After months of deliberating the waiting is over. On the 20thDecember 2016 OFCOM published their revised policy on “the persistent misuse of an electronic communications network or service” (policy).
OFCOM periodically review their policies. As part of the recent review they considered whether there were any improvements or clarifications to the policy required. OFCOM continue to want to understand the drivers of silent / abandoned calls and whether changing the policy would reduce the number of these types of calls, what the impact on the consumer is, and the costs and benefits of businesses operating within the policy.
Any silent or abandon call received by a consumer will at the very least cause mild irritation and at the other end of the spectrum can cause anxiety and stress. Any reduction in the number of silent / abandon calls being received by consumers can only be a good thing.
The collections and recoveries industry along with all other sectors using dialler technology will now be assessing the impact of the changes to the policy, and the required actions to be made to their operations and businesses.
Some of the key changes to the policy are:
- Removal of the 3% abandon rate threshold
- IVM calls where a consumer requests to speak to an agent and experiences an unfairly long wait time is now considered as misuse
- Organisations that do not retain or provide relevant information are more likely for action to be taken and the lack of records will be taken into consideration when determining the level of any penalty
With the removal of the 3% abandon rate threshold, all dialler users will now need to consider what level of abandon rate if any they are comfortable to operate at, as persistently working to anything other than zero tolerance (for e.g. 1%), could possibly be viewed by OFCOM as “persistent misuse”.
We do not have long to implement changes and OFCOM have stated that it expects all businesses to be compliant to the revised policy by 1st March 2017.
OFCOM will be checking to ensure that everyone is fully compliant to the policy. Previously they have taken a tough stance on businesses who have not taken the required action following changes to their policy, we expect that there will be no leniency this time round either.
In August we published our blog “OFCOM Compliant – Are you really? Prove it!” in which said that in our experience, many organisations have either misinterpreted aspects of the policy to the detriment of their business, or do not have sufficient controls in place to monitor and prove compliance.
With a maximum fine of £2M for non-compliance, many organisations do not realise they are at risk.
Now is the time to get help!
Arum offers a comprehensive “Dialler Framework Review” service where we will work with your operations, compliance and risk teams to ensure that your business is compliant whilst embedding best practice to improve contact and collections rate, and at the same time ensuring customers are treated fairly.
Our consultants have an average of 20 years’ experience in dialler technology, from a technical, strategic and operational perspective.
For more information or to find out how Arum can help your business, contact us today.
Walter Mather, Lead Consultant