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Channel Doctors - Blog

April’s Regulation & Compliance Update from the DMA’s Contact Centre Council

Each month Channel Doctors’ Steve Sullivan prepares a summary of all the news contact centre and customer experience professionals need on regulation and compliance for the Direct Marketing Association (’s Contact Centre Council.

April’s headlines include:

Bounty fined £400k for pre-GDPR data protection abuses
Pensions firmed fined £40k despite getting advice from specialist consultants and lawyers
Funeral plan firm fined for calling TPS numbers
Data cleanse leaves TPS file numbers 4m down vs 2018

Download the Update here:

DMA CC Council - Compliance Regulation Hub Update April 2019Download


Publish Date: April 17, 2019

March’s Regulation & Compliance Update from the DMA’s Contact Centre Council

Each month Channel Doctors’ Steve Sullivan prepares a summary of all the news contact centre and customer experience professionals need on regulation and compliance for the Direct Marketing Association (’s Contact Centre Council.

March’s headlines include:

  • Two ‘dawn raids’ of contact centres by the ICO
  • Fundraising Regulator doubles down on ‘naming & shaming’ of charities
  • The first ICO ‘GDPR’ fines may be a while away
  • Vote Leave fined £40k for sending illegal texts
  • PPI ‘robo-call’ company director banned
  • All about the Direct Marketing Commission

Download here: DMA CC Council - Compliance Regulation Hub Update March 2019_compressed



Publish Date: March 20, 2019

What’s happening to the UK’s ‘Middle Tier’ Outsourced Contact Centres?

The ‘middle-tier’ of the UK outsourced contact centre space is potentially precarious, squeezed between smaller niche providers and the global BPO (Business Process Outsourcing) firms. For many clients the ‘middle-tier’ offers a more flexible, focused delivery model than larger rivals, with the added reassurance of direct relationships with their suppliers’ leadership teams.

However, outsourcing can be hard business, typified by low margins and demanding clients. Today these challenges are compounded by increased customer and technology demands, which outsourcers need to be able to anticipate and meet in order to succeed.

The last 12 months has seen significant changes in the mid-market space – consolidation, business failure and new investments – which we reviewed in the infographic, below.

Middle-Tier CC Consolidation - Feb 2019

If you’re a current or potential client of a middle-tier provider and want to work through the implications of these changes – or you’re in the middle-tier and trying to decide where to head next – drop us a line



Publish Date: February 18, 2019

January’s Regulation Hub Update from the DMA’s Contact Centre Council

January’s Regulation Hub Update from the DMA’s Contact Centre Council

All the news contact centre and customer experience professionals need on regulation and compliance, prepared by Channel Doctors’ Steve Sullivan for the Direct Marketing Association (’s Contact Centre Council.


Publish Date: January 28, 2019

Could the 22% of CX Professional Leaders please stand up?

There are some fascinating numbers in the State of Customer Experience 2018: The Five Habits of Highly Effective CX Professionals, produced by Engage ( and Confirmit ( - and lots else, it’s a really useful document, full of great insight, research and ideas. However, I’m somehow unconvinced by its categorisation of 22% of “CX professionals” as Leaders.

Let me explain.

Firstly, I have a bit of a problem with the ‘professionalisation’ of customer experience. Of course there are particular tools, techniques and insights which are vital to improving customer experience, but fundamentally listening to customers doesn’t require the reserved membership or the equivalent of a medieval Guild. Practically anyone can do it and everyone in the organisation should be encouraged to contribute. Some of the best insights will be from the employees who spend all day dealing with customers in the field, on the shop-floor and in the contact centre.

Secondly, the ‘Leader’ category described in the State of Customer Experience 2018 is restricted to those respondents who could see “significant increase in budget in the next 12 months (9 or 10 on a 0-10 scale)”. Sorry, but I just don’t buy this! I’m not naive and I understand that in modern, complex organisations investment in the right techniques and technologies are needed as well as a - simple sounding; hard to achieve - willingness to try and understand what the customer wants. But empire and budget-building are no guarantee of anything. Surely better an unfunded and authentic customer orientation than a vast programme of journey mapping, C-SAT, CES, CX and NPS scoring that goes nowhere (and we’ve all seen just those sort of programmes in action)?

Fundamentally, achieving a great customer experience is very hard work for a variety of reasons. Although being given a bigger budget might be a great help (and presumably at least shows you’ve got some of the necessary support from the Board level) of itself it won’t achieve a thing - except make your search for those elusive sources of evidence of the (undoubted) relationship between customer experience and business performance even more urgent!

So, if – despite my reservations - you aspire to be a leading “CX Professional” but have little or no budget, then don’t despair! Here’s a list of 7 things you can do with no budget, except maybe the cost of a few train fares:

1. Set out on a road trip and talk to colleagues (and your suppliers’ and business partners’ employees) who are in contact with customers
2. Go online and take some customer journeys – make some calls, start a chat, follow the Contact Us directions and see what happens
3. Identify some real customers (at random or on the basis of feedback or complaints), make contact, tell them what you’re doing and ask to talk to them
4. Go the contact centre and listen to calls, read emails and chats and write some notes
5. Find out what groups within your organisation are developing new propositions, contact channels, offers and find out if they have a ‘customer representative’ on board. If they haven’t, find one. Quick!
6. Make a first draft of your CX priorities and changes
7. And be prepared to adjust it as you go – your organisation isn’t static and neither are your customers


Publish Date: January 11, 2019

December’s Regulation Hub Update for the DMA’s Contact Centre Council

December’s Regulation Hub Update for the DMA’s Contact Centre Council

December’s round-up of Regulation and Compliance news for UK contact centres.

This month’s headlines include…

  • Individual company directors, as well as the corporate entities, will now be liable for PECR fines of up to £500,000
  • The Incredible shrinking TPS: 12% smaller already this year & counting
  • PCI DSS Guidelines for Phone Payments have been released – and it’s bad news for contact centres relying on ‘pause & resume’ techniques to take themselves ‘out of scope’
  • Only 5 days left to share your views on a new Code of Practice for Direct Marketing with the ICO
  • The ICO has fined two companies a total of £250,000 for making unsolicited marketing calls to numbers on the TPS – and fined a third firm £200,000 for sending over 14 million texts in breach of the PECR rules
  • The Fundraising Regulator is to start ‘naming and shaming’ charities under investigation from 2019
  • 118 Directory Enquiries providers’ prices have been capped by Ofcom

And hidden away in the Update, a small Christmas Competition!

DMA CC Council - Compliance Regulation Hub Update December 2018-ilovepdf-compressed


Publish Date: December 19, 2018

November’s Regulation Hub Update for the DMA’s Contact Centre Council

DMACCCouncil-Compliance RegulationHubUpdate-November2018-ilovepdf-compressed

A summary of everything that’s happening in the world of regulation and compliance for UK contact centres - enforcement, fines, guidance, consultations and rumours from the ICO, Ofcom, the PSA, central government, PCI Security Standards Council, the Fundraising Regulator, the Direct Marketing Association and more…



Publish Date: November 19, 2018

GDPR: So, nobody died, but…

GDPR: So, nobody died, but…

I’m writing this on 24th May 2018. The day after the new Data Protection Act received its Royal Assent and the day before the day we’ve all been waiting for, GDPR implementation day, 25th May.

Don’t 24 weeks fly by when you’re having GDPR fun?

This week I was intending to provide another bite-sized piece of advice to help you on your way to becoming GDPR compliant, especially from a customer experience perspective. However, as the nation has been floundering under a growing tsunami of last-minute ‘re-permission’ or ‘re-consent’ emails from companies, charities, arts and community organisations for the past few days, I can’t avoid looking at that phenomenon.

An organisation’s legal ability to process – or continue to process – personal data is always situational. It’s subject to both the organisation and its data subjects’ specific context – and decisions the organisation must make about how it sees its role, in order to define its legal basis for handling personal data (i.e. consent, legitimate interests, performance of a contract, etc). That’s all a bit laborious to go into just now (though have a look at, but suffice to say I think most of the ‘GDPR’ emails I’ve received in the past week were unnecessary – and potentially very damaging to the organisation sending them.

Some observations:

  • The best time to re-engage with a prospect or customer is when they’re already interacting with or speaking to you
  • The worst time is probably when scores of other organisations are emailing them about some legalistic gibberish they’ve never heard of. My guess is that email open rates have plunged to their lowest ever level, this week
  • If you have now just lost over 80% of your marketing data (a reasonable guess, for most organisations) after telling your customers that you will rely on their explicit consent to stay in touch with them, then even if you were to justify to yourselves a change in the legal basis to, say, legitimate interests [not impossible, but very difficult] you’re likely to find that’s a hard sell to the customers you just told wouldn’t hear from you again unless they opted in before 25th May!
  • If you weren’t engaging usefully with prospects and customers then the loss of all or most of your database may prove to be a positive change, leading to a refreshed, customer-led approach to engagement
  • Conversely, there are those organisations that have all of a sudden, with appalling timing, pushed their customers and prospects into making a binary decision devoid of any relationship context. We should keep a sense of perspective; no-one’s died – but we may have just witnessed a mass assisted suicide of marketing data

Keep up the good work and the best of luck in the post-GDPR world.


Publish Date: May 25, 2018

Will the GDPR make me a millionaire?

Will the GDPR make me a millionaire?

The implementation date for the GDPR is only a week away. If you have been following this series of weekly ‘Just One Thing This Week’ blogs then we hope you’re fairly well prepared - or at least know what you still need to work on.

Anyway, give yourself a minor diversion and read about my Cunning Plan…

I’ve been doing some sums.

The Office for National Statistics ( reckons there are c.47,000 UK enterprises that employ 50 or more people. Let’s use that as a very rough proxy for the number of UK firms engaging in some sort of formal marketing and customer management/experience activities.

The ICO tell us ( that in 2016/17 they imposed financial penalties totalling £1.9m on just 23 organisations for Privacy & Electronic Communications Regulations (PECR) infringements. The scope, volume and size of penalties imposed on errant businesses by the ICO are all likely to increase in the future (but don’t hold your breath for a 4% of global turnover fine). So, let’s imagine that next year the ICO’s fines total £5m.

In which case if each of those companies paid somebody – me, for instance – a £1000 “GDPR insurance premium” annually I could guarantee to pay any fines. And pocket c.£45m for my trouble. Wouldn’t that be a lot less hassle all-round for everybody?

The odds of the ICO coming knocking and going on to fine an organisation are infinitesimally small (Ok, less than 0.05% according to my crude calculations) so why don’t we all just insure against the risk?

Well, I suppose

  • I’d need someone to underwrite the risk
  • not every company would be willing to pay
  • and no doubt some so-called expert will point out that you can’t insure against the risks of illegal activity

In fact that last point may be the crucial flaw in my genius plan. Shame.

But if it would work, wouldn’t that be a great solution to the GDPR problem?

No, not really.

  • Even without the GDPR, consumers are becoming aware of the treatment of their personal data and their rights like never before
  • Your customer-facing colleagues need to be equipped with the knowledge and tools to navigate this new world
  • Data-driven marketing is changing radically - established techniques may not work in the future
  • The ICO doesn’t just impose fines. Their enforcement actions bring potentially considerable reputation damage – and in future they are more likely to demand organisations stop certain types of data processing
  • Data transparency will entail a cultural shift for most organisations – that’s never just a quick fix

So, I won’t be a millionaire by 2019 and we all still have plenty to do


Publish Date: May 18, 2018

GDPR week #22 - It’s for life, not just 25th May

GDPR week #22 - It’s for life, not just 25th May

We looked at what you need to do help your frontline teams get prepared the GDPR and new Data Protection Act a few weeks ago ( So, by now you will ideally have agreed on an approach and the content you will use to inform and up-skill those teams - the public face of your organisation’s customer experience.

This may have entailed addressing issues around

  • how you acquire, process and retain personal data, or
  • how to recognise and fulfil customers’ data rights

for the first time. And even if training for data protection isn’t a new task, you are probably having to consider additional right, additional data protection-related customer contacts and significantly changed processes.

So, job done? Well, no, not really.

Lots of organisations are focused on the magical 25th May date. But that’s the starting point not the finishing line. Customer data protection rights, responsibilities and perceptions are changing radically - and for many organisations that will require a real culture change. A one-off training session won’t deliver that. The benefits of a flexible and intelligent learning management solution or platform are well known. These tools can give you increased flexibility to develop and refresh content, to assess learning and understanding, ensure consistency across the organisation, include different media (show people what to do on the CRM system when they receive a Subject Access Request), allow your colleagues to self-service their learning and so on.

If you haven’t investigated the benefits of investing in a learning management solution, maybe now’s the time to do so.


Publish Date: May 11, 2018

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