Review of Consumer Contact Centre Activities and Processes (Framework) - March, 2008

A Memorandum of Understanding, dated October 24, 2001, with Canada Deposit Insurance Corporation sets out provisions for FCAC's Consumer Contact Centre. The MOU outlines FCAC's expectations of CDIC's management responsibilities, performance standards, and information needed by FCAC for its analysis and public reporting purposes. The information gathered is used by FCAC's Compliance branch and Consumer Education division in trend analysis, identification of possible new consumer programs or services, and assessment of how well the existing programs or services are working.

Within FCAC, the Manager, Consumer Services, is responsible for the management and oversight of centre's activities and MOU arrangements. Within CDIC, the Consumer Contact Centre Supervisor is responsible for administering the MOU, liaising with FCAC, and supervising the Inquiries Officers on a day-to-day basis. The job descriptions and competency profiles of the Supervisor and the Inquiries Officers define the knowledge levels, responsibilities and key activities related to FCAC inquiries.

Although ongoing administrative, management and support activities are understood by FCAC and CDIC CCC, and are broadly set out in the MOU, they are not set out in sufficient detail to provide for effective oversight and monitoring of CCC operations. FCAC is reviewing information needs and performance standards of the centre, and formalizing operations and management arrangements between FCAC and CDIC. FCAC indicated that the MOU is to be revised / updated during 2008/09.

The MOU should be strengthened with annexes by specifying comprehensive information and performance standards expectations; management, support and administrative arrangements; introduction of new programs; Inquiries Officers competency and training expectations. The annexes should be confirmed annually to ensure their currency and relevancy.

The objective of the Consumer Contact Centre, as described in FCAC's Activity Business Profile, is “The CCC provides consumers with a comprehensive personal response to their financial related questions. The CCC will also direct consumers to the right place to get their problem resolved, and will explain the complaint process, what information consumers need to have, what to expect and what to do next.” The Consumer Contact Centre objective is consistent with strategic outcomes set out in FCAC's 2007-09 Business Plan and the FCAC Act.

The 2007-09 FCAC Business Plan contains service commitments to consumers: Average wait time for a consumer on the telephone before an agent takes the call: 30 seconds or less, Call abandonment rate: 5% or less and Call completed at first point of contact: 90% of calls. The 2006-07 Program and Performance Management Evaluation Report includes other performance measures: Average wait time for consumers who contacted the CCC: 28 seconds and Time taken to close a file related to a telephone call received by the CCC: 96% closed within one day. In addition, the “FCAC – Consumer Services - Policy and procedures - correspondence and telephone contacts” document sets out performance standards as: 90% of calls to be completed at first point of contact, same day for CCC to reply to calls during business hours; and next day for CCC to call back clients who have left messages after hours

The Consumer Contact Centre information is used extensively in monitoring issues and possible compliance and emerging concerns. FCAC has undertaken an update of information and performance standards requirements taking advantage of the enhanced capability of the new Bell ICE system.

The objective setting for the Consumer Contact Centre is appropriate.

The objective of the Consumer Contact Centre, as described in FCAC's Activity Business Profile, is “The CCC provides consumers with a comprehensive personal response to their financial related questions. The CCC will also direct consumers to the right place to get their problem resolved, and will explain the complaint process, what information consumers need to have, what to expect and what to do next.” The Consumer Contact Centre objective is consistent with strategic outcomes set out in FCAC's 2007-09 Business Plan and the FCAC Act.

The 2007-09 FCAC Business Plan contains service commitments to consumers: Average wait time for a consumer on the telephone before an agent takes the call: 30 seconds or less, Call abandonment rate: 5% or less and Call completed at first point of contact: 90% of calls. The 2006-07 Program and Performance Management Evaluation Report includes other performance measures: Average wait time for consumers who contacted the CCC: 28 seconds and Time taken to close a file related to a telephone call received by the CCC: 96% closed within one day. In addition, the “FCAC – Consumer Services - Policy and procedures - correspondence and telephone contacts” document sets out performance standards as: 90% of calls to be completed at first point of contact, same day for CCC to reply to calls during business hours; and next day for CCC to call back clients who have left messages after hours

The Consumer Contact Centre information is used extensively in monitoring issues and possible compliance and emerging concerns. FCAC has undertaken an update of information and performance standards requirements taking advantage of the enhanced capability of the new Bell ICE system.

The objective setting for the Consumer Contact Centre is appropriate.

Job descriptions exist for the Consumer Contact Centre Supervisor and Inquiries Officers. FCAC's Consumer Contact Centre Performance Review forms include competency profiles related to these positions. A new Inquiries Officer receives training on the relevant legislation / regulations as well guidance on WebCIMS, the consumer call information database. On the final day of training, the Officer take calls and make WebCIMS entries under the supervision of an experienced Officer until the new recruit feels comfortable enough to work on their own.

Inquiries Officers receive training on scenario script guidance. They indicated that this was the first use of a comprehensive guide. The Officers indicated that additional training needs are identified promptly by FCAC and training is provided. Officers indicated that CDIC provided other training in areas such as second language, computer skills, business writing, and other professional development sessions.

Inquiries Officers' training is being formalized including scenario script guidance, classification codes, opening and close call script, and introduction of new programs or services. FCAC is developing a 2008/09 training program for on-the-job training / briefings as well scheduled training sessions.

The MOU would benefit, through an annex, by specifying Consumer Contact Centre Supervisor and Inquiries Officers competency and training expectations.

FCAC's Business Plan identifies and assesses key risks facing the Agency and outlines the Agency's mitigating strategies. Risks that may impact the Consumer Contact Centre services are specifically identified and assessed. A risk management report is prepared for each risk, including a risk description, probability and impact scores, mitigating strategies and a residual risk rating. Cautionary risk ratings and mitigation strategies are reviewed annually by management and the Audit Committee. Risk documentation is updated as appropriate.

Senior management regularly reviews the Consumer Contact Centre performance. Any issues are directly assigned to the FCAC manager responsible for the centre for resolution. For example, the mystery call exercise highlighted the need for an improved Consumer Contact Centre to track and report on the centre's performance in more detail and the need for drop down guidance on classification of consumer calls. As a result, a manager was assigned to the centre to implement an improvement plan. In addition, a new Bell ICE system is replacing the old system.

FCAC Business Continuity Plans incorporate Consumer Contact Centre services and specific FCAC staff are assigned to support recovery of the centre.

The risk management processes and activities are appropriate.

Roles and Responsibilities

Job descriptions and competency profiles set out the competencies, knowledge levels, responsibilities and key activities of the Consumer Contact Centre Supervisor and Inquiries Officer positions. The job descriptions and competency profiles are appropriate and complete reflecting their respective responsibilities.

Management responsible for oversight and monitoring of the Consumer Contact Centre changed several times in the last year or so. As such there was some inconsistency in support and guidance to Inquires Officers, in particular, access to FCAC staff in late afternoons and evenings as Consumer Contact Centre hours are outside of FCAC office hours. With the introduction of comprehensive scenario script guidance and increased training, Inquires Officers are more comfortable with handling calls on their own.

The role and responsibilities between CDIC's Consumer Contact Centre Supervisor and FCAC management has been clarified and ongoing communications has been strengthened.

Information / analysis requirements and performance reporting

The MOU broadly sets out the nature of information to be captured by the Consumer Contact Centre and WebCIMS. The consumer information is then used for analysis and public reporting purposes. The volumes and nature of inquires and complaints are made available, in chart and table format, on FCAC external internet site and included in FCAC's annual report.

The FCAC Business Plan, Program and Performance Management Evaluation Report, and other performance documentation provided by FCAC were reviewed to determine whether Consumer Contact Centre performance measures have been established, defined, documented and communicated. The documents set out performance standards such as: Average wait time for a consumer on the telephone before an agent takes the call: 30 seconds or less; Call abandonment rate: 5% or less; Call completed at first point of contact: 90% of calls.

To date, the information and reporting has been constrained by the Consumer Contact Centre system's capabilities in capturing detailed data on Consumer Contact Centre operations and performance. Management is currently updating information and performance requirements, taking advantage of the capabilities of the new Bell ICE system. In addition, system tracking of consumer calls will assist FCAC in adjusting hours of operations and staffing for peak volume hours.

FCAC's WebCIMS database consumer information is routinely reviewed by the Consumer Education and Compliant branches as to the completeness and the classification of the information. The Inquiries Officers are immediately advised on any changes needed.

In addition, the Consumer Contact Centre's performance is assessed through ‘call monitoring' by the centre's Supervisor, periodic mystery calls and conducting a customer satisfaction (call back) survey. With the Bell ICE system, FCAC is considering an electronic survey as a possible alternative to the customer call back survey.

The existing information and performance reporting is reliable but limited due the capability of the current Consumer Contact Centre system. The new Bell ICE system will be able to provide significantly improved granularity of Consumer Contact Centre information in areas such as geographies, peak times, response times, and when a call was dropped and by whom. The enhanced consumer call and performance information can then be used to prepare a wide variety of customized reports.

Business continuity plan

Consumer Contact Centre continuity plans are integrated into FCAC overall business continuity planning. Risks associated with the centre are specifically identified and addressed. Specific FCAC staff are assigned to recovery of Consumer Contact Centre services. In addition, CDIC has backup arrangements for the Consumer Contact Centre and Service Canada can be called upon to provide Consumer Contact Centre services on short notice.

Judgement, documentation and analysis

The Consumer Contact Centre has two components. A Consumer Contact Centre that gathers consumer information and then a WebCIMS database that sets up a consumer call case. The consumer information used by management for identification of emerging consumer concerns and of compliance issues in the industry per se or a specific financial institution.

The Consumer Contact Centre is being upgraded with the Bell ICE system that will keep extensive information on consumer calls with a comprehensive drill down reporting capability. Improvements made or underway are expected to strengthen analytical and reporting capabilities.

Inquiries Officer training

Inquiries Officers receive training on FCAC legislation and regulations as well on capturing information on WebCIMS. Experienced Inquiries Officers have reviewed the new scenario script guidance and found it useful in answering specific questions about classification of consumer calls. Also, FCAC provides ongoing feed back to the Inquiries Officers on the consumer information and the classification of the consumer call. In addition, CDIC provides Inquiries Officers with training on second language, computer skills, business writing, and other professional development sessions. The Inquiries Officers indicated that training and support had improved significantly in 2007-08 and the new scenario script guidance is very useful.

The Inquiry Officers' training should be formalized and aligned with competency expectations.

Quality of information and classification of consumer calls

The Consumer Education and the Compliance branches review the consumer information and call classification recorded in WebCIMS database in detail and provides feedback to the Inquiries Officers on a timely basis, at least weekly. Inquiries Officers make changes as needed to the WebCIMS database. The timely feedback to Inquiries Officers of changes needed results in a very low level of changes and identified changes are rarely repeated.

Inquiries Officers would like guidance on what should and should not be captured in the WebCIMS text fields. The new scenario script guidance is addressing this concern. As well, the FCAC's Manager, Consumer Services, reminded Inquiries Officers that they can directly call Consumer Services and Compliance officers to answer any question they may have.

Other training materials are available and accessible to Inquiries Officers, including CCC Reference Guide for Consumer-Related Calls ; FCAC Consumer Services Policy and Procedures Correspondence, and Telephone Contacts ; Power Point Presentation for WebCIMS Information.

As previously reported a new Bell ICE system is being implemented that is expected to significantly improve the granularity of the information captured and provide drop-down guidance on classification of consumer calls. This is expected to further reduce the number of changes to the consumer information in the WebCIMS database.

Resource allocation and financial planning

The Consumer Contact Centre plans and resources are incorporated into FCAC's plans and budgets. The MOU provides for ongoing operations and support of the centre.

In 2007-08, an Acting manager, Consumer Services, was assigned to the Consumer Contact Centre focusing on developing and implementing an extensive improvement program on a project basis. Effective April, 2008, a Manager, Consumer Services, was assigned to the Consumer Contact Centre responsible for the management and oversight of centre's activities and MOU. The manager's time is allocated between the Consumer Services (Consumer Contact Centre and Correspondence), 60%, and Consumer Education activities, 40%.

As a new Bell ICE call centre system is being installed by CDIC and, as a result, enhanced information requirements and performance standards are being implemented, FCAC should monitor the effort needed for oversight and support of the centre during 2008-09 and going forward.

Overall assessment

The respective processes and activities are in place. With the Bell ICE system, management is updating the information, performance standards and reporting requirements. Improvements made and undertaken should be incorporated into the MOU. FCAC indicated that a revision / update of the MOU in underway. We support these initiatives.

Also, we recommend that management monitor the effort needed to support the Consumer Contact Centre during 2008-09 and going forward.

FCAC uses three mechanisms to monitor and assess the Consumer Contact Centre: call monitoring, mystery calls and customer satisfaction (call back) survey. Centre monitoring is done by the Consumer Contact Centre Supervisor on a daily basis. There was a mystery call exercise in 2007 which identified areas of concern such as Inquiries Officers did not always identify compliance issues or classify the call in the correct compliance classification. This concern is being addressed with the introduction of comprehensive scenario script guidance, in-depth training and implementing plans to strengthen the Consumer Contact Centre service, such as the new Bell ICE telephone system. The new system has an electronic survey capability that is being considered by management as an alternative to a customer call back survey.

Quality activities

Quality activities include a review of the information and classification captured on WebCIMS as well a management review of bi-weekly Consumer Contact Centre statistics. In recording consumer information there are two quality reviews. A review by the Consumer Education division and a second review by the Compliance division. Any information or classification changes are forward to the responsible Inquiry Officer who makes the changes to WebCIMS.

The number of changes is low considering the qualitive nature of the information and the large number of classifications. There are about 30 changes out of some 400 or 500 classification entries made weekly. The level of changes is expected to reduce further with the introduction of scenario script and classification guidance.

In addition, there are monthly Consumer Contact Centre meetings to share updates on FCAC products, services and regulations, and a general discussion of centre operations.

Performance measures and reporting

Routine reports are prepared on the Consumer Contact Centre operations such as Bi-Weekly Management Committee reports on call volumes, # calls by province; Quarterly Scorecard on performance standards – time taken to answer calls, call abandonment rate; Performance Report on average wait time for consumers who contact the Consumer Contact Centre. Quarterly FCAC Statistics are posted on FCAC's website.

With the Bell ICE system, reporting capability will significantly improve in terms of customizing and granularity of reporting.

We support management's initiative of updating consumer information and performance requirements. Annexes should be added to the MOU with respect monitoring the centre's operations and performance and reporting needs.

Although the Consumer Contact Centre service is outsourced to CDIC, the majority of calls are for FCAC. As the result, the Inquiries Officers associate more with the FCAC rather than CDIC. Inquiries officers raised the concern that they are often the “last to know” about new initiatives and publications. They would like to be more involved in FCAC meetings as well timely informed on new announcements and programs so that they can handle consumer calls on an informed basis.

The FCAC manager responsible for the Consumer Contact Centre changed several times over the last few years. The Inquiries Officers indicated that there was inconsistency in support and guidance, and they expressed concern as to access to FCAC staff, especially in late afternoons and evenings because centre hours are longer than FCAC office hours. FCAC increased interaction with the Consumer Contact Centre through weekly on-site visits and involved the Consumer Contact Centre Supervisor and the Inquiries Officers in some FCAC meetings. This was reinforced with new and planned training sessions and providing scenario script guidance.

During 2007-08 an Acting Manager, Consumer Services, oversaw the day-to-day support of the Consumer Contact Centre. FCAC has increased interaction with the Consumer Contact Centre Supervisor and Inquiries Officers, daily contact with the centre and weekly site. E-mails are used to inform Inquiries Officers of changes to the consumer information or the call classification code as needed.

Through an annex, these improvements should be incorporated into the MOU.