Consumer Protection through Contact Centres

Building customer trust while driving compliance

“We care about you in these unprecedented times and we’re here to help.” Organizations have been bombarding consumers with messages like this throughout the COVID-19 pandemic. Customers and regulators are beginning to separate the marketing hype from tangible actions and commitments.

As the pandemic continues, Canadian regulatory bodies, including the Financial Consumer Agency of Canada (FCAC), are creating new and amended provisions to shift public policy toward strengthened supervision over financial product and service delivery in Canada.

Increasing regulatory pressure and reputational risk

The FCAC believes that banks promote trust and confidence in financial institutions when they interact with consumers in a fair, appropriate, and efficient way to help address their personal and financial needs. Losing customer’s trust can have a dramatic and quantifiable effect to organization’s financial well being and customer’s loyalty to the organization. In a recent Deloitte study, three global companies embroiled in scandal lost 20–56 percent of their market cap, relative to their peers, over a period of three months to two years, and fell behind the comparable industry index by 26–74 percent.

Canadian federal government, introduced the Financial Consumer Protection Framework (FCPF) under the supervision of FCAC, to enhance customer trust and confidence in banks, through heightened customer experience, and to promote an enterprise-wide customer centric culture. The new regulations will come into effect in April 2022, which necessitate material changes to people, process, data, and technology across lines of business, and functional groups at the Bank. These provisions require changes to existing Contact Centre policies and procedures, and the way agents interact with the customers. The complaints-handling requirements introduced as part of the FCPF impose tighter deadlines and more stringent record-keeping and reporting requirements.

The new requirements called for in the FCPF increase the need for banks to demonstrate fairness, appropriateness, and inclusiveness across all points of interaction. Those who do not have the processes, governance, and resources to comply with these new regulatory requirements will face financial and reputational risk.

“By demanding enhancements to complaint handling, legislators and regulators are expecting banks to generate greater trust and confidence in their abilities to fulfill promises to consumers.” -- Jay F. McMahan, Partner, Deloitte

Rise of vulnerable consumers

The COVID-19 pandemic has created challenges for many Canadian consumers, especially employees in the hardest-hit industries, who may face prolonged unemployment and economic hardship. Banks need to have meaningful interactions with, and not lose sight of, these vulnerable customers and take proactive measures to protect their interests.

The definition of a vulnerable customer is necessarily broad. It is easy to see how many customers may be considered temporarily vulnerable, especially during times of crisis like a pandemic. Banks need to review how they define vulnerable customers to ensure temporarily vulnerable clients are included and reflected in their contact centre procedures.

Contact centre leaders should be asking themselves:

  • Are our front-line employees trained and equipped to manage vulnerable customers in these times of economic distress?
  • Are we currently using customer data to proactively solve problems for our existing or potentially vulnerable customers?

Contact centres must pivot to meet shifting customer behaviour

To drive customer relationships and meet quality and performance expectations, contact centres need to implement enhanced complaint management protocols and adapt to shifting customer behaviours and rapidly changing virtual operating models. Contact centres need to evolve into “Experience Centres” by designing and reacting to customer interactions to meet or exceed customer expectations and, thus, increase customer satisfaction, loyalty and advocacy.

Contact centres have now become customers’ preferred channel to interact with organizations due to the pandemic, which has also created significant capacity challenges in the contact centres. Banks are experiencing an unprecedented increase in call volumes with limited capacity to manage the demand. This sudden increase in call volumes and reduced agent capacity had a significant impact on contact centre KPIs. The Average Handle Time (AHT) increased from three to six minutes to over 10 minutes1, which has increased customer wait times and complaints. The abandonment rate also increased with the increased hold times.

Banks should take the lead in customer protection

With the economic stress caused by the pandemic, the banking sector has a unique opportunity to increase trust and strengthen customer relationships. The disruption inflicted by COVID-19 prompted banks to digitize faster, rethink their branch strategy, and recognize the significance of contact centres as a preferred communication channel. Contact centres have transitioned from “the other channel” to “THE” channel.

The pandemic, coupled with the increased regulatory pressure provides banking leaders with an opportunity to take decisive, early action to ensure their service operations are resilient, stand out from the competition, and provide exceptional customer experiences.

Challenges will persist as recovery continues. Banks need to invest in contact centres to improve their capabilities to interact with the customer’s anchored on their financial interest, and provide an efficient experience with handling complaints and feedback etc. Banks can strengthen contact centres by implementing sophisticated customer analytics and innovative technologies to transform the customer experience. In addition, promoting a strong workplace culture within contact centres will attract and retain new talent that will be instrumental in spurring innovation.

The new workforce reality

The rise of COVID-19 has prompted many contact centres to embrace remote working amid stay-at-home orders and concern for employees’ health and safety. Compounded by the increasingly contact-less world driving up call volumes, this rapid transition to remote work exposed critical shortcomings in older technology and business continuity plans. With remote working here to stay for the foreseeable future, contact centre leaders need to internalize current challenges and apply those lessons to emerge stronger from the pandemic. Leaders need to rethink many facets of their contact centre operations beyond agent location to include strategy and business continuity plans, channel experiences, and technology.

Mobilize call centres for action

Bank and contact centre leaders need to take decisive action and respond quickly to the systemic challenges created by today’s extraordinary realities. Now is the time for banks to enhance their human touch by evolving contact centres to experience centres with a relentless focus on customer centricity.

Focus on understanding your customers’ needs

Customer experience is overtaking price and product as a key differentiator as personalized, real-time attention and quick issue resolution become critical to strengthening customer trust and loyalty. As per a recent Salesforce report, 80 percent of customers reported that the experience a company provides is as important as its products and services, with 59 percent saying that the pandemic has raised their expectations of customer service. Banks can play a pivotal role in providing aid, comfort, and security to vulnerable customers. Banks can use new technologies to identify potential vulnerability with novel techniques, such as using customer data for automated cash flow analysis. Once identified, banks can proactively reach out and help customers by offering advice and forbearance options.

Harnessing customer information from contact centres has always been a goal, but it will be even more valuable as markets reopen. Leveraging capabilities such as voice analytics, Natural Language Processing (NLP), and sentiment analysis will provide organizations crucial insights into customer and agent interactions to spot trends, identify risks in products and campaigns, amplify successful marketing efforts, and improve customer experience. These capabilities will also provide a 360-degree customer view that will allow agents to offer convenient, clear, and consistent service by focussing on customer interactions rather than navigating through back-end systems.

Contact centres must also embed the culture of fair and appropriate sales conduct among their agents. Training policies and procedures must prohibit agents from pressuring, coercing, or taking advantage of customers during interactions. Agents must only offer appropriate products based on customers’ financial and personal circumstances, needs, and objectives.

Leverage digitally-enabled and intelligent services

Technology will be the critical enabler. Artificial Intelligence (AI) powered systems can route only important calls to human agents, while digital assistants can provide viable options based on customer interactions. Using chatbots to handle simple queries would result in faster issue resolution, which would satisfy customers by lowering servicing costs.

AI-enabled voice analytics, like Deloitte TrueVoice, delivers insights to help better understand how customers feel, proactively identifying vulnerable customers, and identifying opportunities for continuous improvement by monitoring customer sentiments in real time. TrueVoice can help predict potential complaints, identify call reasons, analyse complaints data, and measure agent effectiveness to inform customer experience improvements, build trust, and protect vulnerable customers.

“Contact Centres have become a vital channel for organizations to strengthen customer relationships. Leaders need to take decisive action to ensure their service organizations are resilient.” – Derek Fitzgerald, Contact Centre Leader, Deloitte

Adopt new models to facilitate virtualization and a hybrid workforce

Innovative technologies, strategic resource redeployment, and increased training that enable and empower contact centres are more important than ever and should be fast-tracked. While implementing new technologies, banks must concurrently manage the security risks of technology-enabled remote work

Strengthen customer relationships

As social distancing protocols evolve and society moves to the ‘next normal,’ customers will reflect on how their bank addressed their needs and guided them during this period of economic stress.

The way forward for banks is clear. Bank leaders must combine technology with novel ways to deploy resources and enhance training to respond quickly and decisively to today’s systemic changes. In the near term, customer experience will surpass fees and products as critical differentiators. Personalized, real-time attention and quick issue resolution will be essential to customer retention.

The bottom line

Bank leaders must consider the following critical actions as they navigate the path forward:

  • Establish complaint-handling protocols in compliance with new FCPC regulations.
  • Take proactive, meaningful measures to protect vulnerable customers.
  • Train front-line employees to manage the unique needs of vulnerable customers.
  • Use customer data to gain insights into customer interactions to spot trends, identify risks, and improve the customer experience.
  • Take decisive, early action to enhance the human touch and transform the customer experience with sophisticated customer analytics and innovative technologies.
  • Embrace the new remote work reality and provide contact centre agents with the right tools and training to interact with customers in a fair and appropriate way that fosters customer trust.

People will remember how banks treated their customers during this economic crisis. Regulators will be watching to ensure customers receive fair outcomes. With the clock ticking, banks must transform their operational effectiveness to comply with the FCPF protocols by April 2022. Those who lead during this critical period will be rewarded with trust, loyalty, and life-long customer relationships.

1Deloitte, The Chemistry of Trust, Part 1: The Future of Trust, March 2020.
2GEP, “Impact of COVID-19 on Contact Centers and Measures Taken,” October 29, 2020,
3Salesforce State of Service Report: 4th edition

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