Don’t Be Intimidated By Regulations. We’re Here To Help
Ofcom’s December 2016 directives on Persistent Misuse make a lot of sense – but there’s still a lot here that troubles our CTO, Eddie Gahan
At a time when voice in business is under pressure from SMS, social media and OTT-style messaging, do we really need even more control on how it’s used?
The public seems to think so – and plus, as the regulator, Ofcom, is there to protect us all from annoyance and the danger of conmen responsible, businesses will of course comply with its strictures.
Its most recent guidance on avoidance of what it labels Persistent Misuse, however are particularly stringent – and those brands with large volumes of outbound voice messaging have a big task on their hands to align with them.
We Are Simply Not Going To Interrupt A Customer, Sorry
One regulation in particular our customers are querying is the requirement to begin the message no later than 2 seconds after the recipient begins to speak. In the majority of calls, this won’t be a problem as people generally process a new phone call in half second with a simple “Hello”.
But what about people who give a long greeting, listing their number and name? Are we expected to barge in with the message exactly two seconds after they start talking? Our call system doesn’t do that – it’s rude and delivers a horrible user experience. We only ever commence message delivery after the recipient has finished talking – and as we use the entire greeting to classify the call as a live recipient, we feel we comply with the intent of the regulation.
Keeping The Customer Hanging On
One of the core Ofcom requirements is that when you’re making outbound calls that can redirect a recipient back to your call centre, they can’t be left hanging in a queue. It’s vitally important that the customer is connected to an agent in a timely manner.
As a result, we are recommending to VoiceSage customers that team leaders and call centre managers are fully trained up on any outbound dialer. Why? Because tuning an outbound campaign’s call rate is the best defense. The good news is we’ve just produced new training videos to assist our customers in this.
There’s a number of ways to control a campaign in VoiceSage – from scheduling the maximum number of available agents to actively changing the call rate to speed up or slow down as appropriate. And an upcoming improvement will be to create APIs so that call centres can automatically feed us information on their queues so that we can actively adjust the campaign call rate.
Silence: Evidence Suggests Rarely Golden
Silent calls: the bête noire for the vast majority of us, and one of the main reasons for the new regulations. Rightly, Ofcom want to eliminate the problem as it causes the most inconvenience and anxiety. But just what are silent calls, and how do they differ from abandoned calls? While the term does cover calls where nothing is played to the recipient and/or a quick hang-up occurs, it also covers calls where indirect noise is heard, or a message that doesn’t convey any information to the recipient about who the call is from and what it concerns.
One of the great advantages of VoiceSage being a SaaS-delivered service instead of a Platform (PaaS) one is that we have a close relationship with our customers and can assist them in creating call workflows that convey information efficiently to the recipient. Also, as part of our product extensions planned for later this year we’re developing new features and settings to enforce national regulations that will eliminate any possibility of a silent call.
That should easily help you fend off this one, but then we have the issues of abandoned calls to address. Again, this comes down to ensuring you have an agent available to take a customer’s call when they’re transferred back to the call centre through campaign management rules. If necessary, it is acceptable as far as Ofcom is concerned to put the transferred call in to a call queue or on hold for a short period while caller information is read out to the agent – but this should be kept to as short a time as possible. And while Ofcom advise against “unfairly long wait times”, they don’t give any guidance on how long is too long.
Some of our customers have also raised a worry on how to handle transfers where the recipient hangs up before they’re connected to an agent. In our opinion, if a recipient disconnects within say 30 seconds of the start of the transfer and before the agent has had time to start to help, then it is outside of the calling party’s responsibility or control – and while still an abandoned call, it should not be considered misuse. In terms of what we do for our customers, we try to make it as easy as possible for them when it comes to compliance, and one of our features which will help a lot when calculating Abandoned Call Rates is our campaign statistics report. On the report, you’ll be able to get information like the number of calls that were Transfer Abandoned (Recipient abandoned call), Live calls, Successful transfers, Went To Answering Machine and so on. To assist even further, development of a special ACR report has been added to our development backlog.
CLIs – One of Your Least Favourite TLAs?
One of the easiest ways to fall foul of the regulations is in the misuse of a CLI (Caller ID) when making outbound calls. We work closely with our customer base, and we are confident in recommending that the CLI should never be a premium rate number and should always be the public number for your call centre, which when connected will either connect to an agent or play an informational recording.
In product terms, VoiceSage can’t verify the CLI numbers you enter are valid, but we do check the format to ensure you’re not entering in Premium rate, 070 Personal numbering or other special and costly services.
Ofcom-Friendly Best Practice
* Never be guilty of the much-disliked silent call by having a clear, concise message to deliver to your customers. Make sure to always leave an answering machine message as well
* Train your call centre managers to actively manage the campaigns so that no customer is left hanging in a hold queue
* Verify that outbound campaigns show a valid non-premium rate CLI that will connect back to your call centre
* Keep an eye on this space and the rest of the VoiceSage site and our newsletter and social media channels, as 2017 will be full of new features that will help keep you compliant with all the regulations you need to worry about.
Where To Find Information In The Ofcom Guidance
A2.19 – Time taken to connect the called person to a message.
A1.28 – Misuse resulting from use of technology.
A2.21 – Management, practices and processes & A1.5 ACS, Over-dialling.
Annex 1 – Silent calls, Abandoned calls. A1.8 & A1.11 Calling Party’s responsibility or control.
CLIs – A1.18 to A1.24 – Misuse of a CLI facility.
These issues are not a cause for worry and are easily fixed, so let’s work together to sort it!
Note that we will discuss the topic of Answering Machine Detection in a forthcoming post.
Eddie Gahan is VoiceSage’s Chief Technical Officer