Twelve Days of Consumer Duty #11: oversight of outsourced providers

It’s day 11 of our Twelve Days of Consumer Duty exploring key questions midway through firms’ implementation journeys.  

Today’s question

“We outsource a lot of our customer service functions.  How can we make sure our providers embed the Duty?”

The answer

This is challenging, especially if your outsourced entity is not regulated.

Ideally you will develop a strong relationship with them, then agree firm, clear and detailed service level expectations and have sight of their compliance plan.

You should also agree oversight arrangements, quality control processes (involving both reporting from the provider and your own “mystery shopping” exercises) and escalation procedures where they may not be addressing concerns that you raise.

You’ll need to make arrangements to monitor the provider’s compliance work and the results of this.

You will remain responsible from a regulatory perspective for the provider’s compliance and for making notification to the relevant regulator of breaches in which they are involved.  

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