What can you buy for 2 million quid?

Silent calls are back in the news with what used to be the DTI (morphing through BERR to it's current name "The Department of Business, Inovation and Skills" - come back Prince, all is forgiven...) publishing plans to increase the maximum level of fines from the current £50k to a maximum of 2 million pounds. (Click here for press release).

If you can cast your mind back to last year's action against Barclaycard, Ofcom's chief Ed Richards said at the time "Had we not been limited by the statutory maximum, we would have imposed a larger financial penalty to reflect this misuse". Well, it looks like he may get it.

The plans to consult on the level of fines were set out in the controversial "Digital Britain" report published last June where I for one completely failed to notice the text in paragraph 50 on page 200 saying:

"A further growing area of concern for the Government is the disparity between the various penalties that Ofcom can impose under the Communications Act 2003 in relation to actions causing consumer harm. For example, where Ofcom has found breaches of the Broadcasting Code regarding phone-in scandals and the consumer harm they caused, it has been able to impose fines of well over £1m. Conversely, where Ofcom has found serious breaches of its rules on persistent misuse of a network or service, in particular in relation to extremely high numbers of silent calls (where the people receiving the calls had no method of knowing who had made them, with the resulting consumer harm), the statutory ceiling as currently set only allows Ofcom to fine up to £50,000. It seems to the Government that the discrepancy between these levels of fine is no longer sustainable or desirable. The Government will therefore consult on the penalties that Ofcom is able to impose for contraventions of the Communications Act 2003 and, in particular, the level of the fine it can impose in relation to persistent misuse cases."

(Download full report here (PDF))

So what does this mean?

It has long been argued that the level of the fine has not been the deterrent so much as the reputational damage to your brand. That's why Ofcom have always made it clear they'll go after the originating brand, rather than any outsourced contact centre that happens to actually make the calls. Loosing a bank only £50k in the last year would probably not have registed on the level of petty cash, given what's been going on, but £2m is enough to make even the most profilgate of spenders stop and think.

So, if the threat of 2 million quid fine is enough to sharpen most organisations' focus on managing their dialler properly, what will and what should happen? Well for my tuppenceworth:

(1) Answer Machine Detection (AMD) - we need to get heads out of sand on this one. AMD causes silent calls (fact). Silent calls cause nuisance and anxiety (fact). I'm sorry, but I don't understand why this is still being debated.

(2) Some further clarification on calculating silent call rates when AMD is and isn't being used would be helpful. The DMA has put together some excellent work on this (which I've been a part) and it would be helpful to have that endorsed.

(3) Everybody with an interest in this field should respond to the consultation. My response will be that I will welcome the increased level of fines but call for the publication of the AMD research carried out by Ofcom earlier in the year, and ask that Ofcom confirm publically and in print those clarifications on the silent calls calculations that they've made in public meetings organised by the TPS and others.

Meanwhile I'm wondering, what would I do with £2,000,000?

The Micro Men and the Connected Kids

My past and my present collided in a happily nostalgic way his week. Firstly, I watched “Micro Men” on the telly. It was the tale of the rivalry between the two Cambridge-based home-computer giants of the early 1980s - Acorn and Sinclair. Geeks back then (of whom I was one) tended to wear their allegiances to each of those brands on their selves and I was an out-and-out Acorn man. Indeed, my first gig in the computing world was with a company that sold networking software and hard discs for the BBC Micro - the entire network operating system had to fit into less memory than the average logo on a website does now...

The real reminder was just how new computers were back then. When I first arrived at my secondary school, it owned one computer (an RML 380Z in case you care). You could book 15 minute sessions on it and write programs in a variety of languages, but frankly only a small number of us bothered. The computer lab didn’t appear until I was doing my o-levels and when I left there was still no such thing as computer studies - computers were only used to support teaching in maths and some science classes.

Fast-forward 25 years and I was at parent’s evening for my 4 year old. She’s been 4 for 3 months, and at school for 4 weeks. It is an ordinary village school (not some kind of NASA-sponsored academy) and I was told how she enjoyed ICT (that’s computers for the uninitiated). ICT! She’s 4! I was changing her nappies less than 20 months ago - now she’s being tought how to use Windows!

When she leaves school she’ll be computer literate in systems that now have not even been imagined. She will be familiar with, and probably own, devices that are networked she will communicate and collaborate with her friends and peers in ways that will probably have me harumphing about like a Luddite, bemoaning this “new-fangled technology”. Douglas Adams has a great quote about technology which I wholeheartedly endorse....

“I’ve come up with a set of rules that describe our reactions to technologies:

• Anything that is in the world when you’re born is normal and ordinary and is just a natural part of the way the world works.
• Anything that’s invented between when you’re fifteen and thirty-five is new and exciting and revolutionary, and you can probably get a career in it.
• Anything invented after you’re thirty-five is against the natural order of things.”

So what’s this got to do with the price of fish? Well, another timely collision into my week was reading in Saturday’s Guardian about the amount of time teenagers and young adults spend on social networking sites (stuff that will seem as dated as the ZX81 to my younger daughter when she’s 18). The generation emerging from education into the workplace thinks, communicates, collaborates in ways their forebears simply don’t. They’re emerging into a world in which economic uncertainty will encourage greater scrutiny of their purchases and brand loyalties than their parents (at least I bleedin’ hope so - otherwise, we will have learned nothing from the last 18 months). Being so at home in their connected world, they will be expecting to use the same tools to communicate with retailers and service providers and local authorities and educators as they do with their peers. That was the point of a paper I gave, together with Peter Carragher of the essentiagroup, at the CCF conference last month. We looked at the internet and communication usage of different age groups and discussed how this needs to impact the way we run customer contact in the very near future. It was good fun to research and put together, & I’d like to hear what others thing. If you’d like a copy of the material, drop me an email via contact@callmedia.co.uk or post a comment on this blog entry.

Although terrifyingly old fogyish and rather unfashionably the wrong side of Douglas Adam’s quote, the geek in me is fascinated by what will come next in the world of communication. Just as long as I’m not expected to use it....

Callmedia User Forum

Thanks to all of our customers, partners and friends who came to the Callmedia User Forum at the CC Expo this week - it was good to catch up. We had a lot of fun with our version 5 preview and the Facebook integration and look forward to working on some live projects soon.

We're currently thinking about next year's event and will soon be consulting amongst our user community about venue, time of year, content etc, but if you've got any feedback in the mean time - whether or not you attended this year - we'd love to hear from you.

Expo and the Callmedia Forum are just around the corner!

Firstly, apologies for the absence. I had got quite into this blogging lark but somehow managed to get out of the habit with some aplomb...

However, I have news. Call Centre Expo 2009 is round the corner and as usual Callmedia is there in force. We’re running our 3^rd annual User Forum in conjunction with our sponsorship of the Call Centre Focus Conference. If you’re a Callmedia customer you should already have had an invite. If not then many apologies – it’s not too late to register – you can do it here.

During the first morning, we will be introducing Callmedia 5.0 including our new Expert Contact engine, and also demonstrating our integration with Facebook. All exciting stuff (see the CCF Coverage)

If you’re coming on the Wednesday then we still have our hospitality suite up on the Conference floor (go up the big flight of stairs in the entrance hall to the NEC and follow the signs) and I may see you at another couple of events I’m speaking at: The TPS Forum in the morning, and I’ll be co-presenting with Peter Caragher of the essentiagroup on the subject of new channels for communicating with younger people – we’ve called it “The A to Z of communicating with Generations X, Y and beyond” – I’ll be talking about the technology and Peter will be sharing his real-world experience of using channels such as Video Chat, chat rooms and SMS to reach out to young people.

Failing that, I hope to catch up with you at the dinner on Tuesday evening where we’re one of the award sponsors. Given that I’m talking about predictive dialling call calculations at 9 o’clock the next morning, I’m going to try very hard to be on my best behaviour.....

I hope to see you next week.

At the end of the day....

Sorry for the interruption to your service - just too much going on to get an update on here.

The afternoon session started off with a view from Claudia from CCF magazine on her view of outbound. CCF have been a champion of good practice in outbound contact centres for ages, so it was good to hear her point of view. It was also good to hear her mobile go off while she was on the platform (pesky outbound callers!)

Next up, John Price and Elaine Lee from the DMA’s Contact Centre Council gave an update on activity relating to the Telemarketing Manifesto. This is an initiative launched last year designed to encourage sustainablity and good practice in outbound for the four key stakeholders: Consumers, Companies, Regulators and Agents. (It’s great to see the emphasis on the agents for once. As Elaine pointed out, they are the ones that take the rejection, that make the great calls, that carry the responsibility for the brand). Elaine also covered the impending arrival of the DMA’s Telemarketing Best Practice Guidelines, to be launched soon (when they’ve got through the DMA’s Governance procedures).

Steve Smith of Brookmead Consulting then took us through some research from the TPS Report I mentioned earlier. This report was a pretty extensive piece of work covering a number of areas: The Consumer Experience of unwelcome calls, the impact of regulation on the industry, the regulatory process itself, the view from the US and a personal comment from Simon Roncoroni. Steve’s research, some hot off the press from Mori, gave some very interesting insights into the thoughts of consumers receiving outbound calls, as well as some strong comment from the industy on the regulatory process. More interesting was the industry futures section, where it is clear that genuine cold calling is really in decline and that mobile marketing, integrated web response and much more targeted ofers are the order of the day.

In the afternoon Jasminder from Ofcom gave some clarification around the Ofcom statement issued last September. I’ll write a separate post on this when I get a chance, but the upshot was some confirmation of the definitions relating to the abandoned call formula. It is quite technical, but very important to anybody running a dialler so watch out for my post tomorrow on the subject.

Finally George Kidd from the Direct Marketing Commission (and formerly PhonePayPlus and the Cabinet Office) gave an interesting talk about how to “love your regulator”, exploring themes around the increased longevity, sustainability and profitability that regulation can bring to markets.

So what conclusions can I draw from today?

Well there were two key themes, I think. Firstly, the ever present regulatory theme. There is work to be done by all operators on making sure they understand the September 2008 Ofcom statement and its implications for their businesses. For those using Answer Machine Detection (AMD), the implications are really quite significant in that they have to come up with a robust understanding of the number of silent calls their AMD makes and factor that into their dialler management to include it in their abandoned call rate. In many (if not most) circumstances, AMD is simply not a viable technology, certainly not where it is used all the time. For those not using AMD, exporing Ofcom’s clarification will be important. As I said, I’ll post on that issue tomorrow, but the DMA will work to get a statement that Ofcom can endorse on its website soon.

Secondly, the theme of best practice and on the importance of respecting consumers came through loud and clear. Good targeting is clearly the watchword (or maybe even watchwords...) for successful campaigns in the future rather than the high volume “Spray & Pray” activity we still sometimes see today.

This live blogging lark also turned out not quite to be as live as I’d hoped. Perhaps I’d better look into Twitter....

Lunchtime

Bit busy at lunch to write much, but a fascinating morning. Particularly the session by Simon Roncoroni on his personal vision of outbound.

The presentation on the use of automated messages by Steve Smith of Brookmead Consulting created a very interesting debate on the use of this technology. It's against the law for it to be used for marketing purposes, but the main worry is that if volumes increase it devalues the whole currency of th telephone a a medium.

Session starting - got to go.

Sustainable Future of Telemarketing

Well, I'm here. Safely ensconced at the Wellcome Collection, awaiting the arriva of the coffee trolley (due to a mixup with a timetable and my diary and the clock changing, I've broken the habit of the last 40 years and turned up unfashionably early).

The conference agenda is full an diverse - from the arcane technicalities of the inner workings of diallers to the future of the industry via some research, regulation and a debate on the merits of automated messages.

It kicks of with a session on AMD. This is the absurdly technical bit which was originally going to be part of a separate lab session. I pitty the poor delegates who are going to get me and Roland (the excellent Roland Smith from JAM IP) giving them their first dose of double maths for many a year...

Then the always excellent Simon Roncoroni will be giving his personal view on the future of telemarketing - made all the more credible and relevant by the fact that he's also responsible for such a lot of its past.

Then there's a panel debate on automated messages chaired by the incomparable Claudia Hathway of CCF magazine.

After lunch, Steve Smith of Brookmead Consulting will be launching the publication of a report produced for the TPS last year on the state of telemarketing (I ought to declare an interst - I wrote some if it) .

Then the DMA Contact Centre Council Chair John Price, aided and abetted by Elaine Lee qill launch the Best Practice Guidelines developed by the DMA Council.

Then after afternoon tea and cake, Jasminder Oberoi from Ofcom will issue some clarification around the Ofcom guidelines published in September last year and George Kidd from the DM Commission will round the day off with a talk on the profitability of compliance.

I will log on a lunchtime with a review of the morning. Meanwhile, forget the end of year / end of quarter / last day of winter / eve of pranks / last day in London before the G20 and either enjoy the session or do some work.

Speak later.