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The Analysis CSA

Hold the line

Could a change in the law on silent calls have serious implications for the collections industry?

Leigh Berkley President, The Credit Services Association

In the world of collections, technology has been a significant enabler. Voice analytics, handhelds for field collectors, and web chat are just three examples of innovations that have improved the lot of customer and collector alike. But there are few innovations that have

had a more dramatic impact on our industry than dialler technology, a technology that has taken the art of communications, quite literally, to another level. Call centres use dialler technology to

dialling element, leaving agents simply to press a button to dial the next person on the list as soon as they become free. They would then speak to the customer if they are at home or if not, leave a message before moving on to the next call. This is often called ‘preview mode’. To some people’s way of thinking, this is

maximise the amount of time an agent spends on the phone. Clever algorithms are written to estimate how long each call will take and when the next agent will become available, automatically dialling the next number on the list at the right time to deliver the next call just when the agent comes free. When it works, it works incredibly well, maximising call and operator effectiveness and minimising downtime. As with all great plans, however, things can – and occasionally do

The levels of complaints from consumers about the collection industry’s use of dialler technology is negligible – we are not considered to be part of the problem

exactly what should happen, but from an industry perspective, it would simply be unworkable. The cost of employing the additional number of agents required would simply be prohibitive, with some large debt purchasers predicting an increase of 50% to 150% in their call-centre staff. And, of course, the ultimate loser would be the customer. Rather than preventing customer detriment, it could, in fact, result in the very outcome it is trying to avoid. As with so many of these measures, they are well intentioned but can have unintended

– go wrong. Variables are such that, even if the dialler is set up correctly, calls can be made too soon, or too late, with the resulting (apparent) chaos. Even when run by the most experienced dialler manager, there can still be a small proportion of calls that are abandoned (and in that case, a message is played to the person dialled explaining what happened and who was calling) or so-called ‘silent’ calls, where the person is dialled and picks up the phone to find complete silence. Agencies have, of course, made tremendous inroads into

eliminating silent calls, and current Ofcom rules say that no more than 3% of calls should be abandoned. So much for the background; what is the story? The story is that

Ofcom recently launched a consultation on proposed changes to the ‘Revised statement of policy on the persistent misuse of an electronic communications network or service’. In amongst these changes are apparent proposals to reduce that 3% tolerance for abandoned calls to zero. If that were to come about, the only way an agency could guarantee a zero rate would be to effectively switch off the predictive

February 2016

consequences for compliant firms. The good news, however, is that Ofcom appears to be listening. A party from the CSA and two industry specialists aired our concerns at a recent meeting, and met with a most positive response. We were assured that the regulator did not have debt collection

agencies in their thinking at the time that these proposals were constructed, neither did they feel that the rules have materially changed. They appeared to accept that we have a legitimate need to keep in touch with our customers, and confirmed that their enforcement action will continue to be based on complaints. Since the levels of complaints from consumers about the collection

industry’s use of dialler technology is negligible, we are not considered to be part of the problem. We also suggested a distinction between solicited and unsolicited

calls may be useful, and will continue in constructive dialogue with Ofcom over coming months. Of course there is many a slip twixt cup and lip, and the cup of

kindness shared with Ofcom could yet spill over. We are, therefore, by no means complacent, and would urge all of our members and those using diallers to respond to the consultation, which ends on 10 February, and ensure that our voice is properly heard. CCR 11

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