Complaints EQ - The Timeliness Principle

Jonathan Mantle talks about the complaints time limit rules in DISP and encourages you to ditch the arbitrary timeframes for one simple principle.
Jonathan Mantle
Director of Complaints EQ
Thursday, September 2, 2021


In 2007, some of the specifically prescribed timeframes in DISP such as the five-business day acknowledgement and four-week holding letter were swapped for non-definitive adjectives. But many firms stuck with them. Some even invented their own.

I can understand why. Imagine the look there’d have been on the faces of the compliance team, when told they’d now be checking and monitoring processes against the requirements of ‘prompt’, ‘early’, ‘kept informed’, and ‘earliest opportunity’. “We’ll be sticking with the known quantities, thanks” probably would have been the reply. But you can do it. You just need to adopt a culture and principle of timeliness.

The premise of this ‘Timeliness Principle’ is that you base your processes on, as the name suggests, timeliness - not timeframes. It’s a subtle change of word, with a huge change in focus.

Timeliness focuses on circumstances. Something is only timely if done when it should be, given the situation. Timeframes focus on deadlines– it just needs doing by a certain fixed time, regardless of the circumstance. It’s the difference between when you can and when you must. Which can be the difference between a day and a month.

So, I’m going to wander through the key communications in the complaints time limit rules and explain how to apply this principle and make a significant difference to your culture, and to your customers’ experience.

The acknowledgment

You have to send a “prompt” written acknowledgement, providing “early reassurance” you’ve received and are dealing with the complaint.

Now let’s say you message someone about something that’s important to you, and you need them to acknowledge that they’d got it. If your phone didn’t ping for another five days (maybe seven, if counting the weekend) would you consider that prompt? Would that give you early reassurance they got your message? I doubt it. Given today’s digital age, many of us would be breaking-out in a cold sweat after thirty minutes. Yet many firms still have a process that allows their customers to wait this long. 

You may point out the summary resolution period, and note you don’t have to acknowledge a complaint if you resolve it within this time - so why not just wait until after that? Well, the key word here is *if* you can resolve it within that time. And the rule doesn’t say “promptly, after the summary resolution period expires”.

So, deciding when to acknowledge a complaint should come down to the simple question:

“can we, with a reasonable level of assuredness, resolve this within the summary resolution period?”.

If you don’t know or don’t think so, acknowledge it at once. Don’t wait for a one-size-fits-all timeframe to elapse first.

Alternatively, simply acknowledge every complaint the moment it’s recorded, outlining both the summary resolution and formal resolution stages. Then you’re always ensuring a prompt acknowledgement and early reassurance. Just because the rules indicate you don’t have to do something, doesn’t mean it isn’t in your customer’s best interests to do it anyway.

Keeping the customer informed

In 2007 the four-week holding letter was abolished, replaced with the new requirement that the customer must be “kept informed…of the progress of the measures being taken for the complaint's resolution”. Effectively, moving from a ‘milestone event’ communication to a frequent progress report into what’s happening, and what you’re doing.

There are two key factors in this communication – frequency, and purpose. So, arbitrary timeframe-driven communications will often mean you falling short of both the requirement and the expectations within it.

For example, four weeks may seem far too long to keep a customer waiting, so you decide to arbitrarily introduce weekly updates. But for those complex complaints that take six to eight weeks to resolve, that’s anywhere between five and seven weekly updates - none of which are likely to offer much insight into the complaint’s progress. So, what’s the point of them?  

Adopting a timeliness principle means updating your customers when it’s appropriate. For them. Which means talking to them to understand their needs and expectations. This will make updates more personal as you’ll find them more tailored to what the customer wants (and expects). And you’re more likely to avoid the generic, unhelpful and automated-sounding “we’re still looking at your complaint and doing everything possible to resolve it as soon as we can” - which arguably fails to fulfil the intended purpose of this communication.

A final tip for updating your customers – try phoning first, instead of writing. It’ll help with rapport and give the opportunity for the customer to ask any questions. It can also help when it comes to delivering the outcome later. For example, if you’re waiting for information, talking about what you’re waiting for, why it’s important, and how it may influence your decision. If the decision doesn’t go their way, at least there’ll be no surprises – so they’re less likely to react badly, and your openness and transparency will promote acceptance.

Final Responses

My work is a lot simpler here, because the DISP rules around the final response already works on a timeliness principle! So, I’ll use this opportunity to set the record straight.

Eight weeks isn’t the ‘allowance’ you should be referring to when a customer starts making demands about how long they can expect to wait for a final response. The DISP rules make it clear that you should assess the complaint promptly (there’s that word again) and aim to resolve complaints at “the earliest opportunity”. You’re expected to have resolved almost all complaints before eight weeks. So, it’s not the standard – it’s the remote exception.

Think of eight weeks as Complaints Armageddon – it’s when the rules allow the customer to effectively give up on you and just go to the Ombudsman to get it resolved. It’s not something to aim for or be particularly happy about reaching.

But I’d add that any timeframe you arbitrarily set is wrong. Even saying “our internal target is four weeks!” is missing the point – because there shouldn’t be any specific timeframe. It’s “at the earliest opportunity”.

There’s another danger in setting your own (or any) timeframes as ‘concrete’. It creates an unnecessary pressure on a complaint handler to resolve the complaint to meet this time at all costs. It risks sloppy investigations and poor decisions, perhaps all for the sake of meeting KPIs.

If you’re keeping the customer informed properly, and in the way they’ve asked, they’re likely to be more forgiving if things take a little longer every now and then. So, stop clock-watching.

Measuring it all up

So how do you measure or capture this in your MI? After all, it’s easy to run a report with all the numbers/percentages of acknowledgements sent beyond five days, updates beyond so many weeks and so on.

Well, you should be assessing timeliness within your quality audits – after all, it’s a big part of the customer experience and can create a business risk. But even from a pure reporting perspective, you can still filter acknowledgements not sent immediately and where there was no summary resolution on the case. You may have to review those instances to understand why it’s not happening – but you’ll already have a general understanding of why from the audits.

The advantage of all this means people need to be recording information on the cases they work more comprehensively (which can only ever be a good thing). So, if they’re not acknowledging right away (for example) they’d need to say why. That way, when it’s looked at by on audit or for MI purposes, it can be ‘marked off’ the concerns list unless there’s no good reason identified for the delay.

If this is going to make your KPIs fiddly or difficult, I’d recommend you revise your KPIs. After all, they should be set up to drive the culture you want. And you want a culture of “at the earliest opportunity” and not “when I have to”, don’t you?

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