New Institution - New Ombudsman: Commentary on DTI Consultation on consumer representation
- New Institution - New Ombudsman
- Regulator First - A No Brainer Relationship Choice
- The New Ombudsmodel - Inventing Your Own Complaints
Regulator First - A No Brainer Relationship Choice
The key institutional relationship for the new body will be the one with the regulator. Indeed Option 3 recognises this and gives a regulator the chance to take back the consumer panel in the form of a "regulator's consumer panel". Watervoice - now the Consumer Council for Water - has just been rescued from this in the interests of the independent consumer voice.
This independence may be more notional than real. If consumer bodies want action, they have two choices - persuade companies to do it or persuade the regulator to tell companies to do it. In terms of effective use of lobbying resources and relationship development, this is a no brainer. Go for the single body - the regulator - with the power of compulsion. Forget endless meetings with company A or even worse, trade body Y. The middle way is to start negotiations with industry but in the shadow of the big stick.
The regulator is the big stick and if thwarted by industry intransigence, the consumer body can always run back to fetch big brother to sort out big bully industry. This does of course have repercussions for the relationship with the industry concerned but then it is not clear from these new arrangements if such a relationship is still of any interest or utility. A smart consumer body with access to a research budget can come up with a set of problems and develop solutions for them without any help from boring old business. The next issue is implementation and again why bother negotiating or consulting with the companies when you have the ear of the regulator or law makers?
Getting Out of Complaint Handling - Good
The document asks whether we agree with the idea that companies who provide services should have "complete responsibility towards their customers, including the resolution of complaints?".
Is the question here do you think companies should pay for a nationalised escalated complaint handling scheme like the one for the electronic communications industry? Yes - it is a better model than the Financial Services Ombudsman where the Ombudsman runs the risk - held at bay by the current incumbent - of being seen as the Regulator's Quality Control Supervisor implementing mass schemes of market correction e.g. mis-selling of endowment mortgages.
Expensive, Pointless and Toothless
The consumer representative bodies must get out of complaint handling.
They do need the complaint data but not the complaints. They were a referral shop anyway - complaint in, bounced back to company for another look in the knowledge that the consumer body was taking an interest and resolved or resisted by the company's central escalated complaint handling unit.
The consumer body set-up was expensive set-up, pointless and toothless. The trick here is to establish some relationship of trust with the companies that will persuade them to share their customer problem contact data with consumer bodies. If ordered to supply such data, companies will suppress as much evidence as they can with ingenious complaint definitions that ensure that only the tip of the iceberg of consumer concerns is labelled as a complaint that needs to be counted and notified to an external party.
So how to persuade them to lift the veil?
The point that remains is that Ombudsmen are expensive. The logic is that they are so expensive that companies will settle and so no complaints will ever come to an Ombudsman and so the Ombudsman will go out of business. Only one - the Funerals Ombudsman - has ever done so. The Ombudsmen game is not one for small businesses as Independent Financial Advisers will tell you.
Continued: The New Ombudsmodel - Inventing Your Own Complaints
