Righting the Wrong – Customer Remediation

Tracey Berry
August 2022
GRC

Remediation best practice and pitfalls are once again in the spotlight with the Commerce Commission’s consultation on its draft guidance and Waka Kotahi making news for its vehicle registration refund letters.  

The need to make good for prior errors, omissions and failures can be a vexing exercise for those ill-equipped. But it can also be the experience that strengthens trust and builds enduring customer relationships.

Mosaic FSI have used our team’s experience and expertise in Remediation to make a Submission to the Commerce Commission on its draft guidance. The guidance gives a clear steer to businesses on the areas to focus on:

  • Place the customer first and at the centre of any remediation activity
  • Ensure all governance processes and decisions are recorded and justified
  • Make sure your data processes, particularly those around identifying customers and impact, are robust
  • Customer contact strategies must be proactive
  • Document the remediation process and decisions made within it.

In our experience, here are some of the common problem areas for remediation activities:

  • Inadequate frameworks. The right policies and processes mean remediations can be efficiently run, with the appropriate governance structures in place within clearly defined and repeatable frameworks.
  • Poorly defining the issue and any harm caused. Taking the time to identify the key issues and any potential harm caused, assists in planning the remediation activities appropriately, including any internal or external reporting that will be required.
  • Unclear data scope and assurance. Good data drives a sound remediation process. We have seen many examples of remediation activities having to be reworked because data issues were identified late or after completion.
  • Informal governance and undocumented accountabilities. Good governance processes and clear accountabilities mean decisions can be made with confidence and transparency for stakeholders is in place.
  • Poorly executed customer comms. A full and appropriate comms plan for each customer cohort will reduce the strain on the business of responding to customer questions and complaints.

Mosaic has submitted to the Commerce Commission on Consumer Remediation – you can read the thoughts of Partner Tracey Berry and Principal Consultant, Virginia Douglas here