Driving Customer Transformation under Consumer Duty

A leading insurer faced critical challenges while striving to meet increasing FCA Handbook rules and guidance on Consumer Duty.

They needed a senior customer transformation expert with specific conduct and regulatory knowledge to design and lead a programme that would enhance customer outcomes, support consumer protection, and avoid regulatory censure. This was a high profile engagement that required considerable Board and Executive committee stakeholder management and a clear customer experience strategy aligned to Consumer Duty cross cutting rules and four outcomes for retail customers.

Scope of the Customer Transformation Programme

Camelot’s consultant conducted an in depth review and gap analysis of the current state to inform their approach. They then reviewed this with the Board and Executive committee and secured significant funding to create a programmatical structure designed to deliver against key customer conduct themes, including:

• Monitoring and Reporting: creating and implementing a company wide framework to ensure robust monitoring and reporting of customer outcomes data, across all brands, products and services.

• Journey and Harms Mapping: to understand key areas of foreseeable harm across customer journeys and characteristics, then to inform the design of mitigations that avoid foreseeable harm and deliver good outcomes.

• Outcome Testing: a new framework aligned to the four outcomes, with continuous or deep dive testing depending on risk. This is designed to evidence that the firm’s service and processes deliver good customer outcomes in the same way and to the same level across segments.

• Customer Vulnerability: revised identification and recording, company wide training, and significantly enhanced support methods for customers in financial difficulty and other vulnerable circumstances.

• Customer Understanding: review, ratification, and rewrite of thousands of interactions with retail customers, alongside creation and implementation of a new comms production and testing framework to improve consumer understanding of financial products and services.

• Customer Culture: refocusing on outcomes and embedding change through engagement, training, and communication so employees act in good faith, support retail customers, and take responsibility for delivering good outcomes.

The overall programme was designed, agreed with the Board, and executed on schedule. This complex set of activities encompassed all parts of the business to align priorities and resources behind Consumer Duty requirements. From a position of insufficient controls and process evidencing, the programme started to deliver capabilities in customer experience, consumer support, and digital transformation.

The leadership and expertise provided by the Camelot consultant were pivotal to the entire transformation programme. They drove every stage of the initiative, from initial gap analysis through to execution, ensuring alignment with Consumer Duty requirements and embedding a customer experience strategy that delivered meaningful and measurable change across the organisation.

Strategic and Tactical Execution of Customer Experience and Consumer Support

A combined strategic and tactical approach was implemented to drive success, including:

• A complete overhaul of customer outcomes MI and creation of a robust monitoring and reporting framework, using data and insights to understand expectations, demonstrate compliance with rules and guidance, and evidence delivering good outcomes.

• A market leading approach to identifying and recording customer vulnerabilities through a new technology solution designed and delivered in 4 months as part of a focused digital transformation of tools and processes.

• Retraining and upskilling thousands of frontline employees on consumer support, financial difficulty, supporting vulnerability, and improved customer interactions, so they could support retail customers efficiently and responsibly.

• Removing call scripts to move away from rigid questioning that lacked empathy, toward natural, engaging conversations that focus on customer needs, consumer understanding, and customer experience.

• Empowering customer facing teams to provide a seamless and personalised customer experience, with clear responsibility and accountability for outcomes and fair value.

• Tight management of a multi million pound programme budget and over 140 FTE core resources, ensuring the programme was efficient, aligned to strategy, and delivered the expected benefits to the company and its customers.

  
  

This approach reflects what the FCA expects when firms review certain products and services portfolios. It ensures the duty sets a clear standard for how firms lead the market and treat consumers in the same way across channels.

Resulting Business Benefits and Customer Outcomes

The transformation programme delivered significant business benefits:

• Improved Customer Outcomes: and positive feedback from Board, Executive, and the FCA, helping build trust with consumers and demonstrating good customer outcomes in line with Consumer Duty requirements.

• Regulatory Progress: significant progress towards increased maturity in Consumer Duty, alignment with FCA expectations, and clearer evidence that the firm acts in good faith and avoids foreseeable harm.

• Increased Efficiency and Improved Satisfaction: in frontline customer interactions and consumer support, underpinned by more efficient processes and better use of data.

• Reduced Complaint Volumes: and resultant FTE reductions, showing meaningful change in customer experience, fair value, and outcomes delivered across financial products.

• Vulnerability Quality Assurance at 100 percent: following successful completion and implementation of the training, with teams able to show consistent quality in how they support customers in vulnerable circumstances.

• Stronger Governance: increased Board confidence in customer culture, monitoring and reporting of customer outcomes, and the fair value of products and services, supported by clear rules, guidance, and internal accountability.

  
  

Next Steps: Build Trust through Customer Transformation

Contact Camelot Consulting today for a confidential discussion on how we can support your customer transformation and digital transformation efforts.

Our experts specialise in developing and implementing proven strategies tailored to Consumer Duty requirements and the unique characteristics of the insurance market.

We help firms review their products, services, customer journeys, and experience strategies to deliver good outcomes, offer fair value, and build trust with retail customers.

Let us show you how our innovative solutions can optimise operations, enhance customer engagement, and responsibly transform your business while meeting FCA Handbook expectations.