IP, Technology & Data

OFCOM has published some guidance which helps operators of contact centres to better understand their obligations under the Disability Discrimination Act 1995/the forthcoming Equality Act 2010 (which replaces the DDA later this year).

The guidance is relevant both to businesses that operate contact centres in relation to their own business (whether in-house or through an outsourced service provider), and also to those who operate contact centres on behalf of other clients, whether as a core service or ancillary to a wider outsourcing contract. Whilst the latter may not have direct obligations to customers under anti disability discrimination legislation, they may well have obligations to their corporate clients under the outsourcing contract. Similarly, just because you have outsourced the operation of a contact centre does not mean that you have delegated your legal obligations to a third party.

The guidance emphasises the steps that operators of contact centres should take to help them to comply with their obligations not to discriminate on the grounds of disability, and their duty to make reasonable adjustments in respect of the provision of services. The guidance includes tips for both contact centre staff and for businesses that operate contact centres.

The advice to businesses highlights the importance of disability awareness training for contact centre staff, and of properly considering the needs of disabled customers when constructing IVRs, call routing menus and other parts of the contact centre infrastructure.

Note that the guidance appears to focus on voice-based contact centres. However, I would add another tip to the list – consider how your voice-based contact centre fits in with your other customer touch points. For example, can your service be made more accessible to customers with hearing impairments by offering access by email, a web-based service centre, or by an accessible web-based chat service?

If you have outsourced operation of any contact centres to a third party, then now might be a good time to review the accessibility of those contract centres and to check that your service provider is adhering to best industry practice.

See: OFCOM: Disabled customers and call centres (21 May 2010)

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Martin Sloan

Partner at Brodies LLP
Martin is a partner in Brodies Technology, Information and Outsourcing group and has wide experience of advising clients on technology procurement and IT and business process outsourcing projects. Martin also advises on data protection (including the GDPR), and general technology and intellectual property law, and has a particular interest in the laws applying to social media and new technology such as mobile apps, contactless/mobile payments, and smart metering.
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