The Irish Independent, the Irish Times and Silicon Republic have all carried coverage over the last days about TalkTalk, the CarphoneWarehouse fixed line subsidiary’s operation in Ireland (recently acquired from Tele2).
According to Silicon Republic:
“ Talk Talk has been ordered by the Commission for Communications Regulation (ComReg) and the Data Protection Commissioner to make a public apology over complaints by consumers who received cold calls despite recording their preference not to receive unsolicited marketing calls.”
In addition, they have been asked by BOTH regulators (Comreg and the Data Protection Commissioner) to immediately cease all direct marketing until an audit has been carried out.
The root of the problem is that TalkTalk talked to people who had opted out of direct telemarketing on the National Directory Database. As such TalkTalk should not have been talktalking to these people. And some of them complained, to both the Data Protection Commissioner and the Communications Regulator.
TalkTalk have pointed the finger of blame at “data integrity issues in their internal processes” and gaps in the data that they acquired from Tele2 when they purchased it.
In the increasingly comptetive telecommunications market, not being able to direct market to prospective customers effectively puts you out of the game, with an increased reliance on indirect marketing such as posters or TV ads, none of which match the conversion rate of outbound telemarketing.
The Information Quality lessons here are simple:
- Ensure that your critical core processes (such as marketing database maintenance) are defined, measured and controlled in an environment that supports Quality information.
- Make sure that your Information Architecture is capable of meeting the needs of your knowledge workers. If a key fact needs to be known about a customer or potential customer (such as their telemarketing preferences) this should be clearly defined and maintained and accessible.
- When you are buying a new business or merging with another organisation, an important element of due diligence should be to look at the quality of their information assets. If you were buying a grocery store you would look at the quality of their perishable goods (are you buying a shop full of rotten tomatoes?). Buying the information assets of a business should be no different.
- “The obligation to the customer never ceases”. At some point somebody must have berated a TalkTalk Customer Service/Sales rep for ringing them during Corrie when they had opted out of direct marketing. Why was this not captured? Toyota’s Quality management method allows any employee to ‘stop the line’ if a quality problem is identified. In the context of a Call Centre, staff should have the ability to at least log where the information they have been provided doesn’t match with reality and to act on that. If these call outcomes weren’t being logged there is an absence of a valid component in the process. If the call outcomes were being logged but were not being acted on by Management there is an absence of control in the process.
- “Cease management by Quota”. My guess is that all the staff in the call centres were being measured on how many calls they made and how many contacts they converted. Where these measures were not met I would suspect that there was a culture that made failure to hit targets unacceptable. Unfortunately taking time out to figure out why a customer’s view of their suppressions is different to what is on the screen impacts call duration and the number of calls you can make in a night. Also, removing records from calling lists as scrap and rework slows down the campaign management lifecycle (if the processes aren’t in place to do this as par for the course).
So now TalkTalk’s call centres are lying idle. TalkTalk has joined Irish Psychics Live as being among the first businesses to have a substantial penalty in terms of fines or interruption of business imposed on them by the Regulatory authorities for Data Protection issues. There’s a lot of call quotas not being met at the moment.
I will be interested to hear what the audit of TalkTalk brings to light.