On Track Summer 2013
OnTrack is the PTO's 6 monthly e-newsletter; informing public transport operators, community agencies and key stakeholders about case trends, emerging complaint issues and the PTO's activities.
The end of 2012 saw case receipt to my office stabilise after a very busy first six months of the 2012 year. Daily case receipt decreased from 19 cases per day in January to June 2012, to 16 per day in July to December. This was, however, a 70% increase in daily case receipt compared with the same time in 2011. Cases involving myki continued to be a main focus for my office.
Detailed myki refund complaint investigations represented a large part of our work and positively, resulted in very effective changes in customer communications being introduced by the Transport Ticketing Authority (TTA). This contributed to a decrease in complaints to my office.
Our other activities during this period included:
- the launch of our Annual Report in December 2012, reporting a 93% increase in case receipt during 2011/2012 compared with 2010/2011. This attracted a great deal of attention in the mainstream media;
- continued community engagement, professional development and policy work, which increases community awareness of operators’ complaint processes as well as the PTO’s role and assists in the prevention and resolution of complaints; and
- our continued focus on reducing our carbon footprint. This commenced in 2009 and in 2012 we achieved a 6-Star NABERS Energy Rating and received the Victorian CitySwitch Award—under 2,000m2 category for the second time.
In this issue of On Track we focus on the importance of good customer service and communication; providing data, case studies and insights into what drives complaints and how they can be avoided.
In 2013, we will continue to work with operators to improve service delivery through their people on the ground - station staff, drivers, Authorised Officers, contact centre agents and complaint handling staff. We share a common goal of reducing complaints.
Public Transport Ombudsman
The PTO was established in 2004, as a not-for-profit, independent dispute resolution body. We provide a free, fair, informal and accessible service for the receipt, investigation and resolution of complaints about Victorian public transport operators, who are members of the PTO scheme. We're independent from the transport operators and government and we don’t act as a consumer advocate.
We only investigate a complaint if it has been raised with the operator first and it is within our jurisdiction. We provide impartial advice and referral information in response to enquiries and complaints that haven’t been raised with the operator. We aim to assist the consumer and operator to negotiate a fair and reasonable outcome to a complaint, however, when agreement can't be reached, the Ombudsman may make a binding decision or dismiss the complaint.
We also play an important role in identifying, investigating and reporting systemic issues, which contributes to improved public transport services.
Information requests about PTO Members’ service.
Expressions of dissatisfaction about PTO Members’ service which the consumer has not yet raised with the operator.
Refer for Internal Escalation (RFIE)
Unresolved complaints that have been raised with the PTO Member / operator once and, with the agreement of the consumer, are referred to the operator’s customer service team for resolution.
Complaints raised by consumers with the PTO as a result of the consumer’s dissatisfaction with the operator’s response to the complaint.
We received 1,997 cases from July to December 2012, a 70% increase on the same time in 2011.
When compared with the first six months of 2012, our overall case receipt decreased by 16%, down from 2,382 cases.
We saw a reduction in complaints about
myki and Metro Trains and an increase in complaints about Yarra Trams, buses and V/Line compared with January to June 2012.
- 778 complaints referred back to the operator via the centralised PTV contact centre
- 416 escalated referrals to operator customer service teams (RFIE)
- 276 complaints investigated
- 107 enquiries about operator service
- 420 cases about non-scheme members, the majority relating to infringement notices issued by the Department of Transport
We recognise that there are many positive exchanges between consumers and operator staff which occur each day across the public transport network. As a result, complaints to the PTO are prevented and customer satisfaction with public transport services is achieved.
However, it is our experience that complaints to the PTO often involve dissatisfaction with customer service or communication, in addition to the actual cause of the complaint; and this further reduces the customer’s confidence with the operator’s service.
In the July to December 2012 period, 26% of complaint issues specifically related to dissatisfaction with the service provided by, or interactions with, operator staff including drivers, station staff, complaint handling staff and Authorised Officers (AOs). Often, other complaints include customer service issues too.
This indicates that for the complaints we receive, interactions between consumers and operator staff are a major driver of consumer dissatisfaction.
Interactions with consumers should always be approached positively and constructively - from the initial delivery of services to any subsequent interactions regarding that service. This will avoid some complaints from arising in the first place. If complaints arise and they are handled effectively, the likelihood that consumers will escalate their concerns elsewhere, including to the PTO, will be reduced.
We encourage operators to provide ongoing customer service and communication training for all staff who interact with the public – it will reduce complaints, build loyalty and engender an organisational culture focused on delivering excellent customer service.
A consumer was unable to clarify where to post his application for ticket compensation after Metro Trains had not achieved its monthly performance target.
The consumer obtained an application form online and noted two different postal addresses on Metro’s website. Unsure which address to use, he visited Flinders Street Station for help. A Metro staff member wasn’t sure which address was correct and referred him to a myki staff member.
The myki staff member couldn’t provide the correct address either and referred the consumer to another Metro station attendant, who provided a third postal address—which caused further confusion. The station attendant then provided the consumer with PTV’s number to have his concerns escalated to Metro’s customer service team. When the consumer called PTV, he was directed to myki, rather than having his concerns directed to Metro in accordance with agreed referral procedures.
Frustrated by the inability to obtain simple postal information, he contacted the PTO. Metro, via the PTO, advised that the address provided by the second station attendant was correct, explaining that the confusion had been caused by a change in the post box address of its mailing house. Metro also voiced concern that PTV had not forwarded the complaint to its IDR process—where it would have been resolved without any need for the consumer to contact the PTO. The complaint was resolved.
Good customer service requires staff taking initiative and stepping beyond their role, to
ensure that consumers have the right information at the right time, particularly during first contact.
Each time the consumer spoke with a staff member, whether they were a Metro, myki or PTV employee, it was an opportunity to answer the consumer’s enquiry correctly or to refer the consumer to the operator’s IDR process to get the right answer.
Complaints should be used to identify whether improvements are needed to internal communications about transport information for their own staff and the staff of other transport operators.
In 45% of cases received in July to December 2012, consumers did not have any contact with operators before contacting us.
We provide clear information to consumers through our telephone message, website, publications and community awareness work that we can only investigate complaints that have been raised with the operator first. Despite this, a large number of consumers continue to contact us first, rather than contacting operators.
Having a good internal dispute resolution (IDR) or complaint-handling process and well trained staff, will do little to attract consumers if they can’t find their way to the IDR process in the first place. It is important too, to call a complaint, a complaint. Welcoming or seeking customer feedback is important but when a customer is looking to register a complaint, they are looking for a complaint process not a feedback loop.
Limiting the ways consumers can lodge complaints by requiring written complaints, the lodgement of electronic complaint forms, or by failing to provide complaint contact information, will turn consumers away from IDR and towards external bodies like the PTO.
Consumers should be able to lodge complaints by telephone, email, complaint form, website, in person and by letter. Vulnerable consumers should be provided with assistance and flexible access to the IDR process if needed. All contact details should be easy to locate, particularly on websites which can be difficult to navigate. In some cases, we find that contact information is in small font and/or in hard to find locations.
All operator staff — from the CEO to frontline employees, should know how and when to provide IDR contact details to consumers.
We encourage operators to review the options they make available for consumers to access their IDR processes. It is also important to ensure that all frontline staff are well trained, understand the complaint handling process and know how to refer consumers to it.
In 38% of cases, consumers contacted the PTO after having one interaction with the public transport operator.
Taking the right approach during this first contact can avoid complaint escalation. It is during the first contact that impressions of how seriously and genuinely complaints are handled by a business are made. If the wrong impression is given at this point, it can damage the organisation's reputation and entrench complaints that could otherwise be easily resolved.
We see complaints where consumers have raised concerns with the operator and have received a response that does not invite further communication. Sometimes responses actively discourage further engagement with the IDR process. Examples include operators responding using a ‘no reply’ email address, correspondence that is legalistic or defensive and the use of statements like ‘we consider the matter is now closed’. These are missed positive relationship-building opportunities.
The PTO received 692 cases which were referred to operator customer service teams or investigated by the PTO in the second half of 2012. Of these, our data indicates that:
- 374 involved issues where the consumer had contacted the operator once before seeking PTO assistance.
- 29% of those consumers advised that they were dissatisfied with how a policy or procedure was applied. While customer service staff may, or may not be able to change a policy or procedure, they can review its application, discuss the reasons for the existence of the policy and effectively talk the consumer through the process. If the consumer remains dissatisfied, they need to know that their complaint will be reviewed openly and fairly.
- 14% of consumers advised us that the response they received was generic and did not address the individual facts of their complaint, resulting in consumers not feeling heard.
- 13% of consumers advised that their complaint wasn’t followed up or responded to.
Keeping consumers effectively engaged with IDR processes is within the control of operators through good communication and by taking an open, non-defensive and outcome-focused approach. We encourage operators to use this information to holistically review how they respond to complaints and consider delivering regular staff training on effective customer communications across their business.
An unhappy consumer contacted the PTO after receiving what he believed was a generic response from PTV to his complaint about the co-ordination of bus and train services on the Hurstbridge line.
When the consumer first contacted us, his complaint was escalated to the PTV customer service team for response using the PTO Refer for Internal Escalation Process. The response provided through that process again did not address the consumer’s individual concerns. Further, it did not provide information to support PTV’s view that bus and train services had become more integrated. The consumer again contacted the PTO for assistance.
Following our investigation, PTV provided specific information about bus and train services and how improvements to connections had been made with the implementation of a new timetable. The consumer was satisfied with the detailed and specific information provided via the PTO investigation and his complaint was resolved.
To achieve right first time complaint resolutions, the individual circumstances of a complaint should be reviewed, investigated and a customised response which addresses all of the consumer’s concerns provided.
We record and review the resolution outcomes of complaints, whether they were achieved via referral back to operator customer service teams or through the PTO investigation process.
Sharing this information with operators provides an insight into what consumers are seeking, and what we consider is fair and reasonable. It also provides operators with information about how they could
resolve complaints through their IDR process, therefore reducing PTO complaints.
The provision of a detailed explanation or an apology resolved 62% of these complaints from July to December 2012. This indicates that:
- when a timely and detailed explanation, tailored to the individual circumstances of the complaint is given as a first response, early resolution can be achieved. It also reduces the potential for consumers to change their resolution expectation because of dissatisfaction with the IDR process; and
- a genuine, meaningful, early apology, which addresses all of the consumer’s concerns, is an extremely effective way to resolve complaints. And it’s free! On the other hand, an apology provided after multiple requests, which is poorly worded or has a defensive edge, will lose its impact and escalate the complaint further.
In June 2012, we made recommendations for changes to consumer information about myki pass refunds, after an increase in complaints to our office.
After detailed investigation and discussions with TTA about the lack of available information regarding myki refunds, we obtained independent legal advice about the myki refund approach and the application of contract law and the Australian Consumer Law.
In September 2012, TTA accepted our recommendations, based on our complaint analysis and legal advice, and took the following steps to address the root cause of consumer complaints about the refund process:
- detailed information was placed on the myki website about how refunds are calculated;
- contact centre scripting was changed to reflect how refunds are calculated;
- a refund calculator was introduced for contact centre staff to provide accurate estimated refund amounts to consumers; and
- an internal escalation process for complaints about refund amounts was implemented.
The steps taken by TTA directly resulted in a reduction in investigations being undertaken by our office. Since September 2012, the proportion of investigations about myki refunds has decreased, from 42% of all myki investigations to 26%.
There was no change in refund policy or process, just a change in how information is communicated to consumers and how myki manages complaints internally.
Proactive changes to customer communications and IDR processes in response to reviewing complaint information should be a priority for all operators.
The PTO has received an increase in enquiries and complaints overall over the past two years. The increase can in part, be attributed to the introduction of the myki ticketing system and the heightened awareness of all public transport issues that this major change has brought.
Between July 2010 and June 2011 (see below), the PTO referred over 70% of non-investigated cases to operators, via the central contact centre, because consumers had not initially raised their concerns with them. From mid-2011, this changed and now we are investigating or referring via our RFIE process, 35% of cases, a 10% increase. Taking into account both graphs, this indicates that we are receiving more cases and more complaints from consumers who are contacting the PTO after first contacting the operator and not being satisfied with the response. The challenge for operators is two-fold, it is to increase accessibility and consumer knowledge of their IDR processes, and to address the issues during the first contact. This will reverse current trends in PTO cases.
It can be easy to forget that at the end of every complaint is a person who is affected by a negative experience and by their interaction with the business they dealt with following that event.
For some people, having a complaint is straightforward and easy to work through. For others, it can be an emotional and stressful time. Often these impacts go unspoken and unacknowledged. You can’t predict how someone will respond, or whether the same issue will illicit the same response from everyone who was affected by that issue.
The words displayed at right were mentioned by consumers who lodged complaints with the PTO, words which described the event, or their experience with the IDR process. Many are very emotive. If this aspect of the complaint is not acknowledged or addressed, it will not be resolved.
As complaint handlers, what we can do is identify the impact a complaint is having as soon as possible, acknowledge it as an important aspect of the complaint and ensure we respond appropriately.
Taking the time to understand the varied impacts of a complaint will increase first time resolution rates. Training staff to be empathetic; to see the complaint from the consumer’s perspective, rather than just focusing on policies or processes, will keep consumers engaged.
Five steps to consumer engagement
- Create an organisational culture that is receptive to complaints at all levels and commands ownership of complaints from beginning to end.
- Listen, understand and acknowledge all of the issues raised.
- Investigate openly and thoroughly, viewing it as an opportunity to identify ways of improving services for all consumers.
- Respond in a tailored, constructive and timely way and provide a meaningful chance to respond.
- Always be mindful of the impacts an attitude, action or response can have — they can be positive or negative.
The aim of good customer service is to elicit positive feedback.
The PTO provides independently facilitated workshops for PTO and operator staff, aimed at increasing communication and dispute resolution skills.
We also provide in-house training to operator staff and community agencies about the role of the PTO and we provide our own staff with learning and development opportunities.
Effective Writing Skills for Operators
The PTO engaged the Australian Institute of Management (AIM) to develop and deliver a one-day training session about effective writing skills for operator complaint handling staff. The session focused on understanding and applying the principles of plain English, the structure and format of effective letter writing and avoiding common grammatical errors.
PTO role and processes for frontline operator staff
For a number of years, the PTO has delivered training to new Authorised Officer (AO) recruits employed by Metro Trains. We appreciate the opportunity to explain our role and processes to new AOs and would welcome the opportunity to train other operator staff who have direct interactions with consumers.
Training for community agencies
We delivered training for youth workers about AOs, their powers and our role in investigating and resolving complaints. The training was facilitated by Youthlaw.
There is great value in running sessions for community agencies about public transport, how to deal with complaints—including how to access operator IDR, our role and how to contact us if needed.
Ongoing professional development is vital for all staff who work in dispute resolution or have interaction with consumers. Please let us know if there are areas of professional development your staff would benefit from that we may be able to facilitate.
Accessibility and Communication
We provide our staff with regular training to ensure our service is as accessible as possible.
In November 2012, sessions focused on communicating effectively with consumers who are deaf or hearing impaired. The sessions were interactive and provided a unique insight to PTO staff about how best to communicate with people who are deaf or hearing impaired.
Make sure you are accessible to people who have a hearing or speech impairment
Customer service is the most important business operation for many organisations in Australia today. Customers with disability are just like any other customer and so have a legal right to equal access to services.
The NRS uses specially trained relay officers who act as a bridge between callers. For callers with hearing loss, the relay officer would type your responses to the caller which they can then read on the screen of a special phone called a TTY. Internet relay is another type of call where a NRS user uses an internet-enabled computer or smart phone to make relay calls.
If you receive a phone call via the NRS, there is no cost. Making phone calls through the NRS cost about the same as a local call.
Most importantly, you can be assured that the service protects the privacy of users. The NRS is committed to protecting the privacy of relay calls – both the identity of users and the content of the call. Relay officers receive extensive training about their role, required procedures and legal and ethical responsibilities.
How the NRS can help you
The NRS can run free information sessions on the NRS for your staff to ensure that your organisation is accessible by phone to people with hearing and/or speech loss.
The NRS can provide free brochures, posters, videos and other resources to raise community awareness of the NRS.
Go to www.relayservice.com.au for more information about relay calls and the National Relay Service.
The PTO is founded on the principles of independence, natural justice, access, equity, effectiveness, accountability and community awareness.
We must ensure we provide Victoria-wide access to our services and that people know what we do and how to contact us. Accordingly, we provide public information programs to promote the scheme and our dispute resolution processes.
Over the past six months, the Ombudsman and PTO staff have met with consumers and community agencies at:
- Yarra Trams—Meet the Managers
- VCOSS All Aboard Action Network
- Stride Foundation
- VALID Self Advocacy Network Meetings
- Disability Justice Advocacy
- Broadmeadows Community Legal Service
- Link Community Transport
- Salvation Army Metro Transit Teams Launch
- Youthlaw—Annual General Meeting
- St Kilda Legal Service Co-operative
- Vision Australia
- V/Line— on train commuter consultation
- International Day of People with Disabilities
- Geelong City Council
- Travellers Aid Australia
We’ve also attended a number of joint industry ombudsman forums where representatives from the Telecommunications Industry Ombudsman, Energy and Water Ombudsman Victoria and the PTO meet with community groups. These forums inform consumers about their rights and their responsibilities, provide independent advice and empower individuals to resolve complaints directly with their service providers. They also inform consumers about how they can access independent, external dispute resolution when complaints can’t be resolved.
Our Ombudsman participating in Yarra Trams Meet the Managers forum - providing commuters with access to managers to voice their experience of tram travel. July 2012. Photo provided by Yarra Trams.
The PTO undertakes varied policy work, focusing on internal complaint handling and external consultations by regulators, government agencies and non-government bodies regarding public transport related issues, dispute resolution, social justice, industry reform and law reform.
Below are highlights of the policy work we undertook in July to December 2012.
Stakeholder Consultative Committee
Following the review of our case handling policies in 2011-2012, we identified that we had no formal mechanism for obtaining feedback about the impacts case handling policies have on consumers. To obtain a broad and balanced view, we have created a Stakeholder Consultative Committee, with representatives from industry and consumer groups. The Committee met in November 2012, and will meet again in March 2013.
Draft Passenger Rail Infrastructure Noise Policy
We provided comment in August 2012, and supported the Draft Policy as a means of reducing the potential for consumers being adversely impacted by noise from passenger rail infrastructure.
Review of the AS ISO 10002:2006
The PTO, in its role as a member of SOCAP, is currently involved in a review of the Australian Standard for Customer Satisfaction—Guidelines for complaint handling in organizations. The Ombudsman has also been appointed to the Standards Australia Committee, responsible for the review. The review is in its early stages and a draft of the revised Standard is expected to be released for comment between June and December 2013. To find out more, follow the below link — http://www.ombo.nsw.gov.au.
LaTrobe University Public Interest Law Internship
The PTO participated in the LaTrobe University Law School’s student placement program for the first time in 2012. A third year law student held a 12-week internship with the PTO. The internship focused on the policy work of our office and the way an industry based ombudsman scheme fits within the public law framework. The PTO will continue to participate in this excellent program. To find out more about the program follow the link — http://www.latrobe.edu.au.
Australian and New Zealand Consumer Law Roundtable
The PTO participated in the 7th Annual Australian and New Zealand Consumer Law Roundtable, hosted by the Melbourne University Law School. The Roundtable provides an opportunity for academics, lawyers, regulators and dispute resolution bodies to discuss emerging issues in consumer protection, new legal and behavioural research being undertaken and the effectiveness of consumer protection frameworks in Australia and New Zealand.
Practice Notes and Approaches
We continue to develop internal practice notes for staff about key complaint issues, to ensure consistent and best practice dispute resolution approaches are taken by our staff. In 2013, we will develop publicly available ‘Approaches’ about how we manage specific complaint issues on our website.
In 2013, we will increase the amount of information on our website about common complaint issues, to help consumers understand their rights and responsibilities and how to resolve complaints. We’d welcome your feedback about our website content to firstname.lastname@example.org
Our values are, most importantly, reflected in our work — our case management, community engagement and all our dealings with consumers, operators and stakeholders.
They are also integrated into our publications, brochures, policy documents, processes and recruitment interviews. They are:
We strive for excellence because we value what we do
We are transparent, honest and consistent
We lead through encouragement, guidance and innovation
We treat ourselves and others with dignity
We are impartial and objective