Supporting the cross-cutting rules and four outcomes, a key element of the Consumer Duty is that firms can monitor and assess their customer outcomes. This is so they can confirm that their products and services are working as they and their customers would expect, and in compliance with the Duty.
Firms should be able to identify where groups of customers are receiving poor outcomes and rectify the issue, whilst also being able to evidence why they implemented the chosen solution and how this will improve outcomes for the group in question. If further monitoring suggests that the issue has not been resolved, the FCA would expect to see that alternative action has been taken and monitoring continued. Firms should also learn from their findings to understand what caused these problems, allowing them to act sooner in future or implement processes to prevent reoccurrence.
As with much of the Duty, the monitoring of outcomes is based on reasonableness, considering a firm’s size, nature and complexity of products and services, etc. As such, each firm will need to identify what data sources are suitable for them to be able to ensure that they are delivering good outcomes. Regardless, all firms will be required to provide evidence of their monitoring and any actions that may have been taken, if requested by the regulator.
There are many types of information that the FCA suggests firms may wish to use to monitor customer outcomes. These include:
- Customer retention and cancellation rates - Poor treatment may contribute to higher turnover.
- Behavioral insights – Customer interactions, drop-off rates, preferred communication methods.
- File reviews – Monitoring customer files and interactions e.g., call and emails, to check for errors and assess outcomes.
- Customer feedback – Identifying trends and areas for improvement.
- Number of complaints and root cause analysis – Analysing trends in the numbers of complaints for certain products or services and in-depth analysis to identify the cause, not just the symptoms.
- Allowing staff to give feedback honestly – Staff may notice areas of improvement for products and services, that clients have been reluctant to highlight.
A key component in the storage and analysis of much of this information is data archiving. Data archiving involves identifying inactive information and moving it into long-term storage so that it can be easily retrieved when necessary.
This can be particularly useful for monitoring outcomes as it allows firms to archive communications, whether emails, calls, webchats, social media etc., to capture and analyse customer interactions. It can also provide the opportunity to compare historical outcomes with recent ones, ensuring any required solutions have resolved identified issues.
Firms may wish to use physical storage for archiving, such as external hard drives stored in a secure location or they could use a cloud storage option which allows data to be stored on remote servers, accessed through the internet. Third-party archiving is also an option and may provide firms with additional security and peace of mind but can be limited on capacity.