more mobile data than accessing the information through a browser. Some responses also argued for pricing information to be made available via social media, as some companies who do not have a website may have an online presence through social media. In recognition of these points, we have modified the guidance to allow for greater flexibility.
28. Some concerns were raised about the provision of pricing information online, with responses suggesting that this may encourage consumers to make decisions based on cost alone. This is discussed further in the BRIA.
29. In the course of broader consultation with stakeholders, concerns were expressed about the ability of burial authorities that operate on a non-commercial basis, such as community cemeteries in the Western Isles, to adopt the guidance relating to the display of pricing information. We have acknowledged this in the final guidance and it is discussed further in the Island Communities Impact Assessment.
30. Overall, provision of pricing information online was overwhelmingly supported in consultation responses and so we have decided to retain this in the guidance for burial authorities, cremation authorities and funeral directors. We have, however, made clearer that the provision of this information does not necessarily require the creation of a bespoke website, and could be achieved through use of social media.