Telemarketing Compliance: Protecting the Brand

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During the nearly 50 years of the Cold War between the Soviet Union and the United States, deterrence was the primary method of preventing war and a nuclear holocaust.


Both sides depended on three methods for delivering nuclear weapons: ground-based, sub-based and air-based. All three together created a comprehensive deterrence that one method alone would not.


Though outbound telemarketing isn't a life-and-death issue, protecting a brand from sloppy practices or outright dishonesty can save millions of dollars. Managing compliance with outbound telemarketing requires discipline and a three-pronged effort to be sure your efforts are in compliance and to create a deterrent to damaging your brand.


Most large users of outbound telemarketing spend millions of dollars to develop and enhance brand recognition. The marketplace is becoming aware of the need to protect that brand and the company from false or misleading statements. In today's world, image and reputation should be protected at all costs. Beyond image and reputation, today's world is very litigious, and it doesn't take much to create bad press and possible fines that can run into the millions of dollars.


It makes sense to put together a comprehensive program that keeps your company's finger on the pulse of what is happening. It doesn't matter how well trained your representatives are. When working with many employees, you are in constant danger of someone making a decision - conscious or subconscious - to make statements or use procedures that are not in line with what the company wants. Some of these decisions can be costly.


Monitoring your outbound telemarketing programs is a must; however, monitoring alone does not give you the full picture. Traditional monitoring can help with compliance and add to performance enhancement, but it has limitations and, too often, it simply becomes "monitoring for the sake of monitoring."


The ground force (traditional monitoring model). This is the model for compliance and performance enhancement. This is where the bulk of your efforts must go. This effort is very important to your overall quality program; however, there are land mines that you must be aware of.


In many instances the representative knows monitoring is taking place. Therefore, the calls during the monitoring session might not be indicative of the calls that take place the rest of the time. You can still get value from the session because there are areas that can be enhanced. Even when a representative is going "right by the book," there will be weaknesses and opportunities for improvement.


Another important point is that in a typical one-hour monitoring session you are often not in control of which representatives you get to listen to. You might keep listening to the same representatives. Some of the ones that need to be monitored the most might not get monitored at all. This is where a good database that can give you information about the representatives that are calling on your programs can prove invaluable. You should know who has been monitored, the frequency of the monitoring, what was said and what action has been taken.


You can win most of the battles with a good ground force that is well planned and fully implemented, but you will need additional support that ensures the coverage you need to keep from being vulnerable.


The air force (sales tape audits). The air force deals with specific targets. Everyone knows that you are coming, but no one knows which targets you are aiming for. In this analogy, let's say the targets are completed sales. Your sales are recorded and verified by someone, usually at the center level. The sales recordings are for your protection in the case of a customer dispute. These sales are monitored for accuracy and then stored. You should have a sales audit procedure in place. There should be a specified number of "targeted" sales that are pulled for review by your company. These sales should be the particular sales that you request each week from the center that is calling your program.


Since those who do the verifying know that you are actively monitoring and scoring specific sales, the overall quality goes up. This is a highly focused activity that invariably strengthens the overall program. Some call centers are good at verifying sales, but some let far too many bad sales slip through the cracks. You should make your criteria for a "good sale" clear, and it should be reflected in your monitoring reports back to the agency.


The submarine force (list seeding). This force has tremendous power because unlike the other two, it can strike at any time and any place. This "stealth" force is a tremendous deterrent to noncompliance because it plays no favorites and can and will cover all representatives at all levels of center activity.


List seeding has been used in direct mail for years to ensure proper usage of a mailing list. It is relatively new in outbound telemarketing, but it can be very effective.


Your call list is "seeded" with phone numbers that are redirected to your monitoring group. The call is answered "Hello" and sounds like a normal telemarketing call. The quality coach asks questions, gives objections, etc. This entire interaction can and should be recorded for calibration purposes. After the call, the quality coach scores the call and makes notes for ways to improve the quality of the call and/or address any compliance issues. If a digital recording system is utilized, the report can be attached to the recording and retrieved electronically.


An old military axiom: A poor plan well executed is better than a great plan poorly executed. Ideally, you should cover all of your quality bases by having a great plan that is also well executed.
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