Identifying Systemic Issues and
Improving Customer Service
Annette Donselaar ASM BA BCom MComLaw LLM DFP Grad Dip Compliance AACI
Head of Australian Region Compliance
> Why complaints and compliance teams need to work together
> Systemic analysis in practice - why doesn’t it always work?
> Strategy into action
> NAB – a case study
> Benefits and ongoing maintenance
Does this sound familiar?
> We have a wide range of breaches but why don’t know why they
> We capture information about our customer complaints but we
have difficulty truly understanding what irritates customers.
> We have a ‘gut feel’ about what is going wrong but we can’t quite
put our finger on it.
> We need funding to address some issues but we don’t have the
statistics to back it up.
> Customers tell us that we have certain problems but it is not
reflected in our data.
The link between complaints & compliance
> If you could identify with any of the statements, you are searching for a
better way to understand your compliance environment - environmental
data (especially complaints!) is critical.
> By creating open lines of communication between complaints &
compliance teams you can:
Identify and prioritise the critical impact issues on customers and
Enhance data quality and integrity by focussing on classifications,
relationships and significance
Providing meaningful data to prove (or disprove!) folklore
Enable differentiation between symptoms and cause
> Systemic analysis is seen as the ‘cure all’ to support this process.
– Focus tends to be on immediate resolution by customer
facing staff - rather than broader analysis.
– Data collection tends to support individual resolution.
– Data input is not always seen as valuable by staff - the
problem is fixed so why record it?
– Due to the nature of information collected, analysis tends
to focus on broader issues rather than product or service.
– Lack of integration of complaints data with broader risk
Strategy into action
> Complaints and Compliance teams developed a joint project to address
deficiencies in systemic analysis.
> Purpose was to ensure that:
– staff understood why data is important
– ensuring better analysis of data captured
– closer working relationship on testing, analysis and response to
– Post implementation reviews
Strategy into action
> Complaints training to become mandatory compliance training for all
customer facing staff.
> Complaints and compliance teams review monthly extract of complaints
data -lag indicators for trend analysis.
> Appointment of systemic analysis manager for complaints data who works
closely with compliance staff.
> Information integration:
– trending and indexing data from BFSO database
– risk profiling information across products
– continuous improvement on capture tools and lead indicators.
NAB – Our approach
> Potential systemic issue identified - either through BFSO, CCMC or by own
> Business unit analysis of issue with compliance team to determine
breadth and significance.
> Once systemic issue confirmed:
– Regulator/complaints body engagement program and information
– Dedicated workstreams created to address fundamental issues
– Regular reporting and briefings to stakeholders (including ACA
– Post implementation review to identify lessons learned.
> Stop and Remedy
– short term fix (‘stop’ the problem) and long term remedies
> Quantify and Analyse
– Identify extent of the problem
– strategy for internal and external information (letters,
– principles and business rules
> ‘Future proofing’ systems through knowledge of actual and
> Better intelligence to identify trends of potential and actual
> Early warning of systemic issues through business understanding,
ownership and commitment.
> Focus on the symptoms rather than the causes, and understanding
addressing systemic issues is not a quick fix.
> Critical element is sustainability – ensuring that:
Ongoing measurement program is embedded in the
compliance function and supported by the business.
Monitoring of issues with reporting of systemic trends to
Data integrity reviewed and interrogated on a regular
Feedback loops to prevent reoccurrence developed,
monitored and reviewed.