Martin EllinghamMartin EllinghamDecember 6, 2019


As we’re all aware, PPI represents the largest consumer mis-selling scandal this country has seen.

UK lenders collectively expect PPI to cost them close to £50 billion in total, having already paid out over £48 billion in compensation and admin by June 2019. But what now the PPI claims deadline has passed?

We can be certain that the massive claims management industry that sprung out of the PPI scandal – an industry that currently employs in the region of 20,000 people – won’t be going anywhere any time soon, but it does mean that the Claims Management Companies (CMCs) will be actively seeking new targets, something that financial services businesses are extremely aware of.

One potential issue for CMCs to pursue, and a much-discussed topic at the moment, is that of customer vulnerability – in particular how financial services businesses are ensuring the appropriate levels of not only service but care for vulnerable customers. Such is its importance that the FCA has made it one of the central themes of its business plan for 2019/20.

Underpinning this focus by the FCA is the idea that firms aren’t taking vulnerability seriously enough. However, as yet, outside of their own best practice framework, there are no set guidelines for businesses to follow when it comes to dealing with vulnerable customers.

Although vulnerability as a whole can be hard to define, harder to legislate for, and even harder still to identify, many financial services businesses are taking the opportunity to review their current processes. Aside from instilling best practice across the business, for many, it’s an attempt to pre-empt any regulatory requirements that the FCA could well introduce, not to mention helping to build a robust defence should the CMCs try to pursue vulnerability as their next source of income.

A challenging task

The main challenge faced by financial services businesses is identifying vulnerable customers in the first instance. For example, in the case of a disability, not all disabilities are obvious. Also, it may be that customers don’t realise they’re vulnerable, or even if they do, they’re loath to self-identify.

Others may be experiencing transient vulnerability, perhaps as a result of a major life event or upheaval, something that hasn’t been evident before and won’t continue to render them vulnerable in the future, but for the here and now, is a real issue for that individual. Not only does this make it hard for businesses to spot vulnerable customers, but it makes it nigh-on impossible to regulate for it, such is the scope and the scale of the whole ‘vulnerable’ label.

Alarm bells: Firms aren’t taking customer vulnerability seriously enough

Another hurdle to cross is to ensure staff have the training and tools necessary to help to identify vulnerable customers, as well as empowering them to do the right thing once vulnerable customers have been identified. On the whole, front-line staff are younger people, with not as much life experience as their older counterparts, perhaps making it more difficult to empathise with customers for whom major life events or circumstances have caused them to be vulnerable. It’s difficult to train for that but with greater clarity on what makes a customer vulnerable, from the regulator and the business itself, it’s certainly not impossible for staff to increase their awareness and understanding.

Empowered employees

Aside from increasing employee ability to recognise vulnerability, a vital part of the equation is to empower these very same staff to take the necessary action that vulnerable customers require. This might be by way of a triage-type process, where those identified as vulnerable are passed on to a special unit that’s empowered to deal specifically with vulnerable customers.

Or, again, through training, it’s possible to give employees the option to side-step the rules or standard Ts&Cs when needed, not only giving them the adequate time needed to consider what needs to be done differently, but furnishing them with the knowledge needed to know how to do things differently.

The role of technology

Even if you have the most empowered employees in the industry, the crux of the issue is still successfully and accurately identifying vulnerable customers. Training is good but ultimately it still relies on people to apply things learnt in training to everyday situations, something that doesn’t always translate, and something that still risks people falling through the gaps.

Technological developments are in the pipeline though, with consumer vulnerability detection systems incorporated into customer experience software or a case management platform able to detect patterns in customer language to flag up potentially vulnerable customers. It’s not a case of trying to take control and responsibility away from employees, but more a concerted effort to ensure the obvious signs aren’t missed.

However, even this isn’t watertight. Humans aren’t always right and it’s certainly very helpful to increase automation with technology wherever possible but you still need an element of quality assurance on top. To date, it’s this quality assurance that’s led to best practice development within a good number of financial services businesses, with the opportunity to reassess and review historical cases leading the business to realise that actually, certain policies are unfair or unreasonably applied.

This benefit of hindsight has triggered many to make the necessary changes to proactively help not only vulnerable customers but the entire customer base, too.

Raising standards

Do I think customer vulnerability will be the next PPI?

No, I don’t. It’s not as black-and-white as PPI and such is the breadth and scope of potential vulnerabilities, not only is it impossible to cover all bases from a responsible business point-of-view, but even the regulators are so far unsure how to regulate on it. If any direct enforcement action is to be taken by the regulator, what’s needed is greater clarity on how vulnerable customers are defined, not to mention how they should be treated. As much as CMCs are trying to find a new hook, customer vulnerability isn’t it.

What it does represent is a real opportunity for financial services businesses to raise standards in the industry, applying sound principles to every customer interaction, treating every customer in accordance with their particular needs, and constantly reviewing their own processes to ensure the appropriate levels of service and care for vulnerable customers.

I’m sure that regulators will continue to regulate as they understand it better but so far, financial services organisations themselves are taking the issue of customer vulnerability very seriously, driving best practice, raising the bar and setting the standards required for responsible business practices for today and the foreseeable future.

Martin EllinghamMartin EllinghamOctober 25, 2019


It’s never been easier or quicker to switch suppliers and service providers, with digital innovation and digital disruptors providing customers with the opportunity to make a change in super-quick time.

Such is the freedom of choice and the ease of changing that more and more customers are bypassing the complaints stage, choosing instead to vote with their feet (or more likely in 2019, their mouse). For the providers and suppliers this is obviously proving to be a testing time, with businesses searching for ways to better manage this current generation of increasingly transient and intolerant customers.

Mouse trap: A few clicks is all it takes for a customer to move on

Before business leaders can hope to address this, it’s vital to try and understand what’s led to this shift in customer behaviour on such a large scale. Unsurprisingly, there are a number of factors at play. Generally, people are more frayed than ever before, with socio-economic and political pressures taking their toll, adversely affecting patience levels if and when things do go wrong.

Also, expectations have changed, with an instant response or next-day service now deemed standard, no matter how complex the issue. And, perhaps most worrying for businesses, the entire concept of brand loyalty seems to have fallen by the wayside. While customers still seem to have a certain affinity to particular products and services, brand loyalty, where people have an emotional attachment to a particular brand, certainly seems to be a very rare phenomenon in this, our digital era.

Digital disconnect

This is actually where the crux of the issue lies. We’re now living and working in a truly digital age. Analogue is no more and the majority of interactions customers have with their service providers are digital, creating a disconnect between brands and their customers. Brands don’t have a human face any more, with the continued dehumanisation of brands only serving to remove any remaining traces of customer loyalty.

Over ear: Customers want to know you’re listening

There is one exception to this move away from human interactions and that is when something goes wrong. As a rule, the only time you speak to a human is if something has gone wrong, and the human that you speak to has the power to make the situation much better or even much worse, something that businesses are trying their best to ensure is always the former and never the latter.

Ultimately, even in our digital world, what customers are looking for when they have a problem remain the same. They want a sympathetic ear; they want to know they’re being taken care of; they want to know you won’t stop until their issue is resolved; they want to know it’s not likely to happen again in the future, and they want this all done in a reasonable timeframe.


While there is no budget for a white glove service for every customer, the very fact that we’re operating in a digital world undoubtedly helps to provide certain aspects of what customers want and need. Digital systems can furnish call handlers and other front-line operatives with customer data, transactional information and customer history, helping to take care of the speed to resolution aspect.

Bot seriously: Digital can often leave customers cold

However, this digital ‘efficiency’ can leave people a little cold and a computer’s inability to not only factor in but decipher new contextual variables that are part and parcel of the human psyche, mean that even the most advanced of digital solutions can still leave customers wanting when it comes to optimum levels of service.

While computers are very good if told exactly what to do, their inability to capture the nuances of human behaviour and emotions mean we’re still a long way off from going totally digital for customer interactions. Humans are too complex and fickle to shoehorn into a one-size-fits-all solution, making it necessary to maintain that sprinkling of human interaction alongside even the most intelligent of digital solutions. Which brings us back to the fallibility of humans and their ability to exacerbate an already negative situation.

A winning combination

What’s needed is increased automation to remove the laborious, time-consuming activities, with the addition of the human touch to thaw the seemingly cold-nature of digital intervention, underpinned by timely, contextual information to signpost the best route to resolution for the customer. While many businesses are working towards achieving this, no-one is there yet, with work ongoing as to how best to amalgamate the digital with the human to achieve optimum outcomes for both the customer and the provider.

Businesses need to focus on capturing the information needed to help automate the human touch. So, what are the signs given off by customers that in hindsight have signalled their ultimate intention to leave in the future?

It’s a sign: Customers can signal their intentions to leave in advance

Perhaps a reduction in deposits, a decrease in transactions, switching products or increased interactions with a help desk? As with all things in our digital world, it’s all about how best to use the abundance of data we all now have at our disposal to inform strategy, using the benefits of digital solutions to underpin efficient, effective and empathic human interactions at every possible opportunity.

It’s no longer enough to establish just whether a customer prefers email or telephone contact, or what time of day is best to make contact. Such is the lack of human interaction that the majority of customers experience, it’s vital for businesses to monitor and understand individual sentiments and behaviours, in an effort to uncover a deep understanding of the specific requirements of individual customers at every point of contact.

This, in combination with machine learning capabilities and the nuanced potential of the human touch, is the only hope businesses have of seeing a return to the customer loyalty of the past, resulting in a finely-honed Customer Experience for that all-important competitive advantage in an increasingly volatile marketplace.

Martin EllinghamMartin EllinghamJune 28, 2019



This might sound like a strange question in the context of financial services, but have you ever heard of Kintsugi?

No matter if not because I’m about to explain exactly what it is – and why it matters to your complaints handling team. For those who haven’t come across it before, Kintsugi is the art of repairing broken pottery. Fixing broken pots and dishes might not sound that impressive (or seem to have much bearing on complaints and Customer Experience) but the philosophy behind it is both fascinating and highly useful.

In Kintsugi (which translates as ‘golden joinery’), the broken pottery is repaired in a specific way. The pieces are held together with a special mix of lacquer and gold powder – creating a golden seam that serves not to hide the break but highlight it. The piece of pottery is not as good as new; it wears its golden scars with pride.

New beauty: The art of Japanese Kintsugi can be applied to complaint handling

They are now part of its history and something to be cherished. Whatever caused the item to break has, instead of rendering it useless, helped it become more beautiful. For people used to seeing broken things as being at the end of their journey, it’s an interesting concept to get used to.

However, it’s a philosophy that I think can have a profound effect on how you approach complaint handling – and the entire Customer Experience.

The problem with product-driven CX

Delivering great CX is a challenging task for any company – especially in the complex world of financial services. There are so many different elements that need to come together to keep each customer happy. Some of them you won’t even have control over. After all, how can you account for the things going on in a person’s day that will influence how they interact with you?

Thankfully, overall, customers are incredibly happy with the products and services they receive from companies. The UK banking sector is above the all-sector average for customer satisfaction, so it must be getting something right.

The problem arrives when customers aren’t happy with the products and services they receive. Too many businesses build their CX around the core product. So, when this doesn’t suit the customer’s needs or doesn’t work out as planned, the company isn’t sure how to handle the situation. Sure, it has a complaints handling team, but when the sole focus of CX is on delivering a great product, there’s little any agent can do to add value or retain the customer.

The importance of repairing relationships and building customer trust

When businesses lose a customer, there’s a tendency to label each case as a ‘lost cause’. This is especially the case when a product or service hasn’t lived up to expectations because companies don’t want to be faced with their failures. I don’t mean this as a harsh criticism; it makes sense when an organisation’s outward-facing reputation is built on the success of its offering.

Customers want to purchase from a company they can trust to deliver the goods. However, businesses have less and less control over how their brand is perceived. When a customer has a poor experience, they’re easily able to post reviews online detailing exactly went wrong. There’s no way for companies to prevent this – other than to deliver the best possible CX.

Review regret: Only the best possible CX will prevent online reviews from negatively impacting your brand

In situations where customers are already unhappy, aftercare and complaint handling become vital. Too many customer relationships break down because there’s no effective way to resolve issues and mend the trust between consumer and company. This is where the following philosophy of Kintsugi could make all the difference – both to the retention and acquisition of your customers.

How to apply Kintsugi to complaints handling

As I’ve mentioned already, there are so many elements that go into creating great CX. You can’t deliver the perfect experience 100 percent of the time – it’s simply impossible. However, when things don’t go completely according to plan, you can pick up the pieces and mould them into something new; something stronger.

If you apply the idea of Kintsugi to your CX, you can change the way you look at the customer journey. Instead of hiding the issues customers have had with your products and services (again, you can’t), focus on mending these relationships through complaint resolution to make sure people come away with a positive experience of your overall business.

Resolve to evolve: Mending customer relationships is essential to positive experiences 

By accepting that the customer journey doesn’t always go smoothly, you can transform the perception of your CX and your brand. When people look at a Kintsugi bowl, they don’t focus on how it broke – they see a new, more beautiful object that has taken the place of the original. The same will be true of your CX if you have an effective complaints-handling operation in place to rebuild trust with customers who have had a less than positive experience up until the point they complain.

Creating an opportunity with complaints

If you can make golden repairs on your customer relationships, you can turn negative experiences into positive ones. As well as making those consumers more loyal to you, the approach means people are far more likely to become brand ambassadors – helping you attract new business. This is why complaints are an opportunity for financial services companies, rather than a source of shame.

To make the most of this opportunity, however, companies need to know that their complaints handling teams are operating as effectively and efficiently as possible. For an unhappy customer trying to resolve a complaint, the frustration of having to do something as simple as repeating their details and queries to several different agents is magnified hugely. It’s just one example of how poor complaints handling can exacerbate a negative CX and highlights the need for companies to get the basics right.

When a customer gets in touch to talk about their complaint (whether over the phone or online), they have to be given the confidence that their issue will be resolved as best as possible – regardless of who they talk to. This means making sure that every agent has access to up-to-date information on each case, allowing them to make progress, support the customer and take important steps towards improving the overall CX received.

The way you approach complaints in your company will make a huge difference to how successful you are. If you apply the ideals of Kintsugi to complaint handling, you’ll shift the whole focus of your CX – and your business will be better for it. However, having the right mindset is just one piece of the puzzle.



Martin EllinghamMartin EllinghamMay 18, 2017


The internet is big business. Of course, you knew that already. Most companies in 2017 choose to have an internet presence and to use appropriate keywords to attract footfall to their websites where they can hook customers with special online deals. That’s good news. But do you really know the extent of the internet’s reach and have you fully appreciated what that could mean in terms of customer service?

In 2016, published a report showing the number of internet users across the Globe. In the UK, 92.6% are engaging with online apps and services; over 60 million people. In the US, Canada and Ireland the percentages are in the 80s, with South Africa coming in around 50% (in terms of population that’s still 28+ million users).

Also in 2016, published a report on the use of social media. An incredible 1.59 billion people were engaging with Facebook, 320 million with Twitter and over 100 million people were on LinkedIn.

Thousands of millions of people are using social media to keep in touch with friends and family, to grow their social network, sell products, influence others or be influenced by recommendations, and of course, complain about poor service. Everywhere you go, from buses and trains to (annoyingly) restaurants, it’s increasingly common to see people connected to Facebook or Twitter via mobile devices.

Before the rise of social media, if your train was delayed, your bus driver was rude or the service was terrible in a restaurant, you had a few different options: you could complain there and then, face to face; you could ring the company later and attempt to select the right options to join a queue; or you could write a letter and wait patiently for a response.

All these pathways to customer service are still valid but they all come with their own problems. Face to face conversations can be confrontational and in a society where we increasingly communicate via screens and keyboards, confrontation is something many people shy away from. All other methods require waiting – and the longer you wait, the more time your anger has to build up.

For many people, it’s not even a conscious decision. A browse through Facebook or Twitter reveals a world where even the smallest everyday occurrences are shared publicly. Much of it is largely unimportant but we’re now living in a society where it’s normal to let your social network know what you’re up to and therefore any interaction with a business (good or bad) is likely to be seen by hundreds of people at a time.

The good news is, whilst some will share immediately on their own social media accounts, many will still choose to contact the company direct – via social media – to share their impressions, concerns and anger (and of course to solicit an appropriate outcome). There is ample opportunity, with effective social media management, to turn those opinions around and to visibly do the right thing in a very public setting.

In May 2015, the Guardian published an article by Jo Causon, Chief Executive of the Institute of Customer Service, revealing the alarming statistic that from January 2014 to May 2015 the use of social media for complaints had increased eight-fold. Additionally, their research showed that 1 in 4 social media users had used this avenue to make a complaint between March and May 2015. When you consider how many people are connected to social media that’s a lot of complaint traffic. Now we’re a year on from the publication of that data – imagine how much further those statistics will have developed. Can you really afford to ignore the trend?

The internet has, without doubt, made the world a smaller place and it has provided amazing opportunities to communicate widely and share thoughts with millions of people. As an enterprise with ‘key stakeholders’ and ‘margins’, you really need to know what those people, your customers, are saying about you.

Let’s be clear: Social media offers a great opportunity for customers to vent their anger in real time, but it also presents an equally attractive opportunity for businesses to promote outstanding customer service. You have the perfect opportunity, with a little virtual elbow grease, to turn your critics into your advocates.

Where Does Good Online Complaint Management Start?

That’s a tricky question. To succeed – to have an online presence that is proactive, customer centric and appropriate – you need to target several aspects of your business. You need to make sure you have adequate software to capture complaints and analyse data. You need to make sure you have policies and procedures in place for colleagues to exemplify good practice. You need to make sure that all levels of the business, from the boardroom to the grass roots, are engaged and positive about what you need to achieve. Reward colleagues who demonstrate the best you have to offer.

One thing to remember: there’s no need to panic. Complaints aren’t new. You already know how to provide great customer service and there’s no reason why that can’t translate into great social media engagement.

Let’s start by looking at employee engagement. It’s all very well to tell your customer service team that they need to start responding to customers on social media, but remember this is a very public format and they need to be equipped with the right skills to do so. A badly written social media response or a negative tone may do as much damage, if not more, as not responding in the first place. Fortunately, more and more social savvy candidates are entering the workforce every day.

One Team

You need to make sure that your Customer Service department and your Marketing department are communicating effectively and that all employees are aware of your company’s vision, mission statement and objectives. Most importantly, you need to empower your employees to make good decisions with confidence, so that they can respond in real time, using their own judgement and you know that the risk in them doing so is minimal. You could even use technology to proof and add layers of authorisation (protection) to how they reply.

Apart from the risks associated with public real time responses, great customer service on social media looks the same as great customer service on any other channel. Customers want the same things: they want a swift response; they want you to be honest and acknowledge your mistakes; and they want a satisfactory outcome.

Train your staff so that they know the difference between auto-pilot and genuine engagement. You won’t succeed if you trot out placatory comments without substance. Remember, thousands of people may see the response so it must be worth reading. Try to avoid using cut and paste templates where possible; no matter how well they’re written they are still very obvious – especially after they’ve been seen several times on the same platform by the same customers. Enabling your employees to use their own natural tone of voice and their own words (and encouraging them to use their name to ensure that personal touch) can be scary – but it’s worth doing. One positive, engaging, conversational response that addresses the customer’s concerns directly and offers an appropriate solution will always surpass badly written apologies that don’t sound genuine.

Take It Offline & Be Genuine

Another important consideration is taking conversations offline. A public apology and a transparent ownership of any mistakes are great tools for showing customers that you care. However, consider the implications of offering a solution publicly: you could set a precedent for every customer to want the same outcome; you could even encourage unscrupulous people to make false complaints if you’ve offered public compensation before.

There might be occasions where you need to have a conversation about sensitive data like account numbers or contact details, and a Facebook wall just isn’t the place to do it. Have a process in place for apologising publicly but then letting the customer know that you will contact them privately with the outcome or to take more information – don’t push the initiative back on to the complainant to complain again elsewhere, especially via a channel they did not approach you from.

 Embrace Technology with Technology

Invest in software that will analyse your social media presence and the feedback you’re getting from customers on the main channels like Facebook and Twitter. Remember that whilst we’re focussing here on complaints, many people will share positive experiences on social media too or even seek the answers to basic service questions and these need to be identified and addressed. Every customer who comments about you on social media must be addressed; the one you overlook is the one that will escalate and damage your reputation.

You also need to be able to identify trolls – some people don’t want a genuine outcome, they just want to cause trouble. Being able to identify them and deal with them effectively is a key part of your effective strategy.

Again, look to your processes – do your employees know what to do if they suspect they are being trolled? Knowledge is power so make sure you teach them how to handle this potentially sensitive public situation.

Technology can help you to catch negative feedback before it escalates. Rather than leave it to chance, have a system that alerts you to a problem and get your team to resolve it within a set time – you could even route the problem to the most capable team member to resolve it.

Your Next Steps

Communication at all levels of your company is vital. It’s no good making social media management decisions in the boardroom and simply handing off responsibility to the Marketing team – you need everyone on board. Customer Service need to work with Marketing to make sure they have aligned skills and knowledge about best customer service practice.

The cleanest approach is to have a clear vision that is shared throughout the business, to ensure Marketing provides great feedback and reports on social media analysis and that Customer Service craft great responses that align with the company’s aims and objectives. For those with a separate complaints team, you need to bridge the divide and allow for one team or a connected team.

Effective social media management will help you to develop and maintain a healthy brand and will improve your relationship with your customers. Your customers are talking about you anyway, so you have nothing to lose – and much to gain – by giving them a platform to talk to you via their favourite sites, with you in control.

Remember that mission statement so lovingly crafted that’s lost in the weeds on your website? Use it. Reinforce it daily and show it working publicly through social channels.

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