Complaints Analysis: Have you completed your TCP Code QCA?

TCP Code complaints analysisBy last 1 December, every Australian telco should have completed its first QCA under the 2012 TCP Code. If you don’t know what we’re talking about…


What’s a QCA?

It’s not an official TCP Code term, but it’s the shorthand name we give to the Code’s requirement that:

TCP Code complaints analysisSuppliers must classify and analyse complaints at least every 3 months to identify recurring problems and issues including areas of non‐compliance with this Code.

Since the Code launched on 1 September 2012, every telco should have completed a classification & analysis by the start of December.

How do you do a QCA?

No detailed timetable

There’s no detailed timetable. In a perfect world, complaint classification and analysis would be a continuous process, happening in nearly real time. For large providers, that’s what they should be shooting at. The smaller you are, and the fewer complaints you receive, the more of a ‘once every few weeks’ exercise it can afford to be.  But the Code’s base requirement is for complaints classification and analysis to be carried out at least once every three months.

Outcomes-based process

The TCP Code doesn’t specify a process, but an outcome. The idea is to identify trends, and to use that information to address problems internally before TIO is knocking on the door. That requires four inputs.

First, you need to define ‘complaints’ appropriately

Some providers think that all complaints are being captured, because TIO provides a list of them. They have missed the mark by a long way. TIO complaints represent a fraction of total customer issues, and if that’s all you’re measuring then you have no chance of winning any customer satisfaction awards. Besides, issues typically take from one to five months to reach TIO, so managing a telco by relying on TIO stats is like driving only by your rear vision mirror.

Others agree that ‘complaints’ also includes formal customer issues logged through a complaints email address, phone number or web portal. They’re right, but that’s still not enough. Here’s why.

Here’s how the TCP Code defines a ‘Complaint’

Complaint means an expression of dissatisfaction made to a Supplier in relation to its Telecommunications Products or the complaints handling process itself, where a response or Resolution is explicitly or implicitly expected by the Consumer. An initial call to a provider to request a service or information or to request support is not necessarily a Complaint. An initial call to report a fault or service difficulty is not a Complaint. However, if a Customer advises that they want this initial call treated as a Complaint, the Supplier will also treat this initial call as a Complaint. If a Supplier is uncertain, a Supplier must ask a Customer if they wish to make a Complaint and must rely on the Customer’s response.

That covers a lot more than a formal complaint through the complaints portal, and a very lot more than just ‘TIO complaints’. If you and your people don’t have a good understanding of what counts as a complaint, you’re behind the complaints eight ball already.

Second, you need to capture them

That in turn has three elements. You need a system for recording complaints. For a micro-provider that might mean a spreadsheet. The larger you are, the more capable your complaints system must be. And your people need to be trained to be alert to those ‘expressions of dissatisfaction’ the TCP Code talks about, and when and how to record them in the system. And you and your people need to be enthusiastic about actually doing that. The organisation needs to regard complaints data as a key success input.

Third, you need to classify them

Classification makes raw data useful. How you categorise, tag and index complaints information determines how well you can achieve the TCP Code’s aim of identifying recurring issues. supports careful use of TIO’s keyword schema within telco complaints systems, not only because it is pretty well though out but because it lets a telco see its complaints profile in a way similar to TIO … except weeks or months sooner.

Fourth, you need to look at the data with care

A complaints recording system with comprehensive input, apt classification and powerful reporting capability is essential but there’s one more necessary ingredient: Someone who’s serious about understanding what the information can tell them has to spend time analysing it. If you want to stare at a screen and see nothing of much significance, that’s what you’ll see. If the real information that lies within the data is of vital concern to you, a well-designed system will pay huge dividends.

So what do your October/November/December complaints tell you?

If you haven’t teased  out the valuable information that so often lies within complaints data, do yourself a favour.  Whether you view complaints analysis as smart business strategy or just a chore, the TCP Code expects you to give it regular, active attention.


About Peter Moon

A telco lawyer with a truckload of experience
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