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Business Continuity and the FCA-How reasonable is reasonable

The word ‘reasonable’ can cause an unreasonable amount of debate.

A quick informal poll of your friends and colleagues is all that’s needed to reveal a wide spectrum of what ‘reasonable’ means in almost any context. It is not a word with a universal definition.

Unfortunately, it’s a word that insurers and their contact centres need to grapple with when planning business continuity. The FCA Handbook demands that financial services companies, including insurers, must implement reasonable measures to maintain continuity of all core systems in the face of loss or failure of resources (including people and technology), loss of information, and even external events such as vandalism or acts of God. This applies in particular to the customer’s ability to make telephone contact with the insurer – making call centre business continuity an essential part of financial services’ planning.

The handbook goes on to give a bit more detail on what it means by ‘reasonable’, that it depends on the nature, scale and complexity of the business and the volume and size of transactions, but it remains somewhat vague. What reasonable means in one situation may be far from adequate in another. But by understanding best practice in related fields, a lead can be followed.

Example one – international healthcare

The provision of international healthcare insurance can often be literally a matter of life or death. People rely on it when in the direst of circumstances – often in countries where treatment is not provided on a universal basis or where the necessary standard is not widely available. If a contact centre that processes claims and authorises treatments cannot do so in a timely manner then that could have dire consequences.

So in this real-world example of ours, the nature of the business, as per the Handbook’s criteria, meant that ‘reasonable’ measures entailed routing of calls such that if the primary connectivity fails or call centre locations can’t be accessed, then the business’s ability to keep answering customers’ phone calls isn’t interrupted. No break in service and business continues as normal, seamlessly.

Example two – replacement key cover

Replacement key service providers are also commonly regulated by the FCA. For high street stores and other similar businesses, being locked out of their own stores could mean a substantial loss of revenue.

In a similar way to the healthcare example above, the call management solution deployed allows calls to either be routed to a back-up third party call centre or re-routed into the building through alternative connectivity. The difference here is that nature and scale of the business demanded a rapid failover option, but short delays (measured in minutes) were acceptable.

Example three – golf cover

In the previous examples, reasonable business continuity is something that almost cannot be overdone.

In the case of an insurer that specialises in covering golf equipment, the demands are somewhat different. The provision of replacement golf equipment, even if you are an extremely keen golfer, does not demand such time-sensitive support plans as healthcare insurance. There is however, still a need to provide ‘reasonable’ business continuity, as demanded by the FCA Handbook. In this case, the insurer prepared for the worst with a system that would play a recorded message to customers who could not reach the contact centre, with the ability to leave a voicemail which is then emailed to the support team for them to call the customer back.

Striking a balance

It’s tempting to use the words ‘common sense’ to describe the best approach to business continuity and contact centres, but those are actually dangerous words. Common sense suggests that the right approach is easy and obvious, but this is not the case. The right balance needs to be struck between the needs of the business and the needs of the customer.

The word ‘reasonable’ places an expectation not just on the business, but on the customer too. It’s not just about what is reasonable to provide, but what is reasonable to expect. Over-provisioning for business continuity risks wasting investment time and money on backup systems that, with luck, will never be required – time and money better spent elsewhere.

There is no one-size-fits all solution to contact centre business continuity in the financial services industry. What is reasonable depends on your business and, crucially, what is at risk if you are unreachable.


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