April 1999

New Guidelines For Predictive Dialer Use

BY MICHAEL MCKINLAY, SYTEL LIMITED

[Go to table of predictive dialer behaviors and guidelines.]

The telemarketing guidelines for predictive dialers announced by the U.S. Direct Marketing Association (DMA) in January 1999 represent a major step forward for outbound activities in the U.S., and indeed the world, by sending a clear signal that high levels of nuisance calls will no longer be tolerated.

1) Vendor Vs. User Responsibility. Perhaps the most significant aspect of the guidelines is that the responsibility for implementing them falls almost entirely on users, as opposed to vendors. This is not totally unexpected since, given the current lack of agreed standards, the alternative would be to oblige vendors to ship different versions of their software, depending on what dialing guidelines a user was expected to observe. For example, it is not just an issue of DMA members vs. non-DMA members in the U.S., but of different practices among countries to which vendors ship. Well, that is the argument for now.

2) Nuisance Calls And Abandoned Calls. The heart of the guidelines are the stringent limits the DMA has set on nuisance calls. Vendors and users alike talk about both nuisance calls and abandoned calls as the things dialers do, in seeking performance improvements. They are not the same; abandoned calls being just a subset of nuisance calls. What the guidelines set out to do primarily, and admirably, is not just to limit abandoned calls, but to curtail nuisance practices that dialers have resorted to in the past, specifically what we refer to in the table as "predictive hang ups" and "call delays." These are practices that dialers have indulged in to gain extra productivity, whilst avoiding having to hang up on a live party and declare an abandoned call.

3) Impact On Nuisance Calls And Productivity. Sytel recently conducted some research in the U.S. to determine the current level of nuisance calls. The sample size was small and hence open to significant variance. Nevertheless, our results suggested that for every 100 live outbound calls made to consumers in the U.S., there might be approximately 50 nuisance calls of all kinds.

If this is true, then effective implementation of the guidelines in the U.S. could result in at least a tenfold reduction in nuisance calls. Given that predictive performance and the level of nuisance calls are clearly linked, how can it be that such a large reduction in nuisance calls would leave much room at all for achieving performance gains from predictive dialing? The response is:

1. There is a law of diminishing returns at work in predictive dialing, in that the more nuisance calls that are made (of all kinds), the less the additional benefit in terms of higher agent talk time per hour or lower wait times between calls.
2. It is quite likely that the way some dialers are being used means that nuisance calls do little for productivity, meaning that a reduction in them may not be noticed.

Although probably unintended, the guidelines make dialer efficiency a real issue. So expect to see a lot more serious discussion in the future on what's good (and bad!) in predictive dialer design.

4) Future Impact. Outside the U.S., the U.K. led the way five years ago with its code of practice, and several other countries have followed suit (e.g., South Africa). Many countries have yet to address these issues, so don't be surprised to see the U.S. guidelines providing a model for widespread adoption internationally. If and when that happens, expect the onus of compliance to fall squarely upon vendors. Otherwise, if users are free to make their own choices, then some, unwittingly or otherwise, may choose less rigorous standards than those recommended in the guidelines.

The DMA has made a bold move, and the outbound market in the U.S. and elsewhere can only benefit if the beachhead of these guidelines is both sustained and, in due course, extended.

Michael McKinlay is the managing director of Sytel Limited, a U.K. company which specializes in outbound software and supplies its soft predictive algorithms to some of the world's leading call center vendors. Sytel has campaigned consistently in all major markets for self-regulation of dialers and was a key adviser to the U.S. DMA in the formulation of its guidelines.

There will be some concern about the limit put on call delays due to the time required to perform answering machine detection. Forget the claims you hear for high detection levels in several hundreds of milliseconds. The fact is that two seconds from the time the line goes offhook will be tough for some dialers performing answering machine detection, as opposed to other kinds of call-progress detection. Here are four reasons why users may want to forgo this kind of detection and hence be sure to comply with the call delay rule.

• Predictive dialers are increasingly used for marketing campaigns, away from their traditional homebase of debt collection, where concern for caller reaction was not always high. Today in the U.S., many consumers simply hang up when they know a dialer is doing call progress analysis on them to determine whether or not they are an answering machine. Or their blood pressure rises if the answering machine detection is slow, and the agent is then in for a difficult call.
  
  
• The agent misses the first "hello" and perhaps the second as well.
  
  
• If the speed of detection is increased to avoid these problems, then it is pretty certain that some live calls will be mistaken for answering machines and dropped.
  
  
• If the agent does the detection, then there is the scope to leave a personalized message.

For users worried about the impact on productivity, measured as minutes of talk time per agent hour, it is probably a lot less than you think.