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							  Identifying Systemic Issues and
    Improving Customer Service

Annette Donselaar   ASM BA BCom MComLaw LLM DFP Grad Dip Compliance AACI


     Head of Australian Region Compliance
Agenda
> 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
  occur.

> 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
           the organisation

          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
> Systemic analysis is seen as the ‘cure all’ to support this process.
  However …

       – 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
         events.
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
          data collected

        – 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
    analysis.

>   Business unit analysis of issue with compliance team to determine
    breadth and significance.

>   Once systemic issue confirmed:

         – Regulator/complaints body engagement program and information
           determined

         – Dedicated workstreams created to address fundamental issues

         – Regular reporting and briefings to stakeholders (including ACA
           where appropriate)

         – Post implementation review to identify lessons learned.
Workstreams
> Stop and Remedy

      – short term fix (‘stop’ the problem) and long term remedies

> Quantify and Analyse

      – Identify extent of the problem

> Communication

      – strategy for internal and external information (letters,
        adverts, internet)

> Compensation

      – principles and business rules
Benefits
> ‘Future proofing’ systems through knowledge of actual and
  potential breakdowns.

> Better intelligence to identify trends of potential and actual
  failures.

> 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.
Ongoing Maintenance
> 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
          senior management.

         Data integrity reviewed and interrogated on a regular
          basis.

         Feedback loops to prevent reoccurrence developed,
          monitored and reviewed.