Writing Sample # 4

This is an excerpt from a report that assessed Knowledge Management Services. This report was presented to the Executive.

Public Inquiries and Complaint Handling 

The results of our assessment show that Inquiries is fulfilling its mandate of providing knowledgeable first-contact for the Commission. The Inquiries Group provides a consistent and high level of service, which bolsters the confidence of external stakeholders.

Most staff see our public inquiries service as essential or valuable. Only 7% of staff consider it a nice-to-have or unnecessary function. The Inquiries Group responds to general inquiries from the public and complaints about the regulated community. We triage calls, forwarding 30-35% on to subject-matter experts, when callers require interpretation of our rules or personal guidance. Inquiries helps our high-priced talent use their time more efficiently. 

The success factors of Inquiries are:
  • Knowledge
  • Speed
  • Efficiency
  • Helpfulness/customer service
  • Collaboration with staff

We spend 34% of our time handling complaints and 66% responding to general inquiries, with our time split equally between investor and industry callers.

Public Information Service

We receive inquiries through many channels. Telephone inquiries still dominate over all other forms of inquiry.  Although the amount of email inquiries has not increased, we are receiving more complaints in writing, which require lengthy and detailed responses. Email contacts often require several follow-ups to resolve the issue since virtual communications are less effective for conducting a “reference interview” to determine the person’s real needs.

We try to respond to emails within one business day, which is sometimes difficult to achieve, especially when Donna Bobbett or Stephanie Butler is absent. Because so many of our emails are complaints, we are not able to share this responsibility equally with the whole team. A long-term strategy is to train more Inquiries staff to handle complaints. In the short term, we should train all Inquiries staff to triage the emails and make sure that everyone is taking part. The general emails that require research provide opportunities for everyone to obtain new knowledge without the time pressures of telephone service.

During our assessment, we sent follow-up surveys to those clients who used our services over a two-week period. Most clients completed the survey online. We called back those callers who did not want to use the web survey and asked the same questions over the phone. Altogether, we received 46 responses.

From the survey, we learned that respondents are overall very satisfied or satisfied with their interaction with the Inquiries Group.  Specific measurements included timeliness of response, whether or not the BCSC was the appropriate agency for the inquiry/complaint, the overall helpfulness of employees, and a measure of how knowledgeable BCSC staff are when handling inquiries/complaints. BCSC also rated very highly in our ability to answer all of the questions or concerns posed by our clients. Correlating with these positive results, nearly all survey respondents cited that they would contact Inquiries again for assistance.

Filing Assistance

Assisting insiders and filing agents with SEDI (Insider) filings is one of the most common and time-consuming types of telephone calls we receive; this topic represents 13% of our calls.  These calls can range from simple questions to complex filings that can take well over half an hour to work through. 

Although CDS receives technical support calls from SEDI users (ie: password resets), CDS will forward any call they receive regarding filing assistance to BCSC Inquiries.  We also receive calls from other jurisdictions who consider BCSC to be the primary filing support for SEDI insiders.

The majority of filers find SEDI to be complicated and non-intuitive and they require personal assistance to file successfully. Because a re-write of the system is several years away, we feel that providing online tutorials for common filing questions would help us provide support more efficiently.  It makes sense that assistance should be available 24/7 to support users at any time. We confirmed with SLAC and SPAC advisors that online training would be a welcome addition. A video format would be ideal so filers could follow along and use the visuals to guide them. The tutorial should also provide an option for filers to “jump to” their specific filing question for efficiency.

After SEDI filing questions, the next most common filing questions received by Inquiries are regarding SEDAR, which reporting issuers use to file their continuous disclosure.  Inquiries has a knowledge gap when it comes to SEDAR filings and we escalate most of the more complex SEDAR calls to the Financial and Insider Reporting hunt group for further assistance.  Unlike SEDI, which has no centralized user support, CDS has customer service managers who provide filing assistance; there is a person dedicated to helping SEDAR members in western Canada. Financial Reporting does not have confidence that CDS can provide adequate assistance, although the service CDS provides, as described by their customer service manager, seems like it would resolve many of our calls.

 Support for BCSC Staff

The Inquiries Group acts as a filter between external stakeholders and other Commission employees. Inquiries staff “weed out” general inquiries at the source and only escalate complex or interpretive questions to employees in other divisions. 

We created hunt groups to share escalated calls equally amongst individuals with similar expertise. We evaluated and improved the hunt group system when we installed our new phone system. The system was changed to make call distribution fairer and to make it harder for individuals to stay on ‘make busy’ for lengthy periods. We also added voicemail boxes for groups. All these changes have been beneficial for individuals in the groups and their callers.

As staff come and go, adding new staff to hunt groups can be problematic. They are not added immediately, since new staff don’t have the knowledge yet to handle the calls. We depend on managers to tell us when to add new members, but this rarely happens.

Staff satisfaction with our inquiries service is high. It has been challenging to lose some of our expertise through staff retirements and leave; we continue to concentrate on knowledge transfer and training. Several people from KMS did job shadowing with subject-matter experts this year and we now arrange briefings with each department for new staff.

Inquiries employees need ongoing and updated information about the securities landscape to excel at their jobs.  We need to approach other Commission divisions on a regular basis to gain an understanding of any particular trends or upcoming policies that may affect the types of questions received by Inquiries. This communication should continue to be a two-way street; other divisions should also utilize us to bring information forward from the public.  C&E, for example, approaches Inquiries for their opinion before posting certain items on the InvestRight website to ensure that it will meet the needs of the investing public.

 A distinct area of improvement between the 2007 and 2008/2009 surveys is our level of professionalism. This upward trend speaks to the high level of customer service that Inquiries provides to all stakeholders, regardless of call escalation.

In order to provide feedback on incorrectly escalated calls, it is important to know where the escalation came from. We can improve by letting staff know that the call comes from us and spending the time to explain our steps to date if we have spent a significant amount of time with the caller.

Processes and Procedures

The Inquiries Group naturally shares information informally on a daily basis but there are training gaps within the team. With an upcoming maternity leave and another employee planning for retirement, this training should become a priority. We should also continue to develop our procedure manuals to ensure that they contain information every new employee needs to know and understand in order to do their job. We also need more documentation about particular areas of specialization within the Commission to understand “who does what” in each division.

We manage frequently asked questions for the public website and StaffWeb. In addition, we maintain some information sheets for general enquiries and classify our email questions and answers in subject folders so we can reuse them. All of these sources form a knowledge base for Inquiries staff, but none of them is particularly suitable for quick and convenient access. Creating a better archive of questions and answers would also provide a training resource for new staff.

We use a call tracking system to log every inquiry and complaint received.  Call tracking documents the type of inquiry, the demographic of the caller and if the call was directly internally or externally (if applicable).  Although call tracking is useful for identifying trends in subject matter and activity levels, we should update it more frequently to track new subjects and eliminate redundant or obsolete categories. Our new phone system also provides statistical reports, although we are having technical problems accessing useful information. We need to establish and monitor additional service standards including:

  • Average amount of time spent on calls;
  • Amount of time each employee of Inquiries is available to take phone calls;
  • Average wait time for callers.
 In addition, the new case management system will allow us to create reports. We will need to choose the best methods for recording information to reduce redundant data entry and keep our processes efficient.

Complaint Intake

KMS is responsible for interacting with complainants and documenting their complaint. Our responsibilities include:

  • Eliciting and recording relevant information and forwarding it to staff, in enforcement or compliance, who are empowered to assess it and take appropriate action, if warranted. We document our complaints in SCAN and we will use the new Case Management System when it is developed. We do not investigate or assess the complaint beyond trying to ascertain that there is some thread of legitimacy to the inquiry and the complainant is not out of time
  • Providing customer service: encouraging the complaint, empathizing, advising of additional options of redress. We set realistic expectations about the steps the Commission may take with the complaint but we do not tell callers what was done or what conclusions staff have come to.
  • Making referrals for complaints outside our jurisdiction.
  • Sharing enforcement-related information with other regulators. These are generally routine inquiries related to licensing and registration from agencies such as FICOM and the MFDA.
 Our internal stakeholders and our clients regard our service highly. Success factors include:

  • Patience/empathy/customer service.
  • Knowledge.
  • Judgment.
  • Teamwork.
 We integrate complaint handling into our public inquiries service. Sometimes individuals call to find out about our rules, and we discover potential misconduct by a market participant that we can document. Sometimes individuals call to complain about activities that are allowable under our rules, and we provide general information. When the service was transferred to KMS in 2002, we served only one department, following the processes and procedures created by the Intelligence and Assessment department. Now we also serve the compliance departments in Corporate Finance and Capital Markets Regulation and our processes have evolved to incorporate their needs. A key service is to alert individuals to specific kinds of complaints, such as those involving OTCBB companies or short selling. We keep statistics of products tracked by the ERIT team and feed ideas to our investor education team to address complainants’ issues. A key strategy for the Commission is to increase complaints and our activities have increased. Using the Inquiries team to handle complaints allows us to increase resources to handle more complaints during media promotions. This is successful only when we know about promotions well in advance so that we can ensure a full team to respond to the increase in calls.

In our follow-up survey with clients, we received feedback specifically on complaint handling in KMS. Most callers were satisfied with the service they received. Overall, our clients understand the complaint process and the role of the BCSC in responding to their complaint.

There is some room for improvement in explaining the process and our mandate and jurisdiction. Sometimes this is difficult, but important, news to deliver. Our goal is to help complainants develop reasonable expectations about our process and powers.
 
The communication between KMS and Intelligence and Assessment and Corporate Finance Compliance is typically one-way, with us delivering information to them. We document complaints in “enquiry logs” and send them on to enforcement and compliance staff, receiving no feedback regarding the outcome of the complaint. The new case management system will provide better documentation, which will give us more information to manage follow-up calls from complainants. We feel that opening the lines of communication between our enforcement division, compliance departments, and Inquiries Group would benefit everyone. By knowing more about the priorities, activities, and methods of our internal stakeholders, we can be more proactive in addressing their needs. Working more closely as a team will provide important learning opportunities for KMS staff. Most of our expert knowledge about enforcement and compliance relies on Donna Bobbett, who gained her expertise during her tenure as an investigator. We will need to find new ways to gain expertise when she retires, likely in 2010.

Complaints about our complaint intake function usually focus on the lack of feedback complainants receive after their initial interaction with Inquiries. Complainants express frustration when they provide information and details regarding their complaint but do not receive any information in return.  They express distrust regarding the complaint process and some are sceptical that the complaint goes up the chain of command. Negative publicity is feeding investor discontent and eroding trust. If this attitude prevails, it could lead to a drop in complaints if individuals fail to see the value in reporting their issues to the Commission. We will be working to improve this with our internal partners as an objective in the Strategy 3.2 Operating Plan:

Recommendations for public inquiries and complaint handling

  • Adapt our processes to ensure consistent and timely feedback for complainants and explore services and practices to support victims involved in our enforcement process.
  • Train all Inquiries staff to “triage” emails and create daily targets for everyone, to spread the responsibility more evenly throughout the team and create learning opportunities.
  • Follow up with managers three months after a new employee begins to add them to a hunt group. Provide training to all new hunt group members.
  • Approach other divisions on a regular basis to gain an understanding of any particular trends or upcoming policies that may affect the types of questions we receive. Explore whether regular meetings would be a successful mechanism for sharing and learning.
  • Create online tutorials for common SEDI inquiries. Work with C&E and IS to decide on the best format and technology.
  • Work with C&E, Enforcement, and CF Compliance to improve our procedures for dealing with victims of fraud to increase trust and encourage more complaints. We anticipate creating checklists to improve how we explain the complaint process and describe what we can and can’t do (using less legalistic language.) We will seek more knowledge from the victim services community and share this knowledge with others. We will also work with others to determine when and how the BCSC will follow up with complainants.
  • Develop a system for handling SEDAR inquiries with CF Financial and Insider Reporting. We would like to refer SEDAR calls to CDS since the CSA already pays for this support. It is important that we monitor the impacts of this approach, to ensure that BC filers continue to be well-served. We anticipate that we will need additional training to handle the kinds of calls that are not appropriate for CDS, such as information about filing requirements.
  • Review the call-tracking form quarterly to ensure that we are capturing the latest securities trends removing obsolete categories and subjects. Ensure that everyone understands how to use the system to track customer service complaints and their resolution.
  •  Continue to develop procedure manuals to contain all the information that new Inquiries employees need to know and understand in order to do their job. We will also ask managers to create more documentation about particular areas of specialization within the Commission, highlighting employees who have expertise in a particular securities issue. We will consider whether adding information to employee profiles on StaffWeb is an efficient way to capture this information. Bringing together the links to commonly utilized and referenced materials and organizations is also a priority.  We will make updates to our documentation as information changes, and review manuals each year to ensure that they are comprehensive and accurate.
  • Establish additional service standards for Inquiries and monitor using Genesis, the telephone reporting system. Continue to work with IS to get the system set up to report on our queues, positions, and agents.
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