This week I was chatting with a couple of folks in Canada, as part of my new role at a new company.
Inevitably our conversation turned to contact strategy and in particular reflections on the use of predictive dialers in the UK.
Now, in Canada we were always careful with making calls, cautious with mobile phones, respecting times and timezones. However the dialer still remained a big part of the day.
It was therefore initially surprising when I returned to the UK and observed just how the how little the dialer was being used. Legislation I discovered, backed by high fines (up to £2mm) had really changed the industry and the outbound call was on the decline.
UK Rules: Ahead of the curve?
For those not in the UK, these are the rules that generated the change.
- The ‘abandoned call’ rate shall be no more than three per cent of ‘live calls’ over a 24 hour period
- In the event of an ‘abandoned call’, a very brief recorded information message must be played within 2 seconds
- Calls which are not answered must ring for a minimum of 15 seconds before being terminated
- When an ‘abandoned call’ has been made, any repeat calls to that number in the following 72 hours may only be made with the guaranteed presence of a live operator (the ‘72 hour policy’)
- For each outbound call a Caller Line Identification (CLI) number needs to be presented
- Any call made to the CLI number cannot not be used as an opportunity to market to that person, without consent. Records are to be kept for a minimum period of six months that demonstrate compliance with the above
- Additionally, if your dialer thinks it has connected to an Answer Machine, then any extra calls made that day must guarantee an agent
Impact on Collection Operations
Other markets of course have similar rules. However with the high prevalence of answer machines and tough compliance requirements in place, the efficiency of dialers became limited.
And, it has had an impact on efficiency and staff morale. Afterall staff who were used to talking with people and solving issues were now left listening to answer machines.
Alternatives have been sort and volumes have dwindled.
The regulatory focus in this particular case has been on reducing silent calls, and their impact on society.
Undoubtedly it has benefited many customers, the industry has innovated and the world has not fallen apart.
There are now more self serve options, rapport building and relationship based, focused conversations going on. In many ways, for many companies this has been an opportunity, a way to offer a competitive advantage, to reboot relationships with customers, and it works.
Broader customer changes
However this also broadly reflects a wider trend of increasing customer influence and this is being seen across the various markets.
- In Canada: Customer focused collections is a current topic, nicely expressed in the article “The collections world is changing are you keeping up“
- In the UK: A similar discussion and we have not just seen this trend, but also have this enshrined in regulatory legislation (eg FCA CONC handbook)
Customers are in control, demanding choices and influence. It is important for us to react and react positively. Something many leading players are doing already.
So what’s next
For the UK, we are now waiting for the output from the next OFCOM consultation. Probably more change and it is important to be prepared.
- There could be more capacity and strategy changes required. Are these understood, anticipated should the changes come to pass?
- Is there a plan of action or a checklist ready for when they are published?
- Are potential impacts calculated and have they been clearly communicated (upwards) in your organisation… avoiding nasty surprises?
For other markets such as Canada, preparing for similar changes is also prudent.
- Are you being proactive and introducing customer centric processes in the organisation?
- Are you close to legislation and common practice in other markets?
- Would you be ready if similar legislation was introduced in your market?
We all like to talk across markets and hear about the best ideas from the best people. It should be no suprise if we see similar regulatory frameworks in a market near you soon.
So are outbound calls finished? Not quite, there is still a lot of value, but fundamental change is afoot and the nature of the process will significantly evolve.
Time to hold onto our hats and get out in front of that change.