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Direct Debits - is the UK different?

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I will try not to be hazy though I'm not sure where to start...

Anecdotally we have one of our directors heard that Direct Debits work differently in the UK than over here in Australia, which proceeded to be flicked to me to investigate. I've tried to get some context or even a clue but nada...so I turn to you.

We plan on doing some Regular Giving work for our client. This will require the donor to supply either DD or CC details. We understand the PCI requirements as they are pretty much the same as here (question about that below, though). However when it comes to bank accounts what if anything is different that what we do here which is ->

On the call we are required to take only

Account Number (can't be more that 9char)
BSB (Sort Code) <> 6 char
Account Name

Is that enough information to supply back to our client? In Oz we can take down Bank Name and Branch but that's all catered for in the Sort Code but maybe it's compulsory in the UK?

Is there any limit to how long we can store that information?

One requirement however is that we record and read out a due diligence when Bank Details are offered, which is read out verbaitm to the record who has to agree to terms and conditions at the end. We do not have to do this for CC, though.

So is there anything different. If i'm not doing a good job of asking the right questions could you point me to where I might be able to find the legislation/requirements for taking down Bank Details; language used, inputting, storage and supply. If it exists that is.!

On the question of CC details. Rather than encrypt the recording, we simply took the decision to not record that part of the call. Simplistic maybe but effective. Is this permissible in the UK?

Many thanks in advance

Pierre

Posted 1 year ago

There is some commonality between the UK and Australia but also some noticeable differences too.

Since PCI is mandated by several credit card companies its reach doesn't extend to bank direct debits so on a call, the call centre agent needs to collect only the few details you've mentioned i.e. account number, sort code and account name.

However. Although the DD process sounds similar to yours in Oz, ours has to meet Financial Services Authority (FSA) guidelines http://www.fsa.gov.uk/

Generally speaking, the process starts with the agent asking if the customer is the account holder and if they are the person required to authorise direct debits before then collecting the account number, sort code, account name. A call centre that is FSA compliant should next read out the details collected about the DD and ask the customer to confirm they are all correct. The agent tells the customer that they will receive a confirmation letter within so many days, 3 I think, that states the amounts to be collected and on what dates. The agent then refers to the DD protection guarantee and asks if the customer would like it read out, or is happy to refer to it in the confirmation letter.

Although the process sounds lengthy, and from the agents perspective, wordy, it does nevertheless offer the customer the chance to be clear about what they’re getting into.

Some call centres go much further with the process described while others I’ve observed barely meet the minimum requirements. Not surprisingly, the latter tend to be the ones you read about that have been fined by the FSA for serious breaches of their guidelines, so over here it’s a process that call centres take very seriously.

Why do some companies not follow these guidelines so stringently? Well, the compliance statements are exact and mandatory at various stages of the DD process. It’s a tricky job to ensure the agent follows the process and I’ve seen many different ways of enforcing it.

With regards your last point about encrypting the call recording for PCI compliance with credit card transactions, it used to be enough to simply not record that part of the conversation and I know of many companies that give the call centre agent that ability. However, PCI argues that there’s no assurance that the agent will remember to do this at the appropriate point and I believe that the standard is in the process of being updated so not recording the appropriate part of the call will no longer be a sufficient solution.

Hope this helps,
Karnail

Posted 1 year ago

Brilliant, thanks.

As for the last point re the CC - we took away the ability for the agent to turn the recording off/on. The system does it as soon as you enter that area of the script and then back on when exiting. Up to now it's worked as intended (ie: the agents haven't found a way to break it yet!).

Posted 1 year ago

Help again! I went on the FSA website but what a trek...

Anyone have a summary or a link to the actual guidelines that apply?

Posted 1 year ago

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