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© Professional Planning Forum 2008 Best Practice Programme 2008 1 Latest outbound regulations from OFCOM

Latest outbound regulations from OFCOM - The Forum Complian… ·  · 2010-05-08proposal for factoring answer machine detection (AMD) ... "...Ofcom recognises that at present, and

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© Professional Planning Forum 2008Best Practice Programme 20081

Latest outbound regulationsfrom OFCOM

© Professional Planning Forum 2008Best Practice Programme 20082

Latest outbound regulationsfrom OFCOM.

Are you compliant with OFCOM regulations for

use of automated outbound systems? And are

you still compliant after the latest changes?

Understand the new guidelines and plan for any

changes you want to make in your own outbound

operation

© Professional Planning Forum 2008Best Practice Programme 20083

Why Should We Bother?

© Professional Planning Forum 2008Best Practice Programme 20084

Consequences

© Professional Planning Forum 2008Best Practice Programme 20085

Who have OFCOM Investigated

Banks

Telecoms

Kitchen Suppliers

Debt Recovery

© Professional Planning Forum 2008Best Practice Programme 20086

Where we were before

Limit abandoned calls to a rate not exceeding three per

cent of all live calls made in any 24 hour period

Playing a brief message giving details about any call

answered before an agent is available

Calling line identification (CLI) information to be provided

so that consumers may return the call

© Professional Planning Forum 2008Best Practice Programme 20087

Where we before cont’d

A 72-hour period before a telephone number receiving

an abandoned call may be called again without the

guaranteed presence of an agent

Unanswered calls must ring for at least 15 seconds

Records are kept for a minimum period of six months

that demonstrate compliance with the procedures

Remember - These are only Mitigating factors

© Professional Planning Forum 2008Best Practice Programme 20088

The Revision

In September 2008 OFCOM issued a revised statementof its misuse policy for consultation the main points ofthis were –

Clarification of which factors in their rules carry mostweight

Targeting use of AMD (Answer Machine Detection) andwhat are known as ‘False positives’

Inclusion of ‘Call Steering’ as persistent misuse

© Professional Planning Forum 2008Best Practice Programme 20089

What are the changes?

Clarification of the steps to be taken and procedures

that call centres should adopt to minimise the nuisance

caused by silent or abandoned calls, including a fresh

proposal for factoring answer machine detection (AMD)

false positives into the abandoned call rate calculation;

A set of proposals related to the use of automated

messaging;

A clarification that the unscrupulous exploitation of

revenue-sharing numbers represents a form of

persistent misuse.

© Professional Planning Forum 2008Best Practice Programme 200810

The key changes for diallers

the ‘abandoned call’ rate shall be nomore than three per cent of ‘live calls’,

calculated per campaign (i.e. across callcentres) or per call centre (i.e. acrosscampaigns) over any 24 hour period,

and shall include a reasoned estimateof Answer Machine Detection (AMD)

false positives

© Professional Planning Forum 2008Best Practice Programme 200811

The key changes for diallers

in the event of an ‘abandoned call’, avery brief recorded information message

is played no later than two secondsafter the telephone has been picked up,which contains at least the following…..

© Professional Planning Forum 2008Best Practice Programme 200812

Is Answer Machine Detect dead?

No. Ofcom have not banned the use of AnswerMachine Detect, but the guidelines are soarcane that continued AMD use requires verysignificant thought for each call centre andeven each campaign. To quote Ofcom…

"...Ofcom recognises that at present, and untilaccuracy rates improve, it will be very difficultto use AMD technology without breaching thethree per cent guideline."

© Professional Planning Forum 2008Best Practice Programme 200813

Are the AMD rules right?

[Rostrvm Solutions opinion]. We understand andsupport the objective but the simple percentage ruledoesn’t quite address the issue.

Einstein's definition of madness: “continuing to do thesame thing, hoping for a different outcome.”

Diallers are computers and do the same thing overand over again very efficiently!

You should expect that calling a person and getting afalse positive will lead to a false positive next time.The new rules do not address the repeated falsepositive issue.

© Professional Planning Forum 2008Best Practice Programme 200814

Is turning off AMD bad for you?

If you just look at agent productivity then, Yes

If you look at business outcomes then, No

– Any false positives mean lost opportunities to ‘sell’

– consumers can detect the AMD brief delay and mayjust hang up. Another lost sales opportunity

– Listening to answer machine messages can yieldvaluable information, such as alternate contact details.

© Professional Planning Forum 2008Best Practice Programme 200815

What I need to be doing

Assess quality of AMD and makeOperation decisions about it’s continueduse

Understand the clarification around whata campaign is for abandon ratemeasurement

Look at the clarification for how quickly amessage needs to be played when anabandon call is identified

© Professional Planning Forum 2008Best Practice Programme 200816

What do I need to be doing?

Register for OFCOM Updates

Respond to all Consultations

Consult the supplier of your Dialler

platform about compliance

© Professional Planning Forum 2008Best Practice Programme 200817

Next Steps

Know the regulations - be able to demonstrate this

Make people in your company aware of the risk

Decide and document your own policy

Understand your technology and how to use it

Assign responsibility for compliance

Drive efficiency and performance from all areas

© Professional Planning Forum 2008Best Practice Programme 200818

Questions