DDI Software is delighted to announce the acquisition of yet another new client, based in Manchester and fully authorised by the FCA. Committed to delivering excellent levels of customer service, our client was keen to introduce new systems that would enable it to communicate more effectively with its large customer base and ensure that every single customer’s journey would be an entirely positive experience.
Operating in a highly-regulated environment, it also required new systems that could support best practice and provide complete oversight of its business operations. It was deemed essential that any new systems should not only help achieve compliance but also be capable of facilitating this being demonstrated to the relevant regulatory bodies such as the FCA. Other key items that formed part of the decision criteria included the need for structured data, and flexible access to very detailed management information on a real-time basis.
Following a comprehensive systems analysis and selection exercise, DDI Software and its Ascent CRM and callCent Telephony systems emerged as the preferred solution due to a client-focused ‘can-do’ attitude and an inherent ability to satisfy all the key business requirements. More details to follow soon in our formal Press Release.
In December 2016, Ofcom released its much anticipated and revised policy on the persistent misuse of an electronic communications network (ECN) or service. The policy changes were open for consultation between December 15 and February 16 with the new guidance coming into force, across all industries that utilise an ECN, on March 1st 2017.
With not long to go until the key deadline it is of paramount importance from a fiscal, an ethical and a compliance perspective that you conduct a review of the ways in which your organisation utilises its own ECN. You must determine as a matter of some urgency and certainly prior to the commencement date whether you are in the fortunate position that you already comply, or whether you have identified an action plan to ensure that you will comply, or otherwise.
We all know how important Compliance is to sustaining a successful business model. One look around your organisation will confirm just how pervasive Compliance has become and will reveal a multitude of compliance roles that may have seemed excessive only a few years ago. From Heads of Compliance, to Internal and External Auditors, from your entire Legal and Regulatory departments all the way to the front line staff performing Quality Assurance tasks. Everywhere, in every business, compliance is now the keystone to how that organisation proves to its customer base, its regulators and its clients that it is a modern business with a clear and demonstrable focus on improving internal adherence and external relationships.
With the introduction of the new policy also combining increased powers to seek reparation, the maximum fine that Ofcom can issue to non-complying businesses is £2,000,000.00 and it is with that figure in mind that will drive most businesses to make fundamental changes to their contact strategies prior to March 1st.
The policy changes, whilst perhaps appearing slight, introduce significant change to the landscape for firms utilising ECNs in their every day practices.
Gone is the previous 'safe-harbour' limit of 3% and with it a statement from Ofcom clarifying that it was never their intention to create a safety net. All organisations must now strive for, if not completely achieve, a 0% rate of abandoned calls and for many that will drastically change the manner in which they deploy their ECN. To mitigate what some may consider a drastic change by Ofcom they have also clarified how they will seek to bring action against firms and they will focus on prioritising cases where there is demonstrable evidence of neglect to the new policy as well as the type of misuse and the 'level of likely consumer harm'. We can expect the regulator to act both reasonably and proportionally when looking to bring enforcement action against a firm and we would further expect to see focus remaining geared towards those that are likely to produce extreme levels of misuse.
There has also been a clear definition drawn between silent and abandoned calls and how each type must be considered within the operation of a business. Ofcom do not expect any compliant, ethical business to be making or causing to be made calls which are deemed as 'silent'. There is no doubt that these types of calls can and do cause increased levels of consumer detriment and that experiencing one or more of these calls can cause serious harm to those in a vulnerable condition. Indeed, when considering how to best advise our clients on how to remodel their dialling strategies we took advice from the Vulnerability Registration Service (VRS) to see if there were any additional steps we could take to safeguard those individuals not just from silent or abandoned calls, but from the overarching impact a multiple channel contact strategy can have. It is this type of external consultation that will help to evidence to Ofcom that appropriate steps, systems and controls are in place that encourage compliance not only with the written word of the policy but also with the spirit of eliminating all detriment to consumers, where possible.
There can be no excuses, ifs, or buts. From March 1st, the Ofcom message is clear. No level of silent calls will be tolerated, whether manually dialled or not. Immediate steps must be taken to ensure your ECN cannot and will not make a single, solitary silent call. The impact on consumers is too large and ensuring compliance will be Ofcom’s 'highest priority'.
The spotlight addition to the policy is the warning that misuse can come from outside your deployed ECN and can come straight from your consumer facing staff. The inclusion of Agent Behaviour to the policy for the first time is yet another indicator that Ofcom are looking for more than simple dialling compliance, they are looking for an overarching compliant approach to how any and all contact is made with your customer or client base.
Many firms will already employ auditors and quality assurance staff to ensure their agent behaviour is of an acceptable and ethical standard and many technology packages come equipped with management information, controls and audit tools to further strengthen your commitment in this area. It would not be far-fetched to accept that when investigating potential cases of misuse, Ofcom will pay close attention to the level and type of training, supervision and discipline utilised to minimise the exposure of consumers to behaviour which is below the levels expected.
When one considers the above changes to the abandon rate, the zero-tolerance approach to silent calls and the inclusion of agent behaviour as a potential area of misuse it is of no real surprise that further changes are on the horizon.
In April 2017, new legislation and enforcement powers from the Information Commissioners Office (ICO) come into effect which for the first time will render directors of companies liable for fines of up to £500,000.00 each, which can be further enforced with custodial sentencing.
As the ICO can already issue fines related to nuisance calling it is especially important to act on these changes now, and to mitigate as much risk and exposure as possible.
Naturally, companies will seek to rely upon their current staff, their technology and their management procedures to ensure compliance pre and post the new policy and hopefully for many this approach should prove sufficient. Alternatively, DDI Software can reduce your risk by offering a Compliance Health-check to all interested parties, providing an ideal opportunity to take advantage of expert advice and assistance in achieving and demonstrating compliance.
“We love the flexibility and self-service nature of our system….and when we do call on DDI Software for support or advice their service is always prompt, knowledgeable and friendly.”
“Without the right systems in place you are effectively trying to manage in the dark. DDI’s
systems Ascent, callCent and Insight help to illuminate our business, providing clarity and visibility that enables us to quickly reach meaningful and informed decisions. It’s the perfect solution for us and one that I am sure other progressive organisations will want to explore.”
"The Ascent Collection system gives Hellix the automation required to manage large volumes of accounts in an easy to use and compliant process. It’s simple to operate, keeps agent interaction to a minimum, and DDI’s continuous product improvement programme ensures that they will continue to be a formidable force for many years to come."
"Ascent has proven to be a hugely reliable, dynamic and exciting collection system encompassing a wealth of functionality and speed of data access. Coupled with an impressive reporting module, it helps us deliver time and time again."
"We are a long-term client of DDI Software and are delighted that their systems have seamlessly integrated into our business processes and exponentially increased our productivity. The comprehensive web front end, which enables our clients to access their data real time has provided us a unique selling point and helped us to win business on several occasions."