Communication & managing disruptive events
By Karen Latham
Why is communication such an important factor in managing disruptive events?
The FCA’s regulatory deadline for implementation of their Operational Resilience requirements (SYSC 15A) is now confined to recent history and firms are presumably (or should be!) continuing their ongoing self-assessment and activities to address any vulnerabilities they have identified.
Through work with clients and in other collaborative discussions with firms that fell in the scope of SYSC 15A, a recurring theme came to light whereby firms felt that either they already had an adequate communications strategy and plan in place as part of their Business Continuity Management / Crisis Management, or that communication wasn’t the most critical part of their delivery of compliance with SYSC 15A.
The regulatory guidance* is clear:
As part of a firm’s communications strategy, the FCA expects the firm to:
(1) consider, in advance of a disruption, how it would provide important warnings or advice quickly to clients and other stakeholders, including where there is no direct line of communication;
(2) use effective communication to gather information about the cause, extent, and impact of operational incidents; and
(3) ensure that their choice of communication method takes account of the circumstances, needs and vulnerabilities of their clients and other stakeholders.
(*source FCA Handbook)
In addition to this ‘outward-facing’ management of communications, consideration must presumably be given to HOW disruption is identified and reported.
How many times do we come across situations where all the focus is on the inward communications, rather than a balance of inward and outward communications? Take the still-too-often occurrence of a back-office technology service user informing the technology department that their critical system isn’t working rather than the other way around: with the end user, the ‘customer’, being appropriately notified when the service goes down. Many of us can relate to this on a personal level too; as consumers having to inform their internet service provider that their service isn’t available.
A real life example of why communication is so important
As a result of the extreme weather the UK experienced last week there have been many infrastructure-related disruption events widely reported in the media.
On Monday 18 July, my broadband service disappeared mid-way through the afternoon. As would be the norm, I did my own initial impact assessment and identified that my phone line was still operational, and it was just my internet connection that had been lost.
I then activated my own (often effective) comms plan and posted a message on my neighbourhood social media group, and it came to light the impact was much wider than my property. I also informed a number of my customers that they may want to communicate with me over SMS, or voice until my internet connection was restored, switched from my desktop to my laptop and tethered my laptop to my phone.
Day 1: I placed a call to the fault reporting line for my ISP (an ‘award winning’ provider who have a critical dependency on a supplier for the underlying infrastructure used to provide my service). They responded with the (always irritating) BOT response but I followed the process, a remote test was run and I was informed by text message that, yes, there was an identifiable problem with my connection that required an engineer visit to my property and duly booked that visit for Wednesday morning: not ideal to have such a lead time but given the wider problems the UK was experiencing, I was not entirely unhappy.
So, as I understood it, on Day 1, the ISP believed the problem was within my property, gave no indication they knew about the wider problem, nor did they attempt to contact me.
I revisited my neighbourhood group, some of whom were having issues contacting their ISPs.
Several hours later, service resumed and I assumed someone else’s provider had contacted the infrastructure supplier and had sent an engineer to solve the problem. I had no further communication from my ISP and planned to cancel the scheduled engineer visit the following day.
Day 2: Around midday, my broadband service disappeared again, the same impact assessment and comms with my neighbours was performed and it appeared the service failure was the same impact as the previous day.
My neighbours then began contacting their ISPs to be met with varying levels of support and widely differing resolution and ‘engineer visit’ times. I reassuringly told them my ISP had an engineer scheduled to visit the following day and I would contact the ISP to confirm this was still the case.
Unfortunately, I was met with the same BOT experience but this time, the test result indicated there was in fact no problem with the general supply and it was an equipment failure within my property. This led me to persist in calling the ISP and speaking to a real person (part of the service this ISP uses in their marketing messaging). The operator attempted to be extremely helpful, but it came to light that:
1 – the engineer visit scheduled for Day 3 had been cancelled follow a communication from the ISP’s infrastructure supplier on Day 1
2 – the ISP hadn’t felt the need to communicate this cancellation with me, the customer
3 – the ISP’s infrastructure provider would not (reason not provided) action a ‘rejection’ of my ‘fault resolved’ status to enable a new visit to be scheduled
4 – the ‘system’ would not allow the operator to set up another visit manually
I awaited a call back but having also lost my mobile phone signal, I repeated the dreaded BOT process around 7 pm only to be electronically informed there was no fault with my service!
Day 3
So, three days in to my first reported disruption:
- My ISP still hadn’t notified me when my problem would be fixed, nor that it had inadvertently been fixed (hopefully) as part of a wider-reported issue.
- Other customers impacted by the same disruption event had been kept much more informed by their ISP.
So, what do we learn from this?
- Inadequate communication with suppliers can hamper incident resolution. On Day 1, my ISP appeared to be trying to resolve the wrong problem.
- During disruption, the customer may be able to provide information that will contribute to the impact assessment of the outage.
- Clear and consistent communication channels with suppliers and customers is imperative. Amongst my neighbours we were dealing with at least four ISPs and our experiences and messaging from each varied widely, even with customers using the same provider!
- Poor communication with customers can increase their disruption. On Day 2, had I not phoned to confirm the engineer visit, I would inevitably have stayed around all morning on Day 3 waiting for a non-existent engineer to arrive.
- Processes and systems supporting ‘the face of the firm’ (i.e. call handlers, client services agents) must be adequate to enable staff to perform their job and provide customers with the correct information.
I have no reason to believe my personal experience last week is limited to the telecoms industry. I and many people I know have experienced similar problems communicating with banks, insurers, payment firms and so on when something isn’t working as it should.
Perhaps it’s time that firms dusted off their communications strategies and took another look, putting themselves at the receiving end of the service as a customer or client of the firm? What would they want to know? How would they want to be kept informed? And how about having the courtesy to let customers know when things are resolved – how many firms have that on their plan?!
I assume it is inevitable that firms use ‘customer service’ as a differentiator for selling purposes, but wouldn’t it be great if firms across an industry sector would collaborate and develop a common and standard approach to dealing with customers whose services have been disrupted?
This and other experiences beg the question of how many firms in the financial services sector operate truly effective communications plans that align to the FCA’s rules and the focus on customer service and minimising customer harm resulting from disruptions.
Perhaps it is the rules themselves that erode the quality of the communications and the service itself. What is a poor outcome for a customer? Is it a poor outcome as defined by any reasonable person being provided with the facts and matters of what happened; or is it only when a firm is unable to demonstrate that it followed a rule that a customer has had a poor outcome?
Shapes First have helped a number of clients improve both their inward and outward communications. Good communications can make the difference between your customers getting through the disruption and finding other ways of doing what they need to do, or taking to social media and writing their own version of events. If you would like to hear more about how we can help get in touch.