'Where Are You?' Be Ready to Answer

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The worldwide outsourcing movement has created a variety of answers to the question, "Where are you?" when someone speaks to a customer service representative. To date, there are no hard and fast rules or laws requiring a standard answer from everyone. If some policy makers have their way, this will change, and in Arizona and Kentucky, it already has.

As a topic, location disclosure has become popular for political rhetoric in the past several years. As firms have moved offshore, news articles and television reports have focused on the loss of jobs in the service sector of the U.S. economy. An assumption is made that if consumers knew their telephone calls were being handled overseas, there would be an outcry for firms to move contact center work back to the United States.

It is against the backdrop of this assumption that lawmakers have been trying to create policies to make call center location more transparent to consumers. For a quick review, consider the way that policymakers now consider location disclosure:

Location disclosed upon request. In this scenario, if a consumer asked where the representative was located during the call, a legal obligation would be created to disclose a physical address including city, state and country. The American Teleservices Association encourages this type of disclosure as a fair and honest marketing practice to provide consumers with information they are interested in prior to making a purchase or engaging in service. This type of disclosure gives information to the interested consumer without adding burdensome costs to the marketer or service provider.

Location disclosed at the conclusion of the call. At the end of all telephone calls, the representative would conclude by stating the location information similar to the earlier point I made.

Location disclosed at the beginning of the call. Instead of concluding the call with the location information, the representative would be required to include this information as part of the disclosures that occur at the start of the call. A bill has been introduced in the U.S. House of Representatives and Senate in each of the previous two years that would require this type of announcement (HR 4932 and S 2553). And Arizona and Kentucky have laws requiring this type of disclosure before any solicitation can take place on the phone.

Location disclosed at the beginning of the call with the option to redirect the call to a U.S. representative. Clearly this is the most onerous of the proposed restrictions, and though introduced in New Jersey and contemplated by other states, this approach has not yet become law.

The ATA has monitored legislation on these issues for the past several years and anticipates that interest in disclosure will continue. Honest disclosure is prudent business and protects consumers. But disclosure that is a thinly veiled attempt to influence consumer behavior by state or federal government is restrictive and inappropriate. As an industry, disclosure requirements are not standardized. It is important for firms to consider the methods being evaluated by policymakers and to act in anticipation of legislation.

The teleservices industry should proactively develop best practices in this area. The alternative - waiting for legislators to enact sweeping rules that probably will be inappropriate for the industry - is not an attractive option. The ATA recommends that all companies determine which of the four methods of disclosure detailed above respond most appropriately to their business and customer needs, and put the proper policies in place to meet those needs.

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