The recent introduction of new GDPR regulations has impacted on nearly all of us. Who hasn’t been deluged with emails from every company they have ever interacted with online? Wading through this plethora of messages from companies desperate not to fall foul of the new regulations, I was reminded of a similar frenzy in the credit industry four years ago when the Financial Conduct Authority (FCA) took over from the Financial Services Authority and the Office of Fair Trading.
Treating Customers Fairly (TCF) was top of the agenda and for some it was the first time they had come across this specific phrase – despite the fact that it has been in existence since 2006. Principle six of the 11 FCA principles states clearly and simply: “A firm must pay due regard to the interests of its customers and treat them fairly.”
Material produced by the FCA outlines the regulation and gives examples of acceptable and unacceptable practices but stops short of giving measurable indicators. The overriding message being that customers’ interests must be at the heart of how firms do business.
So how do we measure our performance in relation to the fair treatment of our customers and prove that TCF is at the heart of how we run our businesses?
Having low levels of customer complaints might seem like a solid indicator of good TCF practices in a firm. Consider, however, how few complaints there were about PPI before the mis-selling scandal came to light.
Simply having a well-crafted TCF Policy is not enough. TCF is an attitude – a mind-set. It is cultural and not simply a process that can be evaluated and measured. It has to start with visible and audible support from the top and be cascaded throughout the organisation. It needs to be a standing item on the agenda for all teams, not least the senior management and board of directors.
Independent verification of what we do on a day-to-day basis is essential. Accompanied visits is widely used but simply shows that people know how to behave when they are being watched. A better method is “Secret Shopper” exercises. This gives an insight into how people are actually behaving when they interact with customers. Having used this for over 10 years at Anglia, it has now become a part of our culture.
Although GDPR has been a major focus in recent months, I suspect it will soon become “business as usual’ as part of normal processes and procedures that can be easily controlled and measured. The same cannot and must not be said for TCF. Not only is TCF good for customers, it’s also good for business. A customer-focused business stands in the shoes of its customers; it listens, plans and adapts to meet the ever-changing needs of a market. And if you’re not getting that right, chances are you won’t be standing at all in the not too distant future.
Nigel Dann, Head of Quality Assurance, Anglia UK