BLOG: Ultracomms has published its response to the Ofcom consultation on its ‘persistent misuse’ policy, which includes silent or abandoned calls resulting from outbound dialling campaigns. The response submitted by Ultracomms is based on over a decade of experience working with contact centre organisations in the UK, monitoring and examining the dialling activity of clients and advising on all areas of Automated Calling System (ACS) use, from productivity improvements to operating within the regulatory guidelines relevant to their industry sectors.
Commenting on the submission Darren Sullivan, COO, Ultracomms said, “At Ultracomms, we have welcomed introduction of the Ofcom guidelines, the increased penalties available to Ofcom, and the ongoing clarification of those guidelines the industry is required to operate within. These changes have undoubtedly made significant inroads to reducing the numbers of complaints from consumers to protect the industry as a whole.”
Ultracomms’ full submission is available to download here, but in summary we hold the following views:
We are supportive of the need for regulation in the industry and proactively advise our clients on best practice to ensure they operate well within regulatory guidelines.
We believe that further major changes to the current policy are not in the interests of the industry as the vast majority of organisations, certainly those that we work with, strive to work within the current regulatory framework set out by Ofcom and other industry specific rules.
The penalties available to Ofcom are substantial and are more than large enough to be a significant driver in defining dialling strategies for larger organisations, and could easily drive smaller operations out of business should they be found to be operating outside regulations.
We suggest that the main focus of Ofcom’s investigations to date have been on larger organisations that are trying to remain compliant by presenting CLI and thus making it easy to identify themselves to those that have cause to complain, legitimately or otherwise. We believe the industry and consumers would be better served by shifting the focus of investigation to the small percentage of companies who are attempting to ‘operate under the radar’, for example, by withholding CLI.
Historically, the use of Cadence AMD solutions has been a significant cause of silent or abandoned calls due to the time it takes the technology to establish whether the call has been answered by an individual or a machine.
Following recent advances in Answer Machine Detection technology, it is felt that the current 24 hour rule could be reviewed as the accuracy can now be in excess of 99.99%. This rule restricts the use of this advancement in technology.
Ultracomms’ full response will be published on the Ofcom website and is available here