#5 Achieving Consistency In Complaints Handling

Sarah Lawrence

Sarah Lawrence

Sarah has spent over 20 years of experience in the financial services industry, including over 16 years working at the Financial Ombudsman Service. Sarah specialises in customer service and complaints handling, with extensive experience of management and mediating complaints and is dedicated to passing on her knowledge and experience to businesses to improve complaints handling, customer service and consumers’ perceptions of the industry.

In the fifth of our series of guest blogs on key issues for complaints handling, Sarah Lawrence (access the preceding blog here…), former Technical Manager at Financial Ombudsman Service looks at the importance of consistency in complaints handling

The DISP rules don’t say it in so many words, but its rules cover the need to spot and resolve habitual issues before they become complaints, as well as rules about learning lessons from past experience. This all points to one thing – consistency.

First, let’s take a step back and think about what we mean by consistency when it comes to complaints. Often businesses, the FOS and DISP all point to the outcomes and the redress that’s paid (if applicable). However, it’s now 20 years since the rules were written and we’re still not there, so that tells us one thing – the consistency measures we’ve been using are probably not the right ones.

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The problem is that, like fingerprints, no two complaints are the same because no two customers are identical. What do we mean by this? Take two customers that have both experienced a data protection breach. Both have been notified that their details have been sent to a third party in error. Looking at this from a very high level you would think it would result in the same outcome, with the same redress, but as we all know that’s not the case. This is because once we start to delve beneath the surface and to look at the customers’ reactions and circumstances, they’re very different.

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This is why the nature of complaints makes it difficult to achieve consistency so long as we as an industry continue to focus on the outcome of a complaint and the amount of redress exclusively. Let’s not forget that this is also often a criticism levelled at the Ombudsman Service in terms of their outcomes and redress awards too, so no-one is above reproach.

Therefore, what should we focus on instead if we’re to achieve and measure consistency? The FCA has said that it’ll be measuring customer feedback, complaints outcomes and redress amounts to measure cultural change. Part of that change must include consistency in terms of complaints. Despite needing to wait until the FCA fleshes out the plans further, it’s probable that the FCA will pick on KPIs like the percentage of upholds, the amount of redress or both. In either case, the perennial problem of consistency will remain.

If indeed the FCA uses these KPIs, it will be leaving one key measure out, notably customer satisfaction and feedback. And this means taking some time to sit back and look at this area if you’ve not invested much time in it to date. Again, there are vagaries associated with feedback, because it’s tough to get a positive review about satisfaction when you’ve turned someone’s complaints aside. However, there are things that can be done in terms of making sure you’re offering consistency to your customers regardless of the outcome.

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For us, it’s ensuring that complaints staff are able to offer the same level of investigation irrespective of the complaint and are able to offer a customer experience which re-engages customers with your brand. This means not taking the circumstances of the complaint at face value but engaging with customers at a personal level, so that each and every customer, no matter how difficult the complaint, is dealt with in the same way. Nothing is more guaranteed to ensure a consistent stream of complaints to the Ombudsman Service than customers not feeling they’ve been heard or treated fairly. 

So, what would this look like in terms of measurables? There are many to choose from but, from experience, here are some suggestions: …

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As human beings, we don’t like surprises and we don’t like unfairness. If there’s a sniff of inequality within your processes or your systems, that’s guaranteed to lead to complaints. If we’re going to start to nail consistency, it means that systems, people and leaders all have to mesh together to spot disparities and push hard for a reliable service.

Of course, you won’t be able to please all of the people all of the time, but aiming for consistency in terms of customer satisfaction and offering a service that’s reliable is a good start. It’s then a matter of starting to build something trustworthy that results in less complaints and fewer referrals to the Ombudsman Service, making for a more consistent picture when it comes to measuring your complaints handling.


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