In Focus Risk
TELROCK SMART INTERACTIONS
Left-right: John Preston; Matt Hensby; Sarah Watts; Stuart Knock; Tariq Ali >>
engage over; once conversation is facilitated, we can understand their
situation and build trust.
How will you handle the new rights to be informed, access, and erase data? MF: The questions around data are very interesting. Like many firms, we probably do not share as much data as we could, and that is probably out of a feeling that we should not do so, or could not do so. But actually, from a customer-experience point of view and getting some consistency and some insight into what are the best channels for a particular person might be, then it may be worth sharing more. It is interesting, with GDPR coming along, that it again raises the question of what you can and cannot do.
DC: I think one of the positives around data sharing is it makes the conversation with the customer so much smoother, because you are not having to say ‘OK, I have heard what you have said, I will just check with the lender and come back to you’, which then elongates the whole process. You then may not be able to get hold of the customer again; this can then result in the customer stating you never got back to them and ultimately turns the whole scenario into a difficult situation, when actually, if you had the information to-hand, you could have answered the question and dealt with it there and then. So there is a whole host of reasons why that data, which is held by the lender, should be passed on to the third party at the outset, whether it is a contingent or purchased collection.
BK: It is interesting that banks and other suppliers of credit are rightly of the opinion that you should not incentivise collectors on monies they collect, as this may lead to the wrong behaviours. Yet it appears that they
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continue to sell debt to the highest bidder and pass out ‘contingent’ work to the organisations that collect the most money!
SK: And, on a contingent basis, we pay you a commission based on what you collect, nothing to do with outcome, nothing to do with data, nothing to do with customer journey, just what you collect.
DC: I am delighted to see that there are some creditors who have taken the bull by the horns and piloted other forms of remuneration, but, actually, the reality is that the DCA can end up being worse off, especially where any combined commission rates are reduced as a result. This can be due to the ‘admin fee’ not being high enough. For example, for every I&E you process, you might receive a value or set fee – but often it just does not equate to enough to cover the true cost of the process. If you were to compare this to the commission on the money they collected, they would have been better off on the previous commission basis. So it feels a little like creditors are paying lip-service to it, by suggesting to ‘do it this way because it looks and feels better’, but actually the DCA is not being rewarded fairly. It is a shame because, in my opinion, the sector will struggle to survive profitably unless the creditors change the way that
they remunerate DCAs. There is a firm requirement for the customer journey to be a good one, and you cannot hope to adhere to that without undertaking the process in detail, which takes time and resource as calls become longer and breathing space becomes extended for the truly vulnerable customers. You cannot expect a firm to go that extra mile for no gain. I can see that the creditors acknowledge there is a need for external collections, but their boards or purchasing departments do not seem to be aligned in terms of what that cost now looks like.
CJ: There is an issue with the procurement departments because they would want to sit in front of the board and say ‘I can reduce the cost of this by 15%’, nobody would look at the quality of the outcome.
There is a whole host of reasons why that data, which is held by the lender, should be passed on to the third party at the outset
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SK: You can attribute value to learning information from certain parts of the process as well. So, in terms of vulnerability, an expression of dissatisfaction or vulnerability is a big thing, but if you suggest that a client might want to pay when we have done the 30-day hold, and then another and we have some detail come back and find that the customer is vulnerable, which the client did not know before they gave the account to us, then we are told there is no commercial value in that information. In terms of GDPR, it is a huge challenge. We are contacting our clients to say, if we are on their first- placement panel, and identify vulnerability today, they must make arrangements to take that data back from us; even if the systems are not there to do it today. They really should not recycle that same customer to another agency either at all, or especially without that information, as we do not think that is compliant with GDPR, but we cannot tell them how to write their rules. CCR
April 2018
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