The Irish Examiner reported yesterday that a number of Irish telecommunications companies had been prosecuted by ComReg for systemic billing errors. These prosecutions would have been taken under Section 45 of the Communications Regulation Act 2002, as amended by Section 13 of the Communications Regulation Amendment Act 2007. I believe this may be the first actual prosecution for breaches of this legislation, although ComReg has previously settled with Vodafone for €951,000 in 2012 arising from previous overcharging incidents (in which case it is odd that Vodafone have again been investigated given the undertakings given for independent audits of their billing systems for 2 years)
I’m very familiar with this piece of legislation as, for about six years, my job was to ensure the effective design and operation of internal controls to ensure compliance with this (and other) legislation and to lead root cause analysis and remediation projects to fix systemic billing issues that arose in a particular Irish telecommunications company. A lot of the methodology approach that Castlebridge Associates brings to bear with clients was developed from lessons learned during that time (a period when I spent a lot of my own time and money to be able to learn from pioneers in Information Quality Management and Data Governance such as Dr Tom Redman, Danette McGilvray, David Loshin, and John Ladley).
The diagram opposite (click on it for a detailed explanation) illustrates one of the core concepts we teach clients and use in advisory engagements- the relationships between Strategic level decisions and the Information and Process outcomes experienced by customers (internal or external). Castlebridge Associates will be running one-day “Introdution to Information Quality” and “Introduction to Data Governance” courses in September and October where we explain this framework in a little more detail, but for now, the accuracy of customer bills and charging for telecommunications services is a classic “Information Outcome/Process Outcome” scenario that affected by decisions and actions in a number of areas of the organisation.
A lot of processes and systems need to be aligned correctly to ensure that:
- The information about tariffs and pricing are understandable by the customer so their expectation of costs is in line with reality.
- The right prices and tariffs are communicated to the customer at point of sale, so that retail staff or websites display and explain costs correctly
- The right tariffs and pricing rules are implemented in the billing engine of the phone company
- There is correct handling of incompatibilities between products and tariffs that could effect the accuracy of the customer bill
- There are appropriate automated or structured control in place to detect anomalies and act on them in a timely manner to prevent errors reaching a customer’s bill
This requires not just a technology systems alignment. It requires an appropriate alignment of business functions such as:
- Product development (is the product developed correctly, with appropriate considerations to billing?)
- Marketing communications (are the marketing materials for the product clear about the tariffs and the exceptions to the rates?)
- Learning and Development (have staff been trained properly to sell the product, raise orders correctly etc.)
- Technology (are the data flows and system interfaces for the provision of the service properly defined and monitored?)
These functions need to be governed at the Operations level (the day to day selling of products, management of customer relationships, and the day to day operation of IT systems) and the Tactical level (the line management decision making about business planning, organisation structure, and mid-term strategic goals).
However, a key root cause for billing errors (like any other information quality issue) can be found at the Strategic level in the organisation. Strategic level decisions that are taken around culture, organisation priorities, and, for example, the allocation of staff to Regulatory Assurance and Information Quality management roles, directly impacts on billing outcomes.
Telecommunications services can be exceptionally complex to generate bills for given a host of factors such as product bundling, interconnect charges, roaming charges, license fees to platform providers etc.
The pace of product development, the need to respond quickly to changes in market conditions and competitor offerings creates a high-intensity environment in many telecommunications companies, particularly when the focus of investors and senior leadership is on the bottom line in the Profit and Loss account. In organisations that lack a strong culture around the governance of information and the management of the quality of information, the “data thing” often winds up being dealt with at the end of a project to build a product, or in many cases AFTER the product has gone live. In such cultures, the documentation and artifacts of good governance of information are seen as “overhead”.
And they are. Just like the electricity bill to run the data centre and the paper costs to run the office photocopier.
Proper documentation of processes, clear definition of business rules, formally assigned accountability and responsibility for Information and Process outcomes, and appropriate training are essential to ensure that customers’ bills are correct as close to 100% of the time as possible. Technology is, at most, 33% of the solution here. Data quality profiling across the order to bill processes can reveal inconsistencies and mis-matches and can generate batch files for remediation of defects, but only in an environment where there is an acceptance of the Business leadership role and accountabilities for Information. This requires the technical complexity to be iteratively broken down. Documenting the “Order to Cash” cycles for products, documenting the hand-overs and critical business rules, and assigning accountability and responsiblity for outcomes makes the complex simple.
Above all else, however, appropriate resourcing and training of a Data Governance function to oversee the application of Information quality rules and controls is essential.
It’s worth pointing out that EXACTLY the same disciplines are required for customer billing accuracy as are required for Data Protection compliance. They are just different categories of Information and Process Outcome in the context of a telephone account and the data associated with it.