#4 Are you catching all complaints?

Posted by Sarah Lawrence on June 5, 2020
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In the fourth of our series of guest blogs on key issues for complaints handling, Sarah Lawrence (access the preceding blog here...), former Technical Manager at Financial Ombudsman Service asks if companies are really catching all complaints and submitting them to Root Cause Analysis

It’s become something of a mantra wherever we go, businesses saying a lot about learning from complaints. We know it’s an expectation handed down from the regulator and the Ombudsman Service, and it gets trotted out, so that we can all say we’ve done our bit. Unfortunately, however, the reality is somewhat different, and it reflects in the bitty, piecemeal nature of dealing with complaints from the very start to the potential end after the Ombudsman has made the final decision.

As a consequence, we can’t help feeling that it all leads to a lack of oversight, a lack of a clear direction and purpose that means complaints are just seen as a necessary, and inevitable by-product of interacting with customers. This is a real shame because this sub-conscious thinking leaks through to everything – from the way staff log the initial complaint, to the way the board doesn’t really buy into complaints Root Cause Analysis (RCA). It all makes complaint handling one long, relentless treadmill, where nothing is learnt. No one wants that; not you, not your staff and definitely not your customers.  

Complaint 4

But let’s go back to the very basics, before we get ahead of ourselves. So, what is a notice of dissatisfaction according to the Dispute Resolution Rules (DISP)? This is defined as:

‘…any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service, claims management service or a redress determination which:

(a) alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and

(b) relates to an activity of that respondent…’

And when it comes to DISP, these few words cover a multitude of potential situations because, well, there wouldn’t be sufficient cloud storage to encompass all the eventualities if it each potential situation was defined. It makes it more complicated when you must interpret what the customer is saying to you or your member of staff in the moment. Is that pointed statement about the lack of pens in your branch a notice of dissatisfaction? Is that sarcastic Tweet about ‘loving your customer service’ enough to start the complaints ball rolling? Or is the sobbing on the end of the telephone enough? At what point do you decide a complaint has been made?

The simple answer is they all could well be. It takes investment on behalf of a company to ensure staff have the skills and knowledge to be able to delicately sound the customer out so to be sure they have logged that complaint and so started the complaints process at the right time. And therein lies the challenge, because complaints are nuanced, they can be missed, or staff can be very keen to resolve things without the need for a complaint. Helpful, but not helpful, because if your staff ‘deal with it’ or worse still, it’s missed entirely and simply not logged your RCA, and so your board, is missing out.   

Complaint 5

You might shrug and think ‘it’s not an issue as long as it’s resolved’, and if they aren’t logged who will know? But that's exactly the point! The complaint has been missed, the customer might have a solution to that issue, but what if the problem extends further to other less vocal customers? They may well vote with their feet and likely be demonstrative with their friends, family and maybe even Twitter about you, and in that situation, one disgruntled customer morphs into twenty, forty, one hundred unhappy or even lost customers…

And not only that, it misses one of the most important things and brings me back to the original sentiment about the bittiness of complaints handling. If the very first step is missed and a complaint not logged, or logged incorrectly, then you or your board miss the oversight that it brings in your RCA. And missing that opportunity to right a systemic or repetitive issue could affect more customers. That first step Is vital.

Complaint 6

We know from speaking to businesses that this is an important and often overlooked part of the process in terms of making sure you’re taking the ‘reasonable steps’ required under the DISP rules, and ensuring you can spot a problem from becoming habitual and systemic. We’ve seen businesses collecting this data at the coal face and then finding that it disappears as it progresses up through the levels, so that by the time it reaches board level it doesn’t register or has lost its meaning because it’s been diluted as it passes up through the organisation.

Which is why, for us, the complaints process needs to be recognised and appreciated for what it is. It’s an opportunity to retain customers when they have spotted or experienced a problem or a mistake. It’s a simple way for you, as a business, to see if your systems, processes and staff are all pulling in the same direction and doing what they are meant to be doing.

Finally, and most importantly, it’s actually a way to prevent complaints, because once you spot that issue in your RCA and fix it, it ceases to cause further complaints. It shows the business has learned its lesson and you have the evidence that proves it to you, your customers and the FCA.

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Topics: complaints, regulation, FCA, DISP

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