Preparing for BPA's Telemarketing Recording Rules

In less than a year, BPA-audited publications will have to begin submitting recordings of their telemarketing calls along with their publishers' statements. The 2008 Telemarketing Recording Rule goes into effect on January 1. It's significant because personal direct request continues to be the number one source for b-to-b magazines, providing 32.6 percent of all subscriptions in 2004, according to a compilation of data from BPA and ABC issued by American Business Media.

BPA spokesman Glenn Schultz says if publishers have not begun testing, they should start. "If they haven't already, they should be lining up a telemarketer or setting up a system to do this internally," he says.

Currently, BPA telemarketing rules require calls to either be recorded or for the subscriber to provide the telemarketer with personal identifying information in lieu of the recording. "The bottom line is that they're looking for more accuracy and more accountability in this source of renewals," Schultz says. "And with so much identity theft going on, people are hesitant to give out personally identifying information."

Still, publishers were initially concerned. Would subscribers object to being recorded? "There were a couple of very vocal publishers, who, in just the last month, turned around saying that the concerns that they were going to lose a lot of callers turned out to be totally false," Schultz says. "We all get telemarketing calls all the time, and being told that they're being recorded for quality control purposes has become second nature. So we've had a lot of people tell us their concerns were unfounded."

One of those people was Greg Brumley, president of telemarketing consulting firm, the Brumley Group. "I was afraid of two things," says Brumley. "One, I was afraid people would object to being recorded. And two, I was worried that BPA would nitpick the calls. But we did some spot sampling with BPA and we found that these things were not true. In no campaign that we have recorded have we found any indication of readership drop-off and, in some of the campaigns, the orders per hour have gone up. In some cases, they've gone up by a full order per hour."

Getting Ready
That said, Brumley believes publishers should be ready for the change and makes a number of suggestions as to how they can prepare. "Obviously you've got to be sure number one, that your current vendor is going to be set up for this," he says. "But I think that almost everyone is set up to do this so it shouldn't be an issue. If not, switch vendors. If your vendor says they'll be equipped by January, but they're not equipped now, I would want to know what they're doing to get ready because it requires a lot of hardware and software upgrades to get ready for something like this."

The big issue, says Brumley, is going to be watching the recording and making sure that it's a quality product that will pass BPA audit. There are going to be a few things that publishers will want to show BPA to prove a recording is "an honest call."

1. The call has to state its purpose at the top;in other words the telemarketer must immediately state they are calling to renew the subscription.
2. Provide the full name and title of the authorized telemarketing assistant to BPA.
3. Get a very clear "yes" to empowerment questions such as, "yes, I wish to renew my subscription."
4. Ensure that the call center is not manipulating demo questions such as getting people to state certain credentials that they do not have, and ensure that the call center is not using leading questions.

"I would be doing two things with the spring call cycle," Brumley says. "I would start voice monitoring early and do it often. And then, sometimes during the campaign, I would have the telemarketing firm send me a CD of all the day's orders. And by that, I mean I would call without notice and say, ﾑI would like all of last Tuesday's orders on CD. And they ought to have that CD in your hands within 48 hours."

Accounting for Nuance
Reed Business Information's telemarketing subscription efforts have been recorded and graded on a 23-point scorecard for several years for quality control purposes, says Eric Rutter, vice president of controlled circulation. "We've done it long before it was a BPA requirement," says Rutter. "We have an in-house quality control that listens to a sample of all subscription recordings. Feedback is provided to the vendor and the audience marketing team."

Rutter says Reed found it necessary to monitor telemarketing calls due to their imperfect nature. "In the case of e-mail or an online qualification card, everyone sees the same thing," says Rutter. "With direct mail, it's the same; everyone gets the same direct mail piece. It's very clear cut. In telemarketing, the qual card is not the same. It's spoken by several hundred telemarketing services reps throughout the day. With e-mail, if I click box 14, I click box 14, it's clear. But due to the nuances of conversation, it's not always crystal clear as to what someone's said or if the call is leading."

To that end, Reed gives its telemarketers a detailed script that they are required to follow. "Some publishing companies simply send a qual card to telemarketers to be used as a script," Rutter says. "In our case, we create scripts written specifically for telemarketing milieu. The scripts govern every aspect of the conversation ranging from introductions to rebuttals to collecting demographic data. Are some callers going to deviate from the scrpt? Of course. But we've tried to maximize our chances for success by making sure that the scripts are easy to use and that our instructions are clear and precise."

Sharing the Load
Under the new BPA requirement, publishers will not have to provide recordings for every call. Instead, BPA will do a sampling for all publishers to ensure the validity and quality of publishers' telemarketing subscriptions.

And Rutter believes the process could ultimately prove as labor intensive for BPA as it will be for publishers. "This whole process of pulling, listening to and assessing the recording is going to be a lot of work," Rutter adds. "It will be up to the stakeholders- publishers, telemarketers and BPA;to make sure the audit process is as smooth as possible."

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