INTRODUCTION MANAGEMENT INFORMATION
Management information – the data or statistics collected to measure performance, and drive TCF compliant change where needed.
One of the most important elements of demonstrating compliance is management information.
Hard evidence can be provided by way of management information, or management information and you will need to be able to assess your information against a benchmark.
Management information collected during a period of business activity may be about customers, staff, calls, visits, meetings, sales, opinions, parts of a process, predictions etc. It is not just numbers.
Measurable data is valuable, but commentary or opinions are also management information and can help provide a comprehensive, balanced view. All relevant information from whatever source, can be described as management information.
It can be a summary of what a firm already knows but presented in a way that helps management see a pattern and decide.
This is as relevant to very small firms as what it is to large corporations. The only difference is ‘WHAT management information is required’.
All information relevant to a financial services provider, can be described as management information. Good management information should enable management to make good decisions. To do this, the management information should adhere to the following requirements:
- Accuracy: Quantitative information should be correct with any commentary contributed by the right people
- Timeously: Information should be available sufficiently quickly after the relevant business activity to enable managers to act
- Relevancy: The information and comments must display what a manager can directly influence or something that they may need to escalate to someone who can take the necessary action
- Consistency: The information must be consistent on a period-to-period basis to allow managers to spot trends and make sound decisions
Where management information is obtained, this must be seen, challenged, analysed, and monitored, and where action is required, this must be taken.
Full records are required as evidence of this. This could be by way of meeting minutes, resolutions, training interventions, performance management, complaints or claims statistics, or sales figures. What is important is to identify what information is important, how regularly this should be obtained, and what to do with it.
Practical measurement of the outcomes will identify areas requiring improvement as well as areas where outcomes are clear and evidenced.
For example, where training needs are identified, this can be addressed and provide a solution to what may otherwise become a crisis. Where products need reviewing, this must be identified and can receive attention. Where intermediary contracts are drafted unfairly, these will have to be rewritten.
Management information on customer satisfaction may be indicative of fairness. However, it does not demonstrate fairness as customers can be satisfied with unfair treatment and dissatisfied with fair treatment.
Management information is not just about different parts of a firm telling each other things. It is about measuring performance and identifying potential risks and being in a position to address these.
Financial services providers are expected show that they are using management information to-
- Demonstrate integration of TCF into the business culture
- The progress made in terms of implementing the TCF outcomes
- Act to improve procedures and customer service where required
- Monitor the outcome of remedial action, which in turn should evidence improved standards and therefore fairer treatment of customers
The first step regarding management information for TCF should be to develop the appropriate management information that would assess the delivery of the TCF outcomes.
Existing management information can be used but should be viewed from a TCF point of view. It should be remembered that good TCF management information measures performance and identifies potential risks.
Evidence to show that the provider is consistently treating customers fairly may include management information on the following areas:
All six outcomes are relevant across all areas of business activity.