Ultimate Consultation Response Guide
As we all know, there already are, and will be many more, consultations on the go this year and you would be forgiven for wondering if it’s worth the effort to submit a response. We’ve put together a guide with some top tips to help you establish exactly which consultations you should be responding to, how to form a detailed response including which vital information to include.
1. How important is the consultation subject matter to your organisation?
Read from start to finish. There is a history of consultations containing out of context content, so to understand the full scope it is necessary to read the entire document, including any supporting material if published. After doing that, you can then fully and accurately assess the potential impact based on your company’s; target market, industry sectors, product offering and the potential changes that may be imposed as a result of the consultation process.
For simple consultations which may have relatively little actual impact on your business, you may take the view that submitting a response based on the involvement of relatively few stakeholders is all that is required. In this case, skip the next bit and go straight to consultation content.
2. What to include in a response if the potential impact to your organisation is significant.
a. What are the experts saying? A good place to start is to find out what other industry stakeholders are saying about the subject. Another good place to look is at industry representative bodies that you have access to, for example the Betting and Gaming Council, Gambling Business Group etc. who will undoubtedly be holding discussion groups and conference calls on the relevant topics. From these sources, you will not only get an understanding of the consensus view, but you may also get some ideas that you haven’t already considered.
b. Strength in numbers. One point to note is that even if an industry body will be making the same points as you in their consolidated response, it is still a very good idea to provide one on behalf of your company. The number of responses does matter as a large number is seen as representing a more important viewpoint and, arguably, can lead to a greater degree of consideration. We all remember the “over 13,000 responses” reason provided for the delay in concluding the previous British Gambling Commission customer interaction consultation…
c. Research and real time customer data. Next, it’s time to consider research, either existing or, if the circumstances demand it, new studies. Any arguments you put forward in consultation responses will be received more strongly if they are backed up by either independent research or, and this point is often overlooked, statistics based on your own customer activity. The latter element can be very informative both for the consultation process and your own internal business intelligence, and responses which include statistics showing “impact on the customer” of any potential changes based on real life data can be difficult to argue against. In a similar vein, you could hold customer workshops either directly or via consumer research agencies and present the consultation contents for comment by the consumers.
d. Assemble and brief your team. Once you have all that background, it’s time to engage the appropriate people from within your company. Few non-compliance people will read all of the material, so a short, summarised presentation of the basic content would be useful, together with comments on the general industry view obtained from the above approach. Then, to steer the meeting and to try to prevent widescale, generalised discussion about life, the universe and everything using up all the allocated time, present a list of the consultation questions one at a time and any key points obtained from the above research. For the benefit of the non-compliance types in the audience, it may be useful to include a summarised “possible impact” list of what could happen in terms of the worst-case scenario, the industry preferred and your preferred outcome if they do come to pass.
e. Draft a comprehensive response. From your discussions with organisation stakeholders, get the key points and draft the response using as many of the content points and research data as you feel appropriate. Circulate the draft and if there is a lot of interest, you may need another meeting or series of meetings to discuss.
f. It’s game time. Once you have your final version it’s time to make the actual submission. These days, the process is geared towards online submission and there is normally a way of adding additional documents as well. However, if that isn’t the case or the amount or size of documents means that online submission isn’t practical, a postal address is often provided so you can mail the physical information to the consultation organisation.
3. Consider and predict exactly what the impact to the consumer and the organisation will be.
a. Data-based information. As for consultation content, the key aspect to consider is data-based information. Wherever possible, quoting information and statistics based on real world data is very powerful, both from the impact on the consumer and the impact on your organisation.
b. Cost / benefit analysis. Don’t ignore the commercial impact of changes as this aspect can be useful if presented as a cost / benefit analysis. For example, supplying information that a relatively small percentage of consumers would be impacted by a very costly to implement and manage change could suggest that the change is not justifiable. Similarly, if the technical development work required to implement a change would mean that previously planned customer beneficial development would have to be postponed, this could provide support for the argument that an enforced change does not generate sufficient benefit to consumers but does create a negative impact.
4. Lastly, we come to the question of named or anonymous submissions.
Include or exclude the brand. Some consultations allow anonymous submissions or at least may not verify any contact information that you provide. Why would your organisation want to remain anonymous? Well, if you suspect that the points you are making are potentially controversial, or that the arguments you include are open to easy challenge, or the data you provide could be misinterpreted as negative in some way, you may want to not provide your details. If this is the case, then it is sometimes possible to provide your information to an industry representative body and for them to submit that under their name but as being provided by an unnamed company. Named submissions may carry more weight but providing the information included is sound and backed up by good data, it shouldn’t matter. Only you and the organisation you represent will know whether you believe anonymity is necessary.
With all the above, you may be still wondering if it’s worth the effort, but as the delayed GC customer interaction consultation showed, if there is a significant level of interest in the process then more time is taken to consider the circumstances and potential impact. Whether this generates any change in approach from those initiating the consultation in the first place is another matter, but at least you have taken the chance to influence the process.
Here at Betsmart Consulting, we have supported numerous consultations from various viewpoints, so if you would like to discuss any aspect of the process please do get in touch.
Written by Andrew Mason