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Cisco Outbound Option

Cisco Response to UK OfCom Regulations 2003 (including 2008 revision)

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PB613797

This document is high-level response to the OfCom 2008 revised statement of policy on the persistent misuse of an electronic communications network or service (for the statement of policy, please visit: http://www.ofcom.org.uk/consult/condocs/persistent_misuse/statement/misuse_statement.pdf). As such, it addresses the points raised by OfCom in the revised statement of policy and supersedes any guidance supplied that relates to the 2006 statement of policy OfCom supplied detailing its approach to section 131 of the Communications Act (2003). Cisco recommends the use of Cisco® Outbound Option Version 7.5(2) going forward for compliance purposes.

In the interest of brevity, this document sets out the high-level points of compliance and a Cisco response to each.

1. The "abandoned call" rate shall be no more than 3 percent of "live call", calculated per campaign (i.e. across call centres) or per call centre (i.e. across campaigns) over any 24-hour period and shall include a reasoned estimate of Answer Machine Detection (AMD) false positives.

Cisco response: The Cisco Outbound Option allows administrators to configure the maximum abandon rate for predictive campaigns. The predictive algorithm uses this rate to control the dialer pace such that the maximum abandon rate is not exceeded.

2. In the event of an "abandoned call", a very brief recorded information message is played within two seconds of an individual beginning to speak, which contains at least the following information:

a. The identity of the company on whose behalf the call was made (which will not necessarily be the same company that is making the call)
b. Details of a no-charge (0800) or Special Services basic-rate (0845) number the called person can contact so they have the possibility of declining to receive further marketing calls from that company
c. Includes no marketing content and is not used as an opportunity to market to the called person

Cisco response: You can configure the Cisco Outbound Option to support all these requirements by using the interactive voice response (IVR) platform to provide these messages. The outbound dialer can transfer abandoned calls to IVR applications. You can use both the Cisco Unified IP Interactive Voice Response (IP IVR) and Cisco Unified Customer Voice Portal as queuing and prompting platforms. You can configure Abandon to IVR by entering a route point in the "when no agents are available" field in the Skill Group Selection window. The content of the IVR message (for example, no marketing content) is determined by the end user; Cisco has no control over this content.

3. Calls which are not answered must ring for a minimum of 15 seconds before being terminated.

Cisco response: This stipulation requires appropriate configuration of the Cisco Outbound Option. The default behavior of the dialer is to cancel calls when no agents are available. With Abandon to IVR configured, the dialer does not cancel calls and the call rings until the ring no-answer limit is reached. To ensure this situation is compliant, administrators need to set the ring no-answer limit to at least 15 seconds.

4. When an "abandoned call" has been made to a particular number, any repeat calls to that number in the following 72 hours may only be made with the guaranteed presence of a live operator.

Cisco response: Cisco offers two options to meet this requirement to allow flexibility in the type and purpose of the outbound calling program:

– Administrators can turn off call retries. Then, based on call results, administrators can create a new import list to target calls abandoned previously. This list can then be imported into campaigns running in Preview mode to ensure a live agent is present to handle calls.

– You can use the Dialer Abandoned Delay setting to ensure call retries wait a minimum amount of time before the next attempt is made. Administrators can use this setting to prevent repeat calls within a 72-hour window.

5. For each outbound call a CLI number is presented to which a return call may be made which is either a geographic number or a non-geographic number adopted as Presentation Number which satisfies the Ofcom guide to the use of Presentation Numbers.

Cisco response: This feature is standard for Cisco Outbound Option. Administrators can set a Campaign prefix digit that allows administrators to customize the automatic number identification (ANI) that customers see.

6. Any call made by the called person to the contact number provided shall not be used as an opportunity to market to that person without that person's consent.

Cisco response: This action is customer-based and does not depend on Cisco product features.

7. Records are kept for a minimum period of six months that demonstrate compliance with the above procedures.

Cisco response: Cisco Outbound Option includes out-of-the-box reports that allow administrators to track detailed dialer metrics such as number of calls attempted, answered, and abandoned. Users of versions prior to 7.5 can manually calculate the abandon rate using raw report numbers from camqry11: Summary of Call Counts per Campaign Half Hour. Starting with Version 7.5, new Cisco Outbound Option reports will provide abandon rate by half-hour and daily reports.