Guidance for telcos: Complaints monitoring and analysis

Telcos are required to monitor and analyse complaints, identify systemic issues and problems, and prevent their recurrence to meet their obligations under the Telecommunications (Consumer Complaints Handling) Industry Standard 2018 (see s18). This guidance note should be read in conjunction with that Standard.

Telcos are required to establish processes, procedures and systems to identify systemic issues and problems and take action to prevent their recurrence. Actions taken by telcos to address systemic issues or frequent problems should be measurable, reportable and documented.

We recognise that telcos vary, in size, operations and governance, and processes and procedures will be tailored accordingly.

Our expectations – telcos need to:

• Analyse complaints to establish the underlying root cause(s).
• Identify systemic issues and frequently occurring problems.
• Take prompt action to address complaint issues, frequent problems or systemic issues.
• Develop and implement remediation plans to prevent systemic issues from recurring.
• Identify the person within their organisation with sufficient seniority to manage and be accountable for each initiative being actioned to address systemic or frequent issues.
• Monitor the actions being undertaken to address each systemic issue.
• Establish appropriate controls to measure and evaluate the effectiveness of actions taken against each identified issue, acknowledging that measures will vary depending on the issue.
• Document and report internally to the telco’s governance body (board, audit and risk committee, or similar) on complaint issues and actions taken to remediate.

Best practice – telcos should:

• Establish the frequency of the complaints analysis process, whether it be weekly, fortnightly, or monthly. Complaints need to be classified and analysed a minimum of once every 3 months (see s19(a)).
• Break down complaint categories to draw out the key complaint issues and identify those that could be systemic.
• Define what’s considered to be a systemic issue and establish how these issues will be flagged and handled.
• Document the approach to identifying and promptly handling systemic issues in internal policies and procedures.
• Nominate a person with sufficient seniority within the organisation who will have responsibility for managing and monitoring each initiative being actioned to address frequent issues, with clear reporting lines.
• Develop and implement remediation plans to address frequent issues.
• Adopt metrics alongside internal and external complaint numbers and trends, which are geared towards assessing the effectiveness of remedial actions and are specific to the complaint issue. For example, depending on the identified issue, additional metrics may be customer satisfaction, recurring inquiries or customer retention rates.
• Act on the results of these metrics and use them to measure and evaluate the effectiveness of any remedial actions. If the actions are not addressing the complaint issue, develop and apply a revised remediation plan.
• Review the internal reporting framework to ensure senior management and any internal governance body has visibility of the systemic issues identified, the remedial actions taken to address issues, and the outcomes.
• Maintain an up-to-date record or register of all systemic issues identified and actions taken. This systemic issues register should support the telco’s broader monitoring activities.

There is an overriding obligation on decision-makers within a telco to have clear oversight of the operation of the complaints-handling process. Business processes should include pathways for senior management and any internal governance body to have appropriate insight into consumer experiences.

Our expectations – telcos need to:

• Get approval of their complaints-handling process and network outage complaints-handling process from their most senior responsible executive. This person is also responsible for implementation and operation (see ss7(2) and 10A(2)).
• Document the relevant process and reporting lines for notifying senior management of recurring complaint issues. 
• Commit to effective complaints management, including fostering a culture where personnel handling consumer complaints are empowered to report potentially systemic issues.
• Maintain a fit-for-purpose complaints-management system.
• Review resourcing needs and allocate resources to identify systemic issues, make recommendations and implement measures to address and prevent their recurrence.

Best practice – telcos should:

• Evaluate their complaints-management system regularly.
• Assess how their processes demonstrate they are managing complaints effectively, with an emphasis on addressing systemic issues.
• Report regularly to any internal governance body on complaint issues, particularly systemic complaints.
• Review the resources made available to personnel who handle complaints and evaluate the adequacy and frequency of training to ensure personnel are equipped to identify and report potentially systemic issues.
• Revise resourcing if required, to implement measures to address frequent or systemic issues and monitor the actions being taken.
• Review and improve reporting practices, including how frequent issues are reported along with recommendations for next steps, and implement initiatives to address frequent, or systemic issues. 
• Establish the appropriate level of senior management involvement. 
• Document processes and reporting lines for notifying recurring issues to senior management and detail the level of senior management input if corrective action is required. For example, outline whether decisions on recommended next steps need to be discussed and approved by senior management.
• Require regular senior management review and sign-off on a systemic issues register.

How telcos must handle complaints – ACMA website information 

The Telecommunications (Consumer Complaints Handling) Industry Standard 2018

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Note: Telcos should seek their own advice about complying with their regulatory obligations.