The Doctor Will Text You Now

I recently missed a call in the middle of a busy day from my physician’s office, which had called to tell me that my son’s appointment time had been changed from 9 a.m. to 11 a.m. the next day.

By the time I checked my messages, the doctor’s office was closed and I had to cancel the appointment the next day as I could not make the 11 a.m. time.

The point of this story is that in today’s connected world, the best way to get hold of me in the middle of the day is via an SMS message or email.

I prefer to make appointments on the Web and would like to have an online chat session with someone if I have basic questions around appointments, medication etc. My healthcare provider does not have most of these capabilities, even though they could be enabled via technology today.

Avaya works with some of the leading healthcare providers in the world. We provide technology that allows a customer to start the interaction from a web chat session, move to an automated interaction with an interactive voice response system, and ultimately talk to an agent–with the entire context of the conversation (my heath ID, and details about the web chat/IVR) made available to them immediately for a more personalized experience.

Healthcare providers can reach out to patients/family via the preferred communication mechanism (SMS, email, telephone call etc.). These messages can automate the process of collecting vitals (blood sugar readings, weight, etc.) to better manage chronic diseases, or provide post-visit follow-up to prevent re-admissions, automate collection of co-pays etc.

I hope my healthcare provider embraces these technologies to help me communicate with them at my convenience, via the mechanism of my choice. In my case, if my providers had sent me an email about the time change for the appointment, I would have responded immediately, requesting a different time that worked for me.

Happier me = more loyal customer.

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A Closer Look at MiFID II Recording Requirements

The Markets in Financial Instruments Directive II (MiFID II)—arguably the greatest reform to hit Europe’s financial industry—is finally in effect as of January 3, 2018. This EU legislation serves as a much-needed upgrade from the original MiFID, enacted in 2004, and addresses key issues that resulted from the 2008 global financial crisis.

The directive requires all national governments in the EU to adopt certain laws, which they are free to do in their own way should the resulting effect be the same. Financial services institutions—specifically investment firms, credit institutions and trading venues—are subject to MiFID II, including companies that are headquartered outside of the EU but do business there (for a more thorough overview, see this blog by industry analyst Sheila McGee-Smith).

Recording Regulations: Raising the Bar

Perhaps the greatest impact of MiFID II is the law’s tighter recording regulations. Under the 2004 MiFID directive, there was no mandatory requirement to record communications involving client orders. To ensure fairer, safer and more efficient financial markets, MiFID II now requires firms to record communications (both phone and electronic) for the following investment services:

  • Reception and transmission of orders
  • Execution of orders on behalf of clients
  • Dealing on own account (takes place when a firm puts its own trading books at risk)

The specific customer interactions that are required to be recorded in relation to investment services include:

  • Receipts of client orders
  • Transmissions of orders (both where the investment firm transmits and executes the order)
  • Conclusions of transactions when executing orders on behalf of clients
  • Conclusions of transactions when dealing on own account, regardless of whether a client is involved in the transaction

Important note: MiFID II covers all communications relating to activities intended to result in the conclusion of a transaction or the provision of client order services, even if they do not result in a financial transaction.

Communication of orders placed through channels other than voice—postal mail, faxes, emails, SMS, face-to-face conversations recorded using written minutes—must be stored in a durable medium.

Keep in mind a few rules that apply to this ‘durable medium’:

  • Records must be able to be replayed or copied
  • Records must be retained in a format that does not allow the original to be altered or deleted
  • Firms are required to ensure the quality, accuracy and completeness of all phone records and electronic communications
  • Records must be kept for a minimum of 5 years and, if requested by the National Competent Authority in a specific country, up to 7 years
  • Clients must be notified in advance of recording
  • Records must cover communications made with, sent from or received by equipment provided or permitted by the investment firm (privately-owned equipment used by employees or contractors is not prohibited)

Ensuring Compliancy with MiFID II Recording Regulations

If your business is involved in financial services in any way—even if it’s not your main focus (i.e. credit institutions performing investment activities, branches of third country firms)—you’ll need to investigate to understand whether this new legislation will affect you and, if so, what you need to do to comply.

We recommend a thorough review of compliance across all channels (including back office processes) to determine if they meet the new regulations. If not, you’ll need to deploy a workforce optimization (WFO) solution to demonstrate that policies, procedures and management oversight of the new recording and monitoring rules are in place. Here’s what you’ll need to consider in a WFO solution:

  • Continuous recording: This goes for all inbound and outbound voice and other electronic communications based on business rules. You need a WFO solution that will capture, search and retrieve calls, offer encryption for secure storage, and offer pause and resume capabilities.
  • Desktop screen capture: This is an undetectable back-end process that records desktop screen activity during each customer interaction. Supervisors and managers can use this both in the contact center and back office to view customer interactions from beginning to end via synchronized screen and call recordings.
  • Quality management monitoring: Identify and capture areas of non-compliance, while measuring how well employees are delivering services that align with customer experience expectations.
  • eLearning and coaching tools: Bring employees fully up to speed on regulatory changes and any new requirements, as well as correct any non-compliance behaviors.
  • Voice analytics: Proactively identify, measure and isolate areas of non-compliance by mining intelligence from large volumes of recorded calls.
  • Workforce management: Schedule employee compliance training while ensuring you have enough support personnel with the right skills to serve customers.

The greatest threat to reputability, revenue and customer experience is the thought that your technology is “good enough” to meet current needs. Your ability to innovate and grow are hinged on technology that meets the next-gen needs of today, tomorrow and beyond—something that only 24% of companies say their workforce optimization and recording systems achieve.

To complete a thorough review of your current MiFID II processes, connect with Avaya. For a deeper dive into MiFID II (including a few WFO features not mentioned above) download the white paper MiFID II: What Does it Mean for Your Organization?

MiFID II: What Do You Need to Know?

Sheila McGee Smith Sheila McGee-Smith is a leading communications industry analyst and strategic consultant with a proven track record in new product development, competitive assessment, market research, and sales strategies for customer care solutions and services. Her insight helps enterprises and solution providers develop strategies to meet the escalating demands of today’s consumer and business customers.

If you work in the financial services sector, you’ve likely seen news articles and heard IT, operations and other company managers and executives talking about the impending MiFID II regulation. It’s likely been a topic of conversation for months, if not years. Recently, The Washington Post began an article about MiFID II saying, “The impact of new market rules sweeping across Europe has been likened to motorists suddenly being told they must drive on the other side of the road.”

While the statement may seem like hyperbole to some, for those who work in financial services the statement will have the ring of truth. They have been working for years to create and refine practices and systems to be compliant with a European Union directive that became effective January 3, 2018: the Markets in Financial Instruments Directive II or MiFID II.

An original MiFID was enacted in 2004, prior to the 2008 global financial crisis. Ad hoc changes were made by individual countries to address issues that resulted from the crisis. These issues are being addressed through MiFID II, which harmonizes the rules for all firms with EU clients, across all countries. The main goals of the MiFID II are:

  • Customer protection
  • Increased financial product governance
  • Unbundling of advice from the sale of financial instruments
  • Broader scope of supervision to include equity and non-equity trading
  • Firms must take “all sufficient steps” to ensure that transactions are executed in the best interest of customers
  • A considerable increase in the requirements for transaction data reporting

From an enterprise communications perspective, the aspect of MiFID II which is relevant is that it requires the capture of all communications and orders intended to lead to an execution of a trade, even if the transaction is not actually finalized during the interaction.

Penalties for non-compliance are set by the regulatory agencies in each European Union country. The first fine for non-compliance of the 2004 MiFID directive was given out to Barclays for inaccurate transaction reporting. Barclays’ fines totaled £2.45 million for their inaccuracies between 2006 and 2008. Since then, published reports say that banks have paid over $204 billion in compliance-related fines and infractions.

Every day, millions of transactions are reported by hundreds of trading venues, for thousands of different financial instruments. As a result, the potential for individual company fines of tens of millions of dollars is very real.

If, like so many companies, you are not sure if your current recording procedures will be sufficient to meet the requirements of MiFID II, the time is now to prioritize an assessment. Businesses need a comprehensive review of their compliance across all channels – phone, email, and SMS – to meet the new regulations. In addition, they need to demonstrate that policies, procedures and management oversight of the MiFID II recording and monitoring rules are in place.

If this post has made you wonder whether MiFID II regulations apply to your firm or what types of transactions need to be recorded and which do not, download the white paper MiFID II: What it Means For Your Organization? It gives a more extensive review of the MiFID II regulations and answers questions about what geographies are impacted, what types of firms are affected and how the new transaction recording rules are different from the rules in effect today.

We’re Doubling Down on the Cloud-Based Contact Center with Google

Nearly every business, no matter its size, has some mechanism in place to engage with their customers. For the world’s smallest companies, that’s usually a voicemail number or email address that one person responds to in their spare time.

In contrast, the world’s biggest companies deploy sophisticated, multimillion-dollar systems capable of efficiently processing hundreds of thousands of customer interactions per hour, using tens of thousands of customer engagement agents working 24/7.

But what about the millions of entrepreneurs who find themselves between these two poles?

Companies that are ready to improve their customer engagement, but aren’t ready for a big upfront investment, are increasingly looking to cloud-based, subscription services first.


Read: Avaya Chooses Google Cloud Platform for New Cloud-Based Contact Center Solution on the Google for Work blog


Analysts at Frost & Sullivan estimate the cloud-based customer engagement market will grow 11.6%, roughly twice the growth rate of premise-based customer engagement solutions.

Today, we’re announcing the Summer 2015 availability of Customer Engagement OnAvayaTM Powered by Google Cloud Platform. August 2015 update: The product is now available. Please click here for details.

I want to take a closer look at some of the new features we’ve been hard at work on, and why they’re so exciting.

This new solution provides low-cost agent setup, and allows agents to work from anywhere, right in the browser.

Imagine opening up your Chromebook and logging into the Customer Engagement OnAvayaTM Powered by Google Cloud Platform app with a simple username and password. No VPN required.

We do this by using HTTPS to establish a secure connection between the app and Avaya Secure Border Controller Element, software that verifies access to the database and routes relevant traffic to and from the app. Interactions inside the app are handled by WebRTC, an emerging Web standard that we’re strong supporters of.

HTTPS opens up a temporary information tunnel between the app and the enterprise, which closes as soon as the agents logs off. Every time you use Gmail, buy something online or check your bank balance from your phone, you’re using HTTPS.

Application-specific access using HTTPS has three major benefits for the enterprise: Simplicity, security and scalability.

First, simplicity. Onboarding a new agent is a snap, and can be done completely remotely. Instead of provisioning a new VPN token and sending the agent a complicated sheet of instructions, they log into a Web app–just as simple as logging into Gmail.

Second, security. VPN opens up a bigger tunnel into the enterprise, essentially placing the entire computer on the network virtually. With HTTPS access, data to and from the enterprise is limited to a single application. Nothing else gets through.

Lastly, scalability. The solution is hosted on Google Cloud Platform, which offers world-class reliability. It’s easy to scale up as your business needs grow, and new features are added automatically as they come online.

All customer data exists in the cloud, so if the agent’s Chromebook gets lost or stolen, your risk as an enterprise is greatly reduced.

The result is a truly virtual customer engagement solution, perfect for companies looking for a subscription-based cloud software model.

Customer Engagement OnAvayaTM Powered by Google Cloud Platform is widely available in the U.S. through certified Avaya business partners and Google for Work services partners.