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| Developing and Implementing Consumer Complaint Management Initiatives | | | |
As we saw, Consumer Complaints Management initiatives encompass preventive techniques,
internal complaints-handling approaches and external dispute resolution
programs. These come in a wide variety of shapes and sizes, and are initiated
for many reasons. Comprehensive consumer complaints management
systems are preferred options in many circumstances, since they integrate
all three components. But just as there is no one “correct” Consumer Complaints Management initiative,
so too there is no single approach to developing Consumer Complaints Management initiatives.
Developing comprehensive Consumer Complaints Management systems requires a step-by-step approach
and, likely, more resources than creating a single preventive measure.
Similarly, developing an internal complaints-handling process is likely to
be quite different from creating a new system of mediation or arbitration,
introducing an external ombudsman, or creating a new decision-making
tribunal. By the same token, the process for developing Consumer Complaints Management programs for
single firms may be considerably less elaborate and formal than that for
larger and more complex multifirm initiatives. The eight-step process set
out below is a “one-size-fits-all” approach, describing the full range of
questions and factors to consider when designing Consumer Complaints Management initiatives. There
are aspects of the process that do not likely apply to smaller and less comprehensive
Consumer Complaints Management initiatives. For this reason, a short checklist of elements
of successful complaints management initiatives within firms is also
provided, following the eight-step model. Then, some general tips and
suggestions and a number of sources for more detailed help are provided.
An Eight-step Model for Developing Consumer Complaints Management Initiatives
Step One: Define Problem and Gather Information
- What problem is the Consumer Complaints Management initiative intended to address? Is there baseline
data pertaining to the needs and concerns of consumers on which
to draw? What are the objectives of the Consumer Complaints Management initiative, and does everyone
agree with them? Finding common ground on the problems being
addressed and the objectives of the initiative is essential to moving
ahead with solutions. Industry Canada’s Office of Consumer Affairs
has developed a diagnostic tool to help companies identify problems
with complaints handling.
- What are the options for resolving the problem, and what are the
potential costs, drawbacks and benefits of each solution? Industry
Canada’s Office of Consumer Affairs has developed a diagnostic tool
to help businesses identify ways of improving refund and exchange
policies. There may be value in looking to the experience
of merchants in other sectors and jurisdictions.
- Have all the people and organizations that could be involved or
affected by the Consumer Complaints Management initiative been identified, and have their interests
or concerns been taken into account? For example, the views of a
cross-section of upper management and rank and file officials within
affected organizations, representatives of consumer organizations, and
government officials should all be taken into consideration. Clearly, the
range of identified individuals will depend on the initiative in question.
A single pizza delivery company may not need to directly involve
anyone outside the organization when developing a “30 minutes or
free” delivery policy, but it would be wise to identify and articulate
the interests of the drivers (e.g. the delivery policy should not put
drivers at risk).
Step Two: Hold Preliminary Discussions
With Major Stakeholders
The objective of this stage is to test the tentative conclusions reached in
the information-gathering phase and identify partners willing to help
develop the Consumer Complaints Management initiative. Looking beyond like-minded industry
colleagues to more broadly affected interests such as consumer group
representatives and government officials can help to confirm initial
perceptions of the initiative or stimulate useful revisions. Informal
bilateral sessions may be appropriate in many situations, and focus
groups are also useful for testing new ideas.
Step Three: Create a Working Group
Having the right people on the working group is essential. They should
be dependable, credible and knowledgeable, represent the diversity of
affected stakeholders, and have the necessary time and resources to
commit to the project. Frank discussion should take place at the outset
about the group’s objectives, members’ responsibilities, anticipated
workloads and outcomes, and the ground rules about how the group
will operate (e.g. decision making by consensus, rotating chairs).
Within the organization, an effort should be made to ensure that frontline
employees (who will play a major role in implementing the Consumer Complaints Management initiative),managerial staff and key organization leaders are included.
Consumer Complaints Management proponents may wish to explore the feasibility of inviting a government
representative to participate in the working group, since relevant
government agencies and departments can provide important expertise
and advice. Even when they do not agree to participate as working group
members, relevant government departments and agencies should be
consulted early on in the development of the Consumer Complaints Management initiative.
To ensure that the full range of concerns is heard, it is very useful to invite
knowledgeable consumer group representatives to participate in the
working group. Consumer groups can provide a wealth of information
and valuable perspectives about complaints issues, and their input can
give Consumer Complaints Management initiatives additional legitimacy.“[A consumer group] told us
things about our own product that we didn’t even know,” said John Tory,
President and CEO of Rogers Cable Inc. This has led Rogers to develop
new ideas and services.8 Consumer groups and Consumer Complaints Management initiators should
work together to maintain the credibility and independence of the participating
consumer group. Regular communication with the full consumer
group community is also useful. When consumer group representatives
are involved, it is strongly recommended that some form of remuneration
be offered, such as an honorarium and compensation for travel expenses.
When selecting consumer group representatives, a good fit — both of the
group and of the individual within the group — is particularly important.
Care must be taken when identifying the right consumer groups and
inviting the appropriate representatives within the groups. In this regard,
it is recommended that the consumer groups be fully informed of the
goals of the Consumer Complaints Management initiative, the development and implementation
processes, and the particular roles and responsibilities of the consumer
group representative. This ensures mutual understanding, builds trust
and sets the groundwork for a good working relationship. Before agreeing to participate, the consumer group representative will likely want to
know the following:
- whether all the major players are at the table
- the views of relevant government agencies on the initiative
- the track record of the Consumer Complaints Management proponent for similar initiatives
- whether there is commitment from the organization’s leaders
- the openness and accessibility of the decision-making process
- the roles and responsibilities of all working group participants.
Step Four: Prepare Preliminary Draft and Explore
Appropriate Structures
In preparing a preliminary draft of the initiative, working group members
will likely identify who (people, organizations and new institutional
structures) will be responsible for which aspects of implementation.
For example, certain employees may perform key new functions, and
a new agency or management structure may be created to help with
implementation. Several of the Consumer Complaints Management initiatives discussed in Part One of
this Guide are housed in separate non-profit bodies dedicated specifically
to complaints management or dispute resolution (e.g. the Canadian
Banking Ombudsman, Advertising Standards Canada’s national and
regional consumer response councils, and the Cable Television Standards
Council). The advantage of such new structures is greater perceived and
real independence from other aspects of the organization’s activities. The
credibility of complaints handling and dispute resolution decisions is
likely to increase when decision makers are seen to be at arm’s length
from the organization’s other activities and officials.
In other situations, ad hoc use of neutral third-party mediators or arbitrators
may be sufficient (e.g. as used by the Better Business Bureau). In
such situations, there needs to be criteria for assessing the expertise of
the third parties. Creation of new structures and use of new parties to
help with complaints handling may involve considerable expense, which
should be factored into design considerations from the outset.
Step Five: Consult With Stakeholders
The working group draft of the initiative should be considered a point of
departure. Thorough consultations concerning the draft with all interested
parties will help prevent problems later. One good approach is to
work outward, from those most likely to be directly affected to those less
likely to know about the initiative.
For industry-wide initiatives, once the working group has agreed to a
draft, it should invite, using a public announcement in appropriate
media, comments from anyone interested, allowing a reasonable time for comments to be returned. Direct solicitation of comments from known
interested parties is also advised. A consultation plan can be useful. It
should include roles for high-profile officials with good communications
skills to explain the Consumer Complaints Management initiative and receive feedback. Typically, this
feedback would go to the working group, which would then discuss how
and to what extent the final draft would reflect the comments.
Step Six: Announce and Publicize the Initiative
As mentioned earlier, a Consumer Complaints Management initiative that is not adequately publicized
has little chance of succeeding. Participating merchants (including managers
and employees), consumers and governments all need to know
what the initiative is and how it affects them. A good communications
plan is important. It should identify who must be made aware of the Consumer Complaints Management initiative, who should receive a copy of its terms, and how the individuals
and groups will be reached. The communications activities might include
an awareness campaign addressing such matters as the use of a logo, publicity
endeavours such as advertising and speeches, pamphlets, and a
notice that firms and organizations can display on their premises. There
must be adequate funding to ensure that these communications activities
are properly carried out.
Step Seven: Implement the Initiative
The following are essential elements of effective implementation.
Adequate financing. When there is not sufficient funding, a Consumer Complaints Management initiative
risks being nothing more than words on paper, potentially frustrating
consumers and bringing the reputation of firms into disrepute. The
salaries of complaints-handling specialists, communications budgets,
payment of consumer group representatives’ expenses, and costs associated
with operating new decision-making bodies need to be taken into
account from the outset. Possible self-financing levies (e.g. paying dispute
resolution experts on a per use basis) need also to be carefully worked out
before the program is launched.
Phased-in implementation. There may be value in implementing the
initiative in phases. For example, a program might operate only in certain
jurisdictions at first, or apply only to certain types of transactions. Alternatively,
the program could initially operate on a “pilot” (limited term)
basis. The advantage of the phased-in approach is that it allows administrators
to test the viability and practicality of a program, and make appropriate
adjustments before unveiling a full and comprehensive initiative.
Ongoing communications initiatives. In addition to initial communications
activities, there need to be regular information updates — quarterly,
bi-annually or annually — to tell affected parties how the program is
working and about any changes in operation or other developments.
Step Eight: Monitor, Review and Improve the Initiative
Regular monitoring, review and continual improvement of program
terms and operation should be designed into Consumer Complaints Management initiatives from the
outset. When and how often the monitoring and reviews take place
should be based in part on how long it will take to generate data on
effects and objectives achieved. To measure the impact of a Consumer Complaints Management initiative,
data is needed on the situation prior to the Consumer Complaints Management initiative being
launched (i.e. baseline data) and at frequent intervals thereafter. This data
can be used not only to determine weaknesses in Consumer Complaints Management initiative design
and operation, but also to demonstrate results. The Cable Television
Standards Council, for example, does a random callback of consumers
who have had problems to find out how well the process worked. The
Canadian Motor Vehicle Arbitration Plan (CAMVAP) uses an independent
survey firm to collect and interpret information from all clients concerning
its dispute resolution system. Such processes provide vital feedback to
the organization, so it can understand where systemic problems lie and
how they may be corrected.
It may be useful to model the review methodology after the initial development
process. An independent third party who conducts parts or all of
the assessment can provide a more detached perspective and perhaps
lend more credibility to the process. For example, every five years, CAMVAP
hires an independent consultant to thoroughly review its operations.
Summary
Introduction
Market
-based Consumer Complaints Management Initiatives
Preventive Consumer Complaint Management Initiatives
Internal Complaints-handling Initiatives
External Private Dispute Resolution Initiatives
Comprehensive Complaints Management Systems
Characteristics of Effective Online Trustmark Programs
Online
Redress
The
Need for Effective Consumer Complaint Management Initiatives
Consumer Complaint Management Initiatives and the Law
Developing and Implementing Consumer Complaint Management Initiatives
Elements of Successful Consumer Complaint Management Initiatives
Where
Can I Get More Help?
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