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Turning TCPA Lemons into Enterprise Lemonade Exelon and Neustar Discuss TCPA and Enterprise Phone Management for Utilities

Turning TCPA Lemons into Enterprise Lemonadeenergycentral.fileburst.com/EC/052218_neustar.pdf · Turning TCPA Lemons into Enterprise Lemonade Exelon and Neustar Discuss TCPA and Enterprise

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Turning TCPA Lemons into Enterprise Lemonade

Exelon and Neustar Discuss TCPA and Enterprise Phone Management for Utilities

©2018 Neustar Inc. All Rights Reserved 2

Mitchell Young Neustar Exec. Director, Identity Solutions

Kindle Cook Exelon Senior Project Manager

[email protected] [email protected]

Presenters

AGENDA

©2018 Neustar Inc. All Rights Reserved 3

Industry Insights & Neustar Background Customer Phone Numbers & Impact to Utilities TCPA & Outbound Communications

– Background on TCPA– Knowing Your Customer’s Identity

Exelon TCPA Project

LEGAL DISCLAIMER

The information in this presentation was compiled for informational purposes only. No information contained herein is intended to constitute legal advice and accordingly, you should consult with your own attorneys when developing your own programs and policies. We do not guarantee the accuracy of this information or any results.

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Industry Insights & Neustar BackgroundWhy Accurate Customer Phone Numbers Are More Important Than Ever

©2018 Neustar Inc. All Rights Reserved 5

©2018 Neustar Inc. All Rights Reserved 6

TCPA LAWSUITS Are You Prepared?Largest Lawsuit (by year)

2017: $280M CSP 2016: $76M Travel 2015: $60M Financial Services 2014: $75M Financial Services 2013: $35-$47M Quick Service Restaurant

1.1K2012

2014

2.6K

4.5K2016 2017

4.4K

CONSUMER DATA IS CONSTANTLY CHANGING

45MConsumers change

their phone numbers

60MPeople relocate

Every Year…

©2018 Neustar Inc. All Rights Reserved 7

For over 20 years, a leader in the telecommunications industry:

Power 90% of U.S. Caller ID

Manage U.S. Directory Assistance

N. American Numbering Plan Administrator

TCPA Advisor to the FCC

©2018 Neustar Inc. All Rights Reserved 8

A leader in phone identity management:

10 of Top 10 U.S. Banks

Top 3 U.S. Cable TV Providers

8 of Top 10 Insurance Companies

7 of Top 15 Utilities

50% of U.S. Online Retailers

Verify Consumer Identity 1.4 Billion Time Each Day©2018 Neustar Inc. All Rights Reserved 9

Consumer Phone Numbers & Its Impact on Utilities

©2018 Neustar Inc. All Rights Reserved 10

19 National Drive McLean, VA

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PROACTIVELY KEEP CRM DATA ACCURATE & UP-TO-DATE

John Smithe

415-212-2255

571-545-6789

[email protected]

19 National Drive McLean, VA 22182

Misspelled Name

Non-Standardized Address

Unknown Phone Type

Unverified Email

John Smithe

415-212-2255

[email protected]

Inexact Last Name Match

Type = WirelessMismatch: Phone does not belong to John Smith

Email Verified:Belongs to John Smith

John Smith

Corrected Name Available

Wireless Phone Linked to John Smith. Active Phone. Available.

19 National DriveMcLean, VA 22182-4759

Standardized and Verified: Address belongs to John Smith

ORIGINAL CRM NEUSTAR CLEANSE/APPEND

CONTINUOUSLY CORROBORATED

[email protected] Email Available

Emergency Notifications

!

GeneralNotifications

Collections

$

Marketing

Account Origination

Inbound Communications

©2017 Neustar Inc. All Rights Reserved

Neustar Customer Identity Management

GeneralNotifications

Ensure customers receive messages

Improve customer experience

Reduce TCPA risk

Reduces inbound callsCollections

$

Emergency Notifications

!

©2017 Neustar Inc. All Rights Reserved

Identity Management: Outbound Communications

Inbound Communications

• Increase customer identification

• Improve customer experience

• Reduce live agent costs

• Increase IVR containment rates

©2017 Neustar Inc. All Rights Reserved

Identity Management: Inbound Communications

©2018 Neustar Inc. All Rights Reserved 15

Fortune 500 estimated spend on customer experience

$558BBut who are you really interacting with?

Source: Gartner, Fortune

YOU SPEND BILLIONS TO BE CUSTOMER-CENTRIC

Utilities and The Telephone Consumer Protection Act (TCPA)

©2018 Neustar Inc. All Rights Reserved 16

FCC 2015 DECLARATORY RULING ON TCPA

Two Key Issues for Utilities

1. Definition of “Called Party” Consent not valid if phone reassigned (‘Intended recipient’ irrelevant)

2. Consent/Revocation of Consent– A consumer may revoke consent at any time, through any reasonable means– EEI/AGA Petition clarified ‘prior express consent’ provided at sign-up

©2018 Neustar Inc. All Rights Reserved 18

CONSENT REQUIREMENTS FOR AUTO-DIALING OR TEXT MESSAGING

Types of Notifications Examples Consent Required

EmergencyNotifications Scope is unclear Exempt

Informational Notifications

Service Outages Meter Work; Field Work Pending Curtailment Subsidized Service Brownouts

Prior Express Consent Satisfied if Customer

Provides Phone #

TelemarketingMessages

New Services Scope is unclear

Prior Express WrittenConsent

Risk lies in Auto-Dialing a Reassigned Cell Phone

Outbound Customer Communications

Knowing Your Customers Identity

©2018 Neustar Inc. All Rights Reserved 19

70%

7%

5%

7%

11%

PHONES

Definition

VERIFIED PHONE

UNKNOWN

BUSINESS PHONE

DISCONNECTED

WRONG CONSUMER

18%-22% Phones Wrong or Disconnected Customers Not Receiving

Messages/Alerts Significant TCPA Risk

PHONE QUALITY: UTILITY INDUSTRY BENCHMARK

©2018 Neustar Inc. All Rights Reserved 21

NEUSTAR VERIFICATION FOR TCPA

John Smith555-555-1212

1/1/2015Name-to-Phone: VerifiedPhone Type: MobilePhone In-Service: 12 Months +Disconnected: No

VERIFIED

Challenge: Customers 44% more likely to have service disconnected if they don’t receive Disconnect for Non-Payment Call.

©2018 Neustar Inc. All Rights Reserved 22

SolutionNeustar Phone Verification and Proactive Change

Results $1.6M in wasted truck roll costs identified Improved customer experience Reduced bad debt

CASE STUDY: ‘RECEIVED’ COMMUNICATION REDUCES DISCONNECT RATES

Challenge: Customers call-in when they don’t receive important outage communications due to wrong numbers.

©2018 Neustar Inc. All Rights Reserved 23

Our SolutionNeustar Phone Verification and Proactive Change

The Results 5% increase in customer satisfaction scores 7% less inbound calls $1M+ in annual cost savings Less risk to customer health and safety

CASE STUDY: ‘RECEIVED’ COMMUNICATION REDUCES INBOUND CALLS

908-575-7585

© 2018 Neustar Inc. All Rights Reserved 24

INBOUND COMMUNICATIONS: AUGMENTING A CRM

ANI NOT FOUNDQuery Neustar

Utility Customer CRM

908-578-7585

© 2018 Neustar Inc. All Rights Reserved 25

INBOUND COMMUNICATIONS: AUGMENTING A CRM

IMPACT 76% increase in ANI to ANI match 26% increase in IVR containment Reduce live agent costs + improve

customer experience

NEUSTAR ACCOUNTLINK

NEUSTAR REPOSITORY908-578-7585 (Mobile)

Patrick Smith32 Schindler PlaceNew Brunswick, [email protected] (Landline)908-578-7585 (Mobile)

Also in Household:

Camille [email protected]

Lauren [email protected]

Utility Customer CRM

MATCH FOUND:

Patrick SmithCamille Smith32 Schindler PlaceNew Brunswick, NJPhone: 908-505-9164Status: ActiveAccount: 1264587Balance: $279.00

The Implementation of a TCPA Solution at Exelon Utilities

May 2018

Kindle Cook - Sr. Project Manager

Exelon TCPA Project Steps

1. Project goals

2. Developing project team

3. Completing phone scrub of the Customer CRM early

4. Creating inventory of automated calls

5. Determining process for opt-out/wrong number requests

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1. Project Goals

Designed to mitigate risks associated with 7 million customers Over 100 programs that contact customers Millions of customer calls a month

Two key issues1. Wrong/Recycled Phone Numbers

− Initial and ongoing scrub of phone numbers is important to ensure customer information doesn’t contain wrong/recycled phone numbers

2. Consent & Opt-Outs− Ensure customer has a reasonable way to revoke consent− Technically, be able to track and implement revocations

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2. Project Team & Legal Sponsorship

Exelon Project Team – members from each operating company ComEd PECO BGE

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3. Phone Number Scrub Early & Ongoing

Neustar verified if customer still owned phone number Create baseline of ‘consent’ and ‘phone ownership’

Wrong/Recycled numbers identified Replace wrong/recycled phone numbers with 999-999-9999 or blank

Impacts of removing wrong numbers Consider regulatory requirements to contact customer not by phone Costs associated with contacting customer to get a new phone number

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4. Inventory of Customer Calling Programs

Outbound calling programs divided into 3 groups: 1. Informational

− Customer can opt out2. Marketing

− Customer can opt out3. Emergency

− Customer cannot opt out

Note: Regardless of category, all text messages are opt in only

Get Legal sign-off on classification

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4. Inventory of Customer Calling Programs

Capture details of Calling Programs

Description of activity If made by vendor, vendor’s name Call or Text Type of integration Volume estimates for all calling programs

Business ownership

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o Credit and Collectionso Marketingo Field

o Employeeo Government/Externalo Storm

5. Opt-Out & Wrong Number Requests: Landline vs Mobile

Landline and mobile phone numbers identified to meet requirements

Opt-Out option for following calls:1. Landline numbers for marketing purposes2. Mobile numbers for all purposes (except emergency)

Wrong Number reporting option offered on all calls -- Emergency, Informational, and Marketing -- for1. Landline numbers2. Mobile numbers

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5. Opt-Out & Wrong Number Request Options & Policies

Customer options for updating notification preferences Call the Call Center to inform a live agent Press 9 during an automated call Reply STOP to a TEXT message Press 7 to indicate a wrong number during an automated call Online preference center

Live agent must process Opt-Out or Wrong Number, but DOES NOT need to proactively ask

Express consent can be collected during customer sign up or during updates to contact information

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5. Managing an Opt-Out

When consent revoked, non-emergency calls/texts stopped Once you opt out of one program, you opt out of all

Bill insert used to inform customer of Opt-Out impact Directions on how to opt back in

Consent must be re-established before number is used again

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Final Thoughts & Considerations

Maintain within customer system:• TCPA opt out list• Landline or Mobile Phone indicator

If all vendors placing calls/texts don’t go live at same time, may want to address risk during the phase-in period

Develop a process to add new calling programs or vendors post-project

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©2018 Neustar Inc. All Rights Reserved 37

KEYS TO TCPA

Capture and maintain proper consent

Understand the type of phone you are calling

Confirm phone still belongs to intended call or text target

©2018 Neustar Inc. All Rights Reserved 38

Questions?Mitchell Young Neustar Exec. Director, Identity Solutions

Kindle Cook Exelon Senior Project Manager

[email protected] [email protected]