Feedback fundamental to Consumer Duty compliance

The value of collecting and responding to customer feedback, both good and bad, was underlined during a panel debate at ILC’s inaugural Risk and Compliance event, which took place at etc Venues in Manchester recently.

Panelists Vicky Webster, Head of Strategic Delivery, Claims and Fraud, First Central; Graham Wilkinson, Senior Partner Manager, Trustpilot; and Rob Stewart, Head of Sales, Claims Consortium Group said that a key part of achieving Consumer Duty compliance is understanding what the customer wants and where there may be issues, and then making the necessary improvements to process and communication to ensure good outcomes.

But that can only be achieved by removing the barriers to feedback and then listening to what your customers are telling you.

Vicky said, “There is no such thing as bad feedback. A poor review should give you an opportunity to not only show to other customers that you are responsive to customers and can answer their queries, but that you take it on board and will improve.”

Social proof

Graham suggested that insurers are sometimes reluctant to use third party review platforms such as Trustpilot for fear of negative feedback being in the public domain.

“But that’s exactly the sort of information you need,” he insisted, “because then you can address it. Also, being visible on third party review platforms can generate new customers.”

Explaining this, he pointed to the concept of social proof, which suggests customers follow customers.

“Two businesses might offer the same level of service, but a new customer will almost inevitably go where previous customers have gone. It’s a massive driver of consumer attraction because nothing drives marketing like good reviews. You can have the best offering, but if you don’t have social proof underpinning it then it means nothing.”


This is even more critical in the insurance sector, where competition among carriers is intense and customers, who are often in a vulnerable or stressed state at the time of claim, can quickly feel disappointed.

Often though, the potential for complaints can be mitigated by setting expectations at the outset and telling customers what they should expect.

“We’re fortunate at First Central because we have a connected policy and claims system,” Vicky continued, “which allows us to feed information right through the claims journey. It also allows us to be honest and up front with our customers and manage expectations by signposting any potential issues.

“We also work with tech partners to connect data through the supply chain – ensuring it is correct, protected and seamless.”

Rob said that Claims Consortium Group has also worked hard to ensure data flows freely through the supply chain and that customer communication channels are open.

He said, “Feedback is food and you need to make sure there are no barriers to getting that feedback. What we’ve done across our supply chain is build systems to enable feedback to be shared quickly up the chain to the insurer.”


Apart from enhancing transparency and more accurate information sharing, what this also achieves is a more consistent claims experience, with customers benefiting from the same methods and terminology regardless of supplier.

Rob continued, “When we’re talking about Consumer Duty, one of the key things is consistency of outcome. And one of the best ways to get that is through automated technology. You can’t automate everything and it might not give you the best journey every time, but if you automate nothing you’ll get really good journeys, but they will be quite sporadic. It’s about finding the sweet spot in the middle and there will be a learning period over the next couple years. Ideally, we want to humanise the complex – front-load customer-facing roles with lots of experience – and automate the mundane.”

As more tech is introduced and customer expectations continue to evolve, it is not an easy balancing act.

Vicky concluded, “We need to give our customers the option to go through the claims journey in whatever way they see fit, digital and non-digital, but it needs to be done perfectly and consistently and offer the same outcomes for each, and that’s really difficult.”

The Risk and Compliance event was sponsored by Albany Group, First Central, Gallagher Bassett and Padda Consulting.


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