Use cases

Check every debt call for the protections customers must get

UK and US rules. Checks each collections call for disputes, Breathing Space, advisers, contact limits, affordability and pressure, for a person to review.

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Example · UK energy arrears call: Breathing Space mentioned, an unaffordable plan pushed

Market (UK or US): UK

Call transcript with speaker labels

Agent: Good morning, you're through to Westbrook Energy, my name's Sam. Just to let you know, calls are recorded for training and quality purposes. Who am I speaking to? Customer: Hi Sam, it's Jo Lewis. I've had a letter about my account and it said to ring this number. Agent: Thanks, Jo. Before I go into the account I need to make sure I'm speaking to the account holder. Can I take your full name, the first line of your address and your date of birth, please? Customer: Joanne Lewis, 14 Rowan Close, and it's the second of March, 1981. Agent: Lovely, thank you, that all matches. Bear with me while I bring the account up. Customer: Okay. Agent: Right, so this is your dual fuel account, gas and electric. The letter you've had is an arrears notice. There's a balance of one thousand one hundred and forty-six pounds that's built up since October, and the last payment towards it was in November. How would you like to pay that today? Customer: Before we get to that, how much of it is the gas and how much is the electric? Agent: Let me have a look. It's six hundred and ninety pounds on the electric and four hundred and fifty-six on the gas. Most of it built up over December and January, when the heating was on and the direct debit wasn't covering the usage. Your direct debit was reviewed in February, which is why it went up to eighty-eight pounds. Customer: Right. I did wonder why it jumped. I know it's owed, I'm not disputing it, the readings are right. But I can't pay that today. My hours at work were cut back in the autumn, I went from full time to about twenty hours a week, and I've been behind on everything since. Agent: Okay, I'm sorry to hear about your hours. The balance does need to be cleared, though, so we'll need to get something in place today. Customer: I understand that. I've actually been talking to a debt adviser at one of the free debt advice charities. She's going through all my bills with me, the council tax, the water, you lot, everything. She said she's applying for Breathing Space for me this week, so everything's on hold while we sort out a proper plan. Agent: Right. We haven't had anything through from them on our side, so as far as I'm concerned the account's still live, and I still need to set up an arrangement today. Customer: She said she'd be in touch with all of you. Can't you wait until you've heard from her? It should only be a few days. Agent: I can pop a note on that you mentioned it, but I can't put the account on hold without anything from them. Let's see what we can do now. I can see your monthly direct debit for your usage is still going out, eighty-eight pounds a month. Customer: Yes, I've kept that going whatever else happens. Agent: Okay, good. So the lowest arrangement I can set up on a balance this size is ninety-five pounds a month over twelve months, and that's on top of your usual eighty-eight. Customer: I haven't got ninety-five pounds a month. Once the rent's paid and I've done the food shop I've got maybe twenty-five pounds left most months. That's why I went to the adviser in the first place. Agent: The system won't let me go lower than that on this balance, I'm afraid. And I do have to let you know that if we can't agree something today, the account moves to the next stage of the process, and that can mean a warrant to fit a prepayment meter. Customer: A prepayment meter? I'm trying to sort this out properly, that's the whole reason I'm speaking to an adviser. Agent: I understand, but it's out of my hands if there's no arrangement on the account. Ninety-five a month would stop that from happening. Customer: And what if I miss one? Agent: Then the arrangement would be cancelled and the account would go back into the collections process. So it's important you keep to it. Customer: Right. Fine. Put me down for the ninety-five, then. I'll try. Agent: Okay. Do you want it to come from the same bank account as your usual direct debit? Customer: Yes, the same one. Can it come out on the twenty-eighth, though? That is when I get paid. Agent: Let me check. Yes, I can move the date to the twenty-eighth, that's fine. So the first one will be on the twenty-eighth of this month. Customer: Okay. Agent: And can I just check your contact details are still right? I have a mobile ending 3 1 7 and an email starting jo dot lewis. Customer: That's right, both of them. Agent: Great. And you'll be able to see the arrangement in the app as well, under payments, once it's gone through tonight. Customer: I don't really use the app, but okay. Agent: Lovely. So I've set that up. Ninety-five pounds a month by direct debit, starting on the twenty-eighth, for twelve months, alongside your usual eighty-eight pounds. You'll get a letter confirming the arrangement in the next few days. Customer: Can I show that letter to my adviser? Agent: Of course, it's your letter. While I've got you, have you got a meter reading for me? It keeps the bills accurate. Customer: I took them this morning, actually. Electric is 4 5 2 1 8, and the gas is 0 8 8 7 3. Agent: Thank you, they've gone on. Both readings look in line with your usual usage. Is there anything else I can help with today? Customer: No. That's it. Agent: Okay, Jo. Thanks for calling Westbrook Energy. Take care now. Customer: Bye.
  1. Is this a call about money the customer owes?Yes100%
  2. How much financial difficulty does the customer describe?Clear difficulty76%
  3. Does the customer say the amount owed is wrong or not theirs?No94%
  4. Does anyone on the call mention a legal protection or process that changes how the debt may be collected?Yes99%
  5. Does the customer say a debt adviser, an attorney or someone else is acting for them on the debt?Yes98%
  6. Does the customer ask to limit how, when or where they are contacted about the debt?No82%
  7. Does the customer say something about their health or circumstances that makes it harder to deal with the debt or the call?No68%
  8. Does the agent give the notices the rule set requires before discussing the debt?Yes94%
  9. Does the agent ask about the customer's income, outgoings or what they can afford before a payment is agreed?Not asked98%
  10. Does the agent threaten a collection step or press the customer to agree an amount they say they cannot afford?Yes97%
  11. Does the agent tell the customer about free debt advice or the support the company offers?No86%
  12. How does the agent respond when the customer raises a dispute, a protection, a representative or a contact limit?Raised, carried on100%
  13. What is agreed about repaying the debt by the end of the call?Plan agreed with doubts96%

These are real answers stored from one run on this example.

The prism behind it

Check every debt call for the protections customers must get13 questions

Fields

  • Market (UK or US)
  • Call transcript with speaker labels

Context

These are calls about money a customer owes: arrears on an energy, water, broadband, mobile or credit account, or a debt being collected. The market field says which rule set applies: the UK rules to a UK customer, the US rules to a US customer. Each rule set says what the agent must say, what they must ask, what they must do when the customer raises a protection, and what they must never do. UK rules: Drawn from Ofgem's ability-to-pay rules and Standards of Conduct for energy suppliers, the FCA's Consumer Duty and its debt collection rules (CONC 7) for lenders and collectors, and the Debt Respite Scheme (Breathing Space) in England and Wales. - Notices: the agent gives their name and the company's name, says the call is recorded, and confirms they are speaking to the account holder before discussing the debt. - Affordability: before agreeing any payment, the agent asks about the customer's income and essential outgoings, and agrees only an amount the customer says they can afford. - Support: the agent tells a customer in difficulty about free, independent debt advice, and about any hardship fund, payment break or support scheme the company offers. - Protections: two cases hold collection, for different lengths. A Breathing Space moratorium, including a mental health crisis moratorium, stops collection for its whole length: when the customer says one is in place, the agent notes it and stops asking for payment. A repayment plan being arranged with a debt adviser holds collection for at least 30 days so the adviser can work with the customer (CONC 7.3.12G): when the customer says a debt adviser is helping them, including while the adviser applies for Breathing Space, the agent notes it and does not press for a payment or a plan on the call. When the customer says they are in or applying for a debt relief order, an IVA or bankruptcy, the agent notes it, stops asking for payment and passes the account to the specialist team. A dispute about the amount goes to the billing team, and collection of the disputed part stops while it is checked. - Contact: a request to be contacted only at certain times, by a certain channel, or through a representative is recorded and followed. - Never: threaten disconnection, a prepayment meter, a warrant, court or a debt collection agency to get a payment, or press the customer to agree an amount after they say they cannot afford it. The agent may explain the next steps once, as information, when the customer asks. US rules: Drawn from the Fair Debt Collection Practices Act and Regulation F, which bind third-party debt collectors and which many creditors follow as policy, state laws such as California's Rosenthal Act, the bankruptcy automatic stay and the Servicemembers Civil Relief Act. - Notices: the agent confirms they are speaking to the customer before discussing the debt, and says the call is recorded where the program requires it. On a program run by a debt collector, the agent says on every call that it is a debt collector attempting to collect a debt and that any information obtained will be used for that purpose. - Affordability: before agreeing a payment, the agent asks what the customer can afford. - Support: the agent tells a customer in hardship about the company's hardship programs and that free nonprofit credit counseling is available. - Protections: when the customer says an attorney represents them for the debt, that they have filed or will file for bankruptcy, or that they are on active military duty, the agent stops discussing payment, takes the attorney's details or the case number, and passes the account to the specialist team. A dispute about the debt goes to the disputes team, and collection pauses on it. - Contact: a request to stop calling, to stop calling at work, or not to call at a time the customer says is inconvenient is recorded and followed. - Never: threaten arrest, wage garnishment, a lawsuit or credit reporting that is not intended or not lawful, discuss the debt with anyone other than the customer or their representative, or press the customer to agree an amount after they say they cannot afford it. Judge only what is said in the call. Do not infer a health condition, a disability or a financial situation from tone, accent or language. These answers select calls for a person to review. They never decide who is collected from, what plan a customer gets, or whether a meter is fitted, and checks against a Breathing Space register or a bankruptcy database are made by code.

Questions

  1. Is this a call about money the customer owes? Yes / No

    Count calls about arrears, a missed payment, a payment plan, or a debt being collected, whoever started the call. Yes: The call discusses money the customer owes or a plan to repay it. No: The call is about something else, such as a fault, a move or a new sale, and no debt is discussed.

  2. How much financial difficulty does the customer describe? Scale

    Go only by what the customer says about their money. Pick the level that fits their strongest statement.

    • None The customer describes no difficulty paying; they can pay, or are only asking a question.
    • Some strain The customer can pay but says it is tight or would mean cutting back.
    • Clear difficulty The customer says they cannot pay the amount asked, for example after a drop in income.
    • Crisis The customer says they cannot afford essentials such as food, heating, rent or medicine.

  3. Does the customer say the amount owed is wrong or not theirs? Yes / No

    Count a billing error, a catch-up bill they challenge, charges after they moved out or closed the account, a debt they say belongs to someone else, or a request to prove the debt. Yes: The customer disputes the amount or says the debt is not theirs. No: The customer accepts the debt, or says nothing against it.

  4. Does anyone on the call mention a legal protection or process that changes how the debt may be collected? Yes / No

    Count Breathing Space, a mental health crisis moratorium, a debt relief order, an IVA, bankruptcy filed or planned, or active military duty, whether already in place or being applied for. Yes: At least one of these is mentioned. No: None of these is mentioned.

  5. Does the customer say a debt adviser, an attorney or someone else is acting for them on the debt? Yes / No

    Count a debt advice charity or adviser, an attorney or solicitor, a relative or carer with authority, or anyone the customer says is helping them deal with the debt. Yes: The customer names or mentions such a person or organisation. No: No one acting for the customer is mentioned.

  6. Does the customer ask to limit how, when or where they are contacted about the debt? Yes / No

    Count a request to stop calls, to stop calls at work, not to call at certain times, to use one channel only, or to contact a representative instead. Yes: The customer asks for at least one such limit. No: The customer asks for no limit on contact.

  7. Does the customer say something about their health or circumstances that makes it harder to deal with the debt or the call? Yes / No

    Count what the customer says about physical or mental health, disability, a bereavement, caring for someone, or a similar personal circumstance that affects their ability to pay or to deal with the call. Money trouble on its own belongs to the financial difficulty question, not this one. Never infer it from tone, accent or language. Yes: The customer says something of this kind. No: The customer says nothing of this kind.

  8. Does the agent give the notices the rule set requires before discussing the debt? Yes / No

    Use the notices item of the rule set for the market field, such as the agent's name and company, a recording notice, confirming they are speaking to the account holder, or a debt collector notice. A recorded announcement quoted in the transcript counts. Yes: Every notice the rule set requires is given, before the debt is discussed. No: A required notice is missing, or comes only after the debt is discussed.

  9. Does the agent ask about the customer's income, outgoings or what they can afford before a payment is agreed? Choice

    Use the affordability item of the rule set for the market field. An amount the customer volunteers without being asked does not count as the agent asking. Pick one option.

    • Asked before a payment The agent asks about income, outgoings or what the customer can afford before any payment or plan is agreed.
    • Not asked A payment or plan is proposed or agreed, and the agent does not ask about affordability, or asks only after it is agreed.
    • No payment discussed No payment or plan is proposed or agreed in the call, for example because the call is only about a dispute or a protection.

  10. Does the agent threaten a collection step or press the customer to agree an amount they say they cannot afford? Yes / No

    Use the never item of the rule set. Count threats of disconnection, a prepayment meter, a warrant, court, a collection agency, credit reporting, garnishment or arrest used to get a payment, and pressing the customer to agree an amount after they say they cannot afford it. Explaining the next steps once, as information, when the customer asks is not pressure. Yes: The agent does at least one of these. No: The agent does none of these.

  11. Does the agent tell the customer about free debt advice or the support the company offers? Yes / No

    Use the support item of the rule set: free, independent debt advice or credit counseling, a hardship fund, a payment break, a social tariff or a hardship program. The customer's own mention of an adviser does not count as the agent signposting. Yes: The agent tells the customer about at least one such kind of help. No: The agent mentions no such help.

  12. How does the agent respond when the customer raises a dispute, a protection, a representative or a contact limit? Choice

    Use the protections and contact items of the rule set for the market field. Count a dispute of the debt, a legal protection or process, someone acting for the customer, or a request to limit contact. Under the UK rules, a Breathing Space in place stops collection for its whole length, and a debt adviser helping the customer arrange a repayment plan holds collection for at least 30 days; in both cases the agent must not press for a payment or a plan on the call. When the customer raises more than one, pick "Raised, carried on" if the agent carries on after any of them. Pick one option.

    • None raised The customer raises no dispute, legal protection, representative or contact limit in the call.
    • Raised, stopped or paused as required The customer raises at least one, and the agent takes the step the rule set requires, such as stopping or holding collection, sending a dispute to the right team, recording a contact limit or passing the account to the specialist team, and does not press for a payment or a plan after it.
    • Raised, carried on The customer raises at least one, and the agent keeps pressing for a payment or a plan, or brushes it aside, instead of taking the step the rule set requires.

  13. What is agreed about repaying the debt by the end of the call? Choice

    Judge where things stand when the call ends. Pick one option.

    • Affordable plan agreed The customer agrees a payment or plan they say they can manage.
    • Plan agreed with doubts A plan is agreed, but the customer says they may not keep it or cannot afford it.
    • Referred for support The customer is passed to a hardship fund, a specialist team or debt advice instead of, or before, agreeing a plan.
    • Collection paused The agent holds collection, for example while a dispute is checked or while an adviser works with the customer.
    • Pay in full The customer pays, or agrees to pay, the whole balance at once.
    • Nothing agreed The call ends with no plan, payment, referral or pause.

Lens columns

is_debt_conversation, is_debt_conversation_probability, financial_difficulty, financial_difficulty_average, debt_disputed, debt_disputed_probability, formal_protection_mentioned, formal_protection_mentioned_probability, representative_involved, representative_involved_probability, contact_limit_requested, contact_limit_requested_probability, vulnerability_disclosed, vulnerability_disclosed_probability, required_notices_given, required_notices_given_probability, affordability_asked, affordability_asked_probability, pressure_used, pressure_used_probability, support_signposted, support_signposted_probability, continued_after_protection, continued_after_protection_probability, plan_outcome, plan_outcome_probability

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