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The Credit Services Association (CSA)
Blog: Raising standards for debt collection ‘tracing’ activity
Claire Aynsley is Head of Regulatory and Compliance Standards at the Credit Services Association. Since joining the organisation over 10 years ago, her dedication and passion for the industry have greatly enhanced the status of the Association, forging strong relationships with regulatory bodies and other industry stakeholders to ensure we are at the forefront of any regulatory and legislative changes.
What is tracing activity?
Tracing is an activity carried out in order to locate the whereabouts of an individual, where it has been determined that they have moved on. In our sector, tracing is carried out to locate a new address for a customer in order to re-engage with them or reconnect them with their creditors. Tracing is also used to locate individuals who are beneficiaries to a windfall or locating missing relatives.
There are a number of tracing methods which assist tracing companies in helping to locate individuals, and alongside these methods, tracing companies utilise numerous data sets to help validate their trace output. Methods include telephone contact, written communication, and field-based enquiries which are supported by data held at credit reference agencies, publicly available data and other data providers.
The CSA’s role and our new code
As the UK trade association for the debt collection and debt purchase sector, the Credit Services Association’s (CSA) role is to ensure that our Members are maintaining the highest possible standards by providing them with best practice guidance. Our main Code of Practice, which is currently being updated, refers to the activity of tracing but not in any great detail and since trace-related complaints (identifying and contacting the wrong individual as a result of lack of information or erroneous data) continue to be a key issue for the debt collection sector, we felt that it was important to take a proactive approach to ensuring that our Member companies are sufficiently ‘self-regulating’ when it comes to tracing activity.
We have therefore launched the CSA Trace Code of Conduct and Principles of Trace, which will be implemented from 30 September 2016, from which point all Members who carry out tracing activity, or outsource it, will be expected to adhere to it. Members now have time to digest the Code and make any necessary changes to their internal policies and processes to ensure compliance with the new code. This period also allows us to offer any support and guidance needed ahead of the implementation date.
Our aim is to drive the right behaviours and professionalise the activity of tracing in line with other debt collection practice, ensuring that the principles of Treating Customers Fairly are embedded at every stage of the debt collection process.
Understanding and addressing mis-tracing complaints
‘Mis-tracing’ – when someone is mistakenly contacted regarding a debt which is not theirs – is undoubtedly inconvenient for the recipient and can lead to complaints. The CSA Trace Code of Conduct requires members to undertake on-going root cause analysis of these complaints to understand exactly what the impact is on the recipient and how this could be mitigated. Members must also continually improve internal processes to reduce the occurrence of mis-trace and other trace-related complaints, as well as ensure data accuracy at all times to avoid repeat mis-tracing.
Taking all the necessary steps to validate a person’s identity before making any contact will cut the occurrences of mis-tracing and save both Members and customers time and hassle.
High quality training for all staff is an important part of improving conduct and this is also referenced in the Code. For more details on training relating to the Code of Conduct, please email firstname.lastname@example.org.