English: This is an example of a Customer Interaction Model (CIM) in the Pronto methodology in Dutch. An organisation (Organisation) identifies possible transactions (“Verkrijg product” means “Acquire product”) with customers (Klant) about the requisitioning of a product that the organisation can deliver. Nederlands: Dit is een voorbeeld van een Klant Interactie Model (KIM) op basis van de Pronto-methodologie. Een organisatie identificeert transacties (“Verkrijg product”) met klanten. (Photo credit: Wikipedia)

The phrase is often used to describe the need for good records management and good documentation practices in investigations. One website suggests it as an approach to capture knowledge [link], while another suggests it can be used to help investigations [link]. The phrase can also describe how bureaucracies work because they rely on precedence, evidence, and rarely consider verbal authorisation as sufficient for decisions.  The approach would be appealing to those organisation that have regulatory bodies or an ombudsman to investigate customer complaints. In the public sector, where there are a number of regulators and an ombudsman, complaints have to be investigated with that destination in mind. As a result, the approach may prove attractive. However, I believe that such an approach while laudable will create a customer service problem.

Does it create or destroy trust?

The approach is problematic in customer services because it inverts the relationship with the customer. The employee becomes the person of record instead of the customer. If an employee does not write down what happens, then it did not happen. No matter what the customer says, they will have to prove their case and refute the evidence written down by the employee. In an investigation, the approach makes sense. Investigations are designed to find out what happened and assign blame. Investigators have to reviews the available evidence and this is usually what was recorded contemporaneously about the event. In customer service, by contrast, the issue is usually alive in the customer’s memory so there is no need for the customer to record it.

Can the customer ever prove they are right?

When the approach is used for customer service, it undermines the idea that the customer is always right (within reason). I say within reason because a customer is not allowed to abuse an employee. The relationship is based on trust. The approach that if it is not recorded it did not happen is based on distrust. The approach asks the customer to prove their claim and provide evidence that can refute what the employee has recorded. In many ways, we can consider this as being wrong until you can prove yourself right, which can be a standard for industries with a regulator or ombudsman. If your industry does not have a regulator or an ombudsman, the approach will be problematic because it would drive away customers and business. A for profit business has to retain business and the trust of its customers. In the public sector, where the customer cannot choose their service provider, the approach will be problematic.

In the public sector, the organisation either regulates a business or enforces statute. The client or customer cannot take their business elsewhere and the organisation has greater power over them. If customers and business do not need to be retained, then trust is less important because there is no need to worry about competitors. However, the issue is not about competition or a market approach to public service because those approaches create their own problems. These issues are beyond the scope of this blog.

How will the customer respond: record everything, forget nothing

When organisations use this approach, it forces the customer to write down or record everything they did with an employee just to make sure they had a fair hearing. The distrust that is implicit in such an approach becomes explicit. In local government, we can see case where distrust, for reasons other than this approach, displayed when clients and employees covertly record meetings and conversations. There have been recent cases where social services have had their information recorded and employees have taken covert recordings as evidence in employment tribunals. [see court cases]

The vulnerable are at the mercy of the bureaucracy design to protect them

The approach is particularly problematic in social services because the social worker’s notes that make up the official record are what the court relies upon in its judgement. The practice does not avoid “He said/She said” exchanges. Instead, it creates an institutional bias against the customer. We can see this bias in two ways. The first is that the customer does not know the organisation operates in this manner. They do not know that what they say or do can and will be recorded to their disadvantage. Second, they are not aware that only what the officer wrote down is the official and accepted version of events. If the customer becomes aware of this practice, they will start to record every interaction with the organisation. They will also make more subject access requests (SARs) under the Data Protection Act. However, these will not be enough. The notes will only reflect what the employee recorded.

What will happen is that the customer will want to record and submit their version of events. In time as technology allows, they will move from contemporaneous notes to capturing the event in real time. The customer will no longer make notes of a conversation or a meeting. Instead, they will want to record it. The trust between the employee and the customer will disappear because the organisation has undermined it.

What the regulator requires becomes the bureaucracy’s business model.

A related problem is that the approach will reflect the demands created by the regulator or the ombudsman. For example, the Information Commissioner regulates data protection and freedom of information issues. As a result, officers prepare responses to the applicant with a view that the complaint will end up with the regulator. The regulator begins to shape customer service and customer complaints. If the regulator tells organisation “if it is not written down it did not happen,” then the organisations will respond accordingly. A perverse outcome is possible because the approach creates more complaints and more appeals to the ombudsman for the apparent unfairness of the approach.

At a deeper level, the approach creates a severe disadvantage for vulnerable clients and customers. If a customer distrusts the organisation, they will want to record the meeting. If the organisation refuses to cooperate and refuses to meet if the customer or client wants to record the meeting, then the customer has to accept that what the company records is the official record. In that scenario, the customer or client is in a double bind. The employee’s record is official because what they write down is what happened. The applicant is left defenceless because they have no basis to challenge the official version.

A system open to abuse? 

A further danger is that an employee can exploit the approach. The customer is wrong until they can prove they are right and they do not even know they are wrong until they try to prove they are right. They can only prove they are right based on the official record kept by the employee with whom they are in dispute. If the employee insults them, they have no redress because the employee keeps the official record. The employee has an incentive to write down what puts them in the best light rather than what happened. Would any employee ever record that they insulted the customer or provoked the customer? No. Yet, that is what happens with the logic of “If it is not written down, it did not happen.” They can write down whatever they want, following a meeting, a telephone call, or conversation, because they keep the record.

Record more, but do you change the culture? 

An organisation may try to avoid this by recording telephone calls. The approach can help to mitigate this approach, but it leaves unaddressed those issues that are not handled by telephone. Unless an organisation is prepared to record all customer-based events, it will prove difficult to manage this process. Few companies will have the resources to record all interactions. The problem, at its core, is about culture rather than technology. Technology may limit or restrain the worst aspect of culture, an employee will be more circumspect on the telephone, but that does not change the approach to customer service.

Customer service creates the trust and respect needed for business 

The approach to complaints and customer service has to be based on mutual trust and respect. As soon as that disappears, the relationship goes from consensual to adversarial. If an organisation uses the “if it is not written down” approach to avoid regulatory or ombudsman complaints, it will be at the price of customer trust. Is this a price worth paying just to avoid ombudsman complaints?

Would you run your customer service on that basis?

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