How do I now use the dialler? What you need to know!
In late December 2016 Ofcom released their revised policy guidance ( dialler) relating to persistent misuse (of calls). They also added some clarity around the continued focus on Silent, Abandoned calls and IVM.
Ofcom, importantly, stated that the previous 3% threshold for Abandoned calls (or drop rate) that many organisations worked towards should not be considered a ‘safe harbour’.
Silent and Abandoned calls are considered as misuse, and persistent misuse would be viewed seriously, with a fine up to £2 Million.
Click here to download our essential Ofcom dialler regulation checklist.
Compliance is required from 1st March 2017!
The End of the World as We Know It!
The industry, having provided feedback to the December 2015 consultation, and amongst varying predictions of doom and gloom for the outcome, have been waiting anxiously for the output.
Ofcom, having taken their time to consider the input, have clearly stuck to their original proposal.
They have provided guidance, however not much more clarity around what needs to be done to be compliant. The interpretation is up to the companies themselves, Ofcom will just audit after the fact and then make judgement.
What are other companies doing?
This lack of prescriptive guidance proposes a problem. Just what do companies do? What should the strategy be now?
We have seen a range of reactions:
The conservative, risk adverse organisation
“The only way we can guarantee to be compliant is to set the threshold for abandoned call at 0%. We are going to turn predictive mode off and switch to preview or manual”
Safe, yes, however it is expensive as all efficiencies from the dialler are lost.
The weighted risk approach
“I am going to dial down my abandon rate to under 3%. As long as I don’t have lots of complaints and stay off the radar I will be okay”
This presents some risk of a fine and censure if there is deemed to be persistent misuse, however in the meantime efficiencies from the dialler are maintained.
The wait and see
“It is not clear what we need to do exactly, let’s wait and see nearer the time and look to other organisations in order to get clarity”
Again, this preserves the efficiencies, but could leave an organisation exposed to fines.
What does Arum recommend?
Ultimately a decision on dialler strategy is one that needs to be informed by the risk appetite of the company. For zero risk of non-compliance a 0% threshold will need to be used, with rising risk as the threshold increases. Moving to a lower threshold will undoubtedly introduce additional expense and inefficiencies.
Reliance on outbound calls as a core method of contact has become increasingly prohibitive. This new guidance will only make matters worse, and will accelerate decisions to further embed digitalisation.
It’s now not just what the dialling strategy should look like, but what the overall, end to end, channel strategy is.
There will be pressure on cost and now is the time to review your contact strategy to mitigate the impacts.
In some ways, the days of outbound predictive diallers, with AMD switched on, made us lazy. We were used to being able to spin the dialler and not having to think much about the strategy.
Whatever the approach you now adopt, now is the time to think about this and be smarter in your approach. We only have until 1st March 2017 folks!
Chris Warburton and Walter Mather, Lead Consultants
Our consultants have an average of 20 years’ experience in dialler technology, from a technical, strategic and operational perspective. Contact us and find out how we can help your business.
T: (0)870 383 1980