On 13th July I told you that I’d got in contact with the Information Commissioners Office about No Agent Available Calls.

The specific question put to the ICO was a follows:

“In principle, is it legal for an organisation, which was making a marketing call, to play a called individual a recorded message which is not a marketing message?

“It is not clear from reading the regulations that this is acceptable, as the initial purpose of the telephone call was for marketing purposes even though the resultant message was not.”

The response received:

“Regulation 19 relates to automated calls, i.e where “non live” direct marketing communications are transmitted following an automatically initiated sequence of calls. The situation you describe refers to non live communications automatically transmitted, which are not direct marketing in nature. As such regulation 19 would not apply.

“I appreciate your comments that the purpose of the call would be to facilitate a live direct marketing communication (regulation 21), but as no direct marketing material is actually communicated the call would not fall under the regulations, and therefore not under the ICO’s remit.”

Therefore, as long as the message that is played is carefully worded to ensure that it contains no marketing information, organisations need not be worried about using the NAA message.

It’s now time for us all to start doing this - although I appreciate that understanding what can and can’t be done is a little daunting for many call centres. For this reason I’ve has started to put together a code of practice for removing silent calls from your organisation. This can be found here.

Please get in contact if you would like further information about using the NAA message in your call centre.

I’ve just been speaking to David Hickson (see recent articles) and he pointed something out about the BT privacy at home thing that could be interesting. Please understand that neither I nor David are suggesting that anything like this is actually happening; this is just theoretical.

One of the things that I highlighted was that BT are obviously concerned about the number of consumers who are moving to alternative providers for their call traffic. This is driven by the fact that it can be significantly cheaper to buy your minutes from elsewhere.

Most CPS/LCR companies rely on telemarketing to contact consumers and let them know that they’re being ripped off by BT.

How can BT stop it’s competitors from helping consumers to save them money? Get them all to sign up to the TPS list so they can’t call them.

That’s just one (strongly anti-BT) point of view that you could take. As I said before, I’m not suggesting for a minute that this is the reason that BT are doing this. I’m sure they’ve just got the interest of the consumers at heart.

Regards,
db

I’ve no need to tell you that this industry has concerns about the number of TPS registrations.

It’s obviously with concern that I read about BT (who aren’t afraid of making a few sales calls themselves) who are promoting a new service called Privacy at home. This is sold to consumers as a way of stopping cold calls. It gives the consumer free caller display and automatically subscribes them to the TPS list.

I’ve a few issues with this - mainly because it’s a crooked as a nine bob note.

One of the conditions is that the consumer continues to make some calls using the BT network. This is aimed at getting call traffic back from the CPS/LCR providers that offer a much better deal than BT.

This in itself I don’t like - BT are using the current concern over telemarketing as a way to market something unrelated.

Secondly (and this is the really dodgy one), regarding TPS registration BT say:
“Of course, we’d like you to give your consent for BT to contact you after registration with news of genuine savings and improvements to our services.”

Yes - although they subscribe you to the TPS, BT are still going to make telemarketing calls to you. In fact; you’re likely to receive more calls then before.

Regards,
db

Terrorism is at the forefront of everyones minds at present.

Last Thursday around 50 people were killed. Whilst this was a tragic event, and my thoughts go out to the families that have lost loved ones, the truth is that London escaped lightly. Remember that over 400 firemen alone were killed on 9/11 - and the death toll in Madrid was over 200. More lives were lost at Lockerbie, but the location and nature of the London attack was too familiar for it to not make us stop and think.

This served as a strong reminder that the open nature of our society makes us an easy target. It’s the price we have to pay for our freedom.

I was interested to hear that there was a security clamp down at Nuclear power stations immediately after the attacks on Thursday. This is on the assumption that these may prove tempting targets because of the panic and destruction that would be caused by one of these power stations being destroyed.

Truthfully, they’re safe. Thursday proved that the likely targets are ones that are easy to get into, have a large amount of people in a small space and would cause maximum disruption after the attack.

With that list of criterea in mind, how many people think we should seriously consider the security in our call centres?

Regards,
db

I thought I’d brighten your afternoon with a return to one of my favourite subjects: silent calls.

Firstly, I’m going to start calling them something else. I’m going to call them “No Agent Available Calls” - for a reason I’m hoping to get to in a minute.

OFCOM issue a notification to MKD holdings under section 128 of the Communications Act towards the end of April. They gave them “one final chance” to sort things out before OFCOM considered further action. Whilst this stopped short of making (as I would have liked) an example of someone who was at one time obviously causing a nusiance, it must be noted that MKD holdings have cleaned up their act and this latest investigation was the result of a misunderstand around how to report the number of NAAC’s made. When I spoke to OFCOM yesterday, they confirmed that MKD have returned the first tranche of information required under the notification and the results were satisfactory.

This starts us on a long journey to clarify exactly what is and isn’t allowed. The act itself is not clear and does not specifically mention silent calls or NAAC’s. However, we now know that OFCOM do consider silent calls to be a nusiance and what this industry needs to know is what level of calls are acceptable. OFCOM won’t quantify - citing that there’s many other factors to be taken into consideration, not only the number of calls made. I don’t feel this is a suitable answer though. Can you imagine if we were told that there was a speed limit but we weren’t going to be told what it was?

What is relevant is that with MKD they have insisted that the level of silent calls on each individual line must be under 5% of the total calls made. In thoery, this goes some way to set a rule for us to work by.

A lovely chap called David Hickson, who emails me regularly, seems to suggest that no silent calls are acceptable. Intially this seems a ridculous point of view: I strongly believe that this industry needs to be able to maintain the use of dialling equipment in order to maintain and improve staff productivity levels. Without this, we’ll be taking a step backwards.

However, this may be possible - and that is if we make NAAC’s, not silent calls.

This is an idea that has been in circulation for a very long time. The plan is to play consumers a message (rather than silence) if it turns out that there is no agent available to take the call. This way we don’t get little old ladies that are concerned about the calls, and the consumer is fully aware where the call has come from.

As an industry (lead by the DMA) we’ve always been concerned about this. There’s another piece of relevant legislation: The privacy and electronic communications regulations, this time policed by the Office of the Information Commissioner. This says that it’s illegal to call people with automated called equipment and then play them a message for marketing purposes.

The big question centre’s around whether it would be acceptable to play someone a recorded message which did not contain marketing information, if the original purpose of the call was for marketing purposes. Some people tell me that this is obviously allowed, but reading the regs myself I don’t believe it’s that clear cut.

So I spoke to the OIC about it and they agree it’s OK in principle, but they start to get nervous when you ask them to put it in wrting. I’ve now written to them with some very specific text and hopefully soon the OIC will agree a standard message that could be used. Then we’ll be able to get OFCOM to agree that 5% of NAAC’s are acceptable.

Then we won’t have scared old ladies, and people who don’t want to receive marketing calls can continue to register with TPS just like did before. The big question would then be: What are BBC breakfast going to moan about without the telemarketing industry as a target?

It’s been a long week.

Winning the Olympics. Terrorist attacks in London.

I can honestly say that this is the biggest rollercoaster I’ve ever experienced. These two events were probably the happiest and the saddest that London has seen in last 50 years.

But they both made me proud to be British, and proud to be a Londoner.

I felt immense pride as Lord Coe and his team celebrated the Olympic result. I also felt immense pride at the way that the emergency services calmly and selflessly carried out their jobs on Thursday morning.

What’s my point? I don’t really think I’ve got one.

How am I going to relate this to Customer Service? I’m not.

Britain Rocks.

CSM is a brand new show organised by CMP (the same people who publish Call Centre Focus and bring us the Call Centre Expo).

Whilst not being specifically a call centre show, it’s relevant to what we do and therefore had a sprinkling of call centre exhibitors. By far the most popular technology on site was CRM, although it’s interesting how CRM seems to be splitting into different directions. On one had we’ve got systems that are really just call centre datacapture screens, and on the other we’ve got some quite aggressive sales workflow packages.

The first thing I noticed upon driving into the car park is that the cost of parking has now risen to £7. I don’t really understand what the NEC think they’re doing to deserve this amount of money for lending us their tarmac, but I suppose I’ll just have to put up with it.

I was too busy chatting to make it to any of the keynote sessions, but the speakers looked interesting.

A few things that caught my attention:
MX Digital
I had a really interesting chat with Paul Moorman about how it’s important to ensure that your hosted service provider cuts the mustard. It’s all too easy for someone to host your call centre system from their back room - and you need to ensure that something as business critical as your call centre is supported with correct voice and data links in a secure, fire protected location on servers that are correctly maintained and patched.

Right now
Rightnow provide an on-demand CRM package (which I plan to discuss in CCF this month). What’s really interesting is that they are bundled with a speech service. This means that the CRM is in a position to provide complex voice self-service from information captured by the CRM system.

Talisma
Talisma are placing their CRM as a multi-channel solution, providing a level of workflow management for enquiries into the contact centre. I expect that they’ll look to bundle this with an ACD in the near future to provide a complete out of the box call centre system. When I mention this to the guy on the stand he said that there were no plans at the moment, but did hint that Talisma were owned by the same VC group as Concerto. Could be one to watch.

DPS direct mail
Have some software which, although starting out as a data processing tool, is starting to look little like CRM. This allows data from many sources to trigger a customer contact through any channel (Such as inbound mail resulting in a record ending up in an outbound call queue). I look forward to learning more about this in the future.

Reach2Mobile
These guys have just started selling text message marketing software. Unlike most systems till now, these send messages directly from a GSM modem (rather than over the ‘net to a gateway). Purchasing pre-paid SIMs is a great way to get cheap texts, and the software is well put together. It’s targeted towards getting mobile numbers to opt-in for marketing and could find some great uses soon.

I believe this holds potential for a “call me” text from mobile although the MD told me that they’ve no immediate plans to do this.

ContactCentreWorld
Were there in full force - and kept hassling me everytime I walked past the stand. Frankly, it’s as annoying as when I have to remove spam messages from the forum about how we should visit their website.

Next stop, Call Centre Expo.

Regards,
db