DISP – 1.3 Complaints Handling Rules a.k.a get your house in order

They say a change is as good as a rest don’t they, but wouldn’t it be refreshing if we could take a hefty swipe at DISP to tidy it up and get it updated for 2020 and beyond? That’s why this is the first in our series on looking at DISP, being able to take what you need and then overlaying where we now are in terms of technology and customer expectations. 

So starting at the beginning, we’ve had a look at DISP 1.3 to translate it for you and to give you some food for thought in terms of working within the framework of the rules that still loom large in today’s complaint handling.

1.3.1 outlines the fact that you need to have ‘effective and transparent procedures for reasonable and prompt handling of complaints’ and 1.3.2 goes on to say that complaints should be allowed to be made ‘by any reasonable means’ and ‘require resolution’.

You’d think this would be obvious, but you’d be surprised at what we’ve seen when working with businesses…so, here are some questions to pose to yourself:

What does your complaints handling process look like?

This is more than thinking about a flow chart, this is about making sure the various parts of your process fit together efficiently. Is it a slick, well-oiled machine that your staff know well and that customers are able to use easily? There will always be bits that don’t perhaps work that well, but if it’s not working at all, then it’s time  to take a good look at what you could you do to make it clearer for your customers and your staff.

Do your staff know what a complaint looks like, do they know how to log it as such and how it should be resolved within your procedures and systems?

Again, businesses tell us that they know their staff know this, but how do they know that this is the case? When we start to investigate, it quickly becomes clear that staff ‘know’ it verbatim and can rattle it off in parrot fashion, but it doesn’t translate as a good experience for a customer. For example, being able to understand it sufficiently to be able to explain what will happen f something goes pear-shaped and the impact this will have on a customer, or to feel empowered enough to suggest solutions to problems rather than finding work arounds. 

So, let’s look at something simple, by way of an example – publishing your complaints process. This always represents a good start to being more open with your customers. Which is why we spent a day snooping about to see what we think of various companies’ complaints pages on the internet (bearing in mind that not everyone has access to the internet), and it’s a very mixed bag.

Some businesses have gone into detail in terms of timelines and what the customer needs to tell you. Yeah, that’s a sound plan,  but we didn’t see one example, telling the customer what they can expect from the complaints process – how about telling them what type of questions you’d ask to investigate the complaint, so they can understand it’s not being nosey, but forms the basis of a thorough investigation? How about telling them the specific timelines that you work to to manage expectations? How about undertakings in terms of keeping customers informed of what’s happening?

This isn’t to put customers off, but helps to manage expectations from the very start. Yes, some customer might be put off, some might go straight to the Ombudsman Service, but having a fully transparent complaints process speaks volumes to your customers about your commitment to righting perceived wrongs. It also means you need have a very open undertaking to stick to those commitments and all staff need to pull in the same direction, which in turn gives you ‘measurables’ for performance. 

And, you’ll have to excuse us if we’re starting to sound like a stuck record, but a very big, HUGE hint here, it gives you a head start in terms of the FCA’s future metrics for measuring cultural change from complaints handling. 

The remainder of 1.3.1 then goes into detail about using telephone numbers that shouldn’t cost more than a basic rate and yes it does mention mobile phones.

And that’s all well and good, because we know from research from Huntswood last year that phones are still tops for making complaints. Parking that information for one moment though, we’re in 2020 now and so other communication channels have to be considered. 

Do you use messaging, do you patrol Twitter and Facebook as part of your process? If you were to pass that through the DISP 1.3.1 filter, would it satisfy the need for ‘reasonable and prompt complaint handling’?

Yeah we think it does and doubtless you do too. But we have seen examples where businesses are so intent on the damage that a rogue tweet and hashtag can do, that they forget the basic ideas behind being fair to customers. And in basic terms it sees people, who tend to be younger and more tech savvy than the older generations, on Twitter get preferential treatment over and above someone that has written into your business? 

We understand that one letter poses, potentially a reduced risk as opposed to someone on Twitter  given the exposure this could generate, but in practical terms your complaints process shouldn’t be offering a better, quicker service those using technology over those that use the phone or letter writing. So, ask yourself, if you are using Twitter, Facebook, Instagram etc, does your process treat everyone fairly to satisfy Principle 6 – in terms of treating all of your customers fairly?     

Are you confident that your complaints data is spot on so that you can satisfy the remainder of 1.3.3 in terms of reporting and having someone responsible for overall compliance?

We’ve seen some complaints processes that make it virtually impossible for businesses to accurately document their complaints, because they’ve been unable to define what a complaint is.

How would you define it for the benefit of your staff? If you can’t, how will your staff spot a complaint when it appears?

It’s a tough one this, because complaints are as individual as finger prints and so too are the people that make complaints. One person’s minor issue is another’s absolute disaster. so, it requires staff that are able to use their skills, knowledge and training in order to properly sound out the customer in order to identify an ‘expression of dissatisfaction’.  

But we also have to balance the individual staff spotting this issue against the needs of the business as a whole. We know businesses don’t want to see complaint numbers spike due to logging everything as a complaint, especially as it might not have been…but muck this part of the process up and it’ll have a HUGE impact at the higher end. Put simply, the data in, affects the data out meaning that if there is a problem at this level then you can’t rely on your Root Cause Analysis. The data will be so skewed as to provide utterly useless insight making it impossible to spot a systemic or recurrent problems.   

We think businesses need to take a good look at what they consider to be a complaint and how they define it. This will have a huge ripple effect on your Root Cause Analysis and getting your house in order. We also recommend getting your board on board with this, because there’s nothing more demoralising for those on the coal face than seeing the same problems time and time again. Apologising or investigating the same issue over and over, or worse still passing information back up the line and hearing nothing but deafening silence. It takes them time to collect all the data, translate it and report on it, but nothing will happen if the people higher up the chain don’t feel there is a need to act on it. But there is gold in that insight and solutions to the same old perennial problems, which will benefit you, your business and your customers when they get resolved. If you think about it, if you get a big enough issue, such as pricing issues with insurance, you can kiss goodbye to your reputation or some of your customers. And we all know that can take an age to turn around. 

 

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