Some feedback received
Here are some views on the first draft of the code that I have received by email. The contributor will remain anonymous unless they tell me they wish to be named:
3. The content of the message:
3.1 There will be many views on exactly what name is used.
For me, it needs to be that of company responsible for the call in a form that permits ready identification. By "responsible" I mean the company who would hold a "do not call", or would be subject to action by the ICO in the event of the recipient being registered with the TPS. The form of the name would be that most commonly used in a telephone or business directory or in searching for a web site, so that one could discover how to write, call or e-mail.
If the call was made by an overseas agent on behalf of a UK or EU company, it would have to be the company rather than the agency.
In some cases it would perhaps be necessary to give the name of both the agent and their client, to meet the "responsibility criteria specified above.
3.2 I believe that a few words to cover the general purpose of the call should be included in the specification of the message.
"This was a non urgent call and there is no need for you to call us back" is one example that goes a long way to avoid any hint of marketing. There is a danger that too much vagueness could lead us back to anxiety
- well why did my bank call me then?
- who is this company I have never heard of?
- if you don't want me to call you back so we can speak, why did you call me?
Unless the ICO insists on particular wording (which is unlikely) I believe that the most helpful reassuring wording appropriate to the campaign, that does not include marketing material, should be used.
3.3 It may be best to either give a very clear indication of when a further call will be made, or to say nothing at all about future calls. Some companies would wish to always make an attended call to anyone who has received an NAAC as soon as possible - I see no problem with that. Others would perhaps wish to advise that no further attempt would be made for at least 72 hours.
3.4 On the question of giving a number to request no further calls I am probably going to be controversial. I do not think that this is necessary (as a requirement).
If the name of the company has been given adequately, there should be no problem in contacting them to ask for no further calls. If CLI is provided then this would make this easier.
The purpose of the Informative Message is to close the issue swiftly andeffectively without causing trouble or embarrassment to either party. No anxiety, no nuisance, no need to write down telephone numbers.
I fear that if any focus is given to the provision of call back numbers then the message gets longer and the process gets complicated. This may also draw attention away from the imperative need for the name of the "responsible" caller to be clearly given in the message.
I would not however go so far as to say that this should be prohibited.
3.5 If the message is brief, transmitting it twice is fine.
This may help to deal with the problem of the beginning of the message being missed if recorded by an answering machine or service. For the live listener, a little thought may need to be given to the start of the message so that the hearer has a little time to put the phone to their ear, make
their announcement and tune in to the fact that they are listening to a message, before important information is given. If the caller's name comes too soon, even the most alert listener may have to wait for the repetition before they catch the name.
4. I am not sure if the one second limit is feasible.
The DMA has this in its code, however I have read someone dismiss this as unattainable for predictive diallers.
If answering machine detection is at all reliable and does not make the delay unacceptable, it is a highly desirable feature from the consumer's point of view. I get notified of all messages left on my landline by a call to my mobile - I would rather not be notified of NAACs.
This point may need some serious debate.
5. Everyone seems to be getting very excited about CLI at the moment.
I am not excited about CLI, except where the issue distracts attention from the key point. It has its uses, but it should not be seen as an alternative to making calls properly in the first place - that is what the Informative Message is about.
Why should someone be compelled to give CLI with all sorts of strings attached, if they are making calls that announce who they are and why they called?
If they tell me who they are and I want to call them, I can look them up in the phone book. If they do not tell me who they are when they call, they are making a nuisance call. If they are making a nuisance call, why should I believe that any CLI they give is likely to be genuine and effective in identifying them.
Compelled provision of CLI is simply being used as an excuse for failure to use the telephone properly. The Informative Message is about using the telephone properly.