The Future of TCPA Compliance and 1:1 Consent
Recently, there’s been a lot of buzz about advertisers moving to live call transfers as a lead source. Because this is new territory for some advertisers, I thought it would be helpful to share some of the important things to think about and address for anyone considering this option.
A web lead is generated when a consumer fills out a lead form on a website proactively and that lead being sold to a lead buyer. A call transfer, also called a warm transfer, is generated when a web lead or an outbound phone call occurs offline by a third party who gets an interested consumer on the phone and then transfers that consumer to your call center live.
The perceived benefits of a call transfer over a web lead is that you get a live, warm body to market to, as opposed to buying a lead then making outbound calls to get the consumer on the phone, then figure out if that consumer is actually interested in your product or service. Warm transfers allow the advertiser to circumvent the challenges and inefficiencies they perceive. A notable difference between the two channels is that phone transfers are more expensive, but because of the assumption that the leads have been pre-qualified, they are perceived to be worth the higher cost.
We’ve been hearing a lot about the growing adoption of call transfers from marketers. These marketers are buying more calls than leads these days, explaining that while they may pay more for them, they see a higher value. They value having consumers on the phone, as opposed to spending time and money on the lead just to get them on the phone.
With a web lead, their reps have to call their leads multiple times, maybe unsuccessfully, only to ultimately get an angry consumer on the phone not interested in talking to them. Meanwhile, they perceive that call transfers will all be interested in talking to them immediately.
When our team attended LeadsCon New York a few weeks ago, my colleagues heard more conversation from people saying the same thing. It seems to be that the frustrations advertisers have with lack of visibility into web leads and the perceived cost associated with the lack of visibility is driving people to call transfers. Advertisers feel that while it may be six times the cost of a web lead, the efficiencies gained justifies the cost.
1. Performance is the most important place to put your focus. Many marketers perceive transfers to be easier and more efficient. This isn’t surprising because, in theory, it sounds fantastic. However, you need to be cognizant of the actual costs of generating a call into your call center, versus generating the call yourself if your lead channel works efficiently.
If you’re thinking about buying warm transfers, what it comes down to is cost per acquisition (CPA.) If you spend $20 for a warm transfer and $2 for a web lead and you only spend $10 to get the web lead on the phone, then you are getting nearly twice the yield over what you are getting from warm transfers.
2. Even with a warm transfer, you still need a TCPA compliance strategy. It’s a misconception that you don’t have to be concerned about TCPA compliance. Just because you aren’t making the call, doesn’t mean you are not responsible for TCPA. If an interested consumer is on the phone and the third party is making the outbound dial and not naming a particular brand they are calling on behalf of, the call buyer is probably protected from TCPA. However, if the third party is naming your brand in the outbound dial, you could be named in a lawsuit.
Even if you’re safe from TCPA risk for an inbound call, you still need a foolproof plan to follow up with that consumer—and that follow up requires consent and being able to prove that consent if required.
3. Be cognizant of the quality of the calls being transferred. With some call vendors who have a consumer on the phone for any amount of time, you may pay just because they get transferred, even if all calls are not equal in quality. Some clients say there’s still a notable percentage of transferred callers who thought they were going to the service department or getting something free if they got transferred. There is not a lot that can be done about the quality issues, aside from having a dialogue with the warm transfer provider. You need to consider the impact that the percentage of poor quality call transfers has on your CPA when you are testing and measuring the performance of this channel.
I’d challenge someone who says they can’t make leads work as well as warm transfers to take a look at their existing lead program and ask: “Have I done all I can to make this work?” An efficient lead channel is a proven, effective way to grow your customer acquisition, and there’s tools out there that allow you to do this in a straightforward, trusted way. And, with web leads, there is trusted and proven data available today that can be leveraged to improve quality.
Calls are a great way to get interested consumers on the phone for your agents. But what are the costs in getting that consumer into your call center? Many of our customers have found warm transfers to be better as a supplement than as are placement to their lead programs. So, before you implement call transfers as a rip and replace for your web lead program, you should first try to run the two channels side-by-side, and do your due diligence, measuring, and testing.
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