Your board report asserts good outcomes. Can your data evidence them?
Consumer Understanding and Consumer Support are evidenced almost entirely from customer communications data. In groups built by acquisition, that data sits across several systems, owned by nobody centrally. A two to three week review that establishes what you can evidence, what you cannot, and what has to change before the next cycle.
The Problem
The FCA reviewed the first round of annual board reports and was direct about what fell short. Reports asserted that customers understood communications and that support was adequate, without analytical evidence behind the conclusion. Reports stated that remediation had happened, without confirming it worked.
Two of the four outcomes are communications outcomes. Consumer Understanding is evidenced by what you sent, to whom, whether it was received, whether it was read, and whether the customer acted. Consumer Support is evidenced by what happened when they did not.
That evidence lives in your CRM and communications platforms. In a firm that grew by acquiring other firms, it lives in several of them.
Nobody set out to make it unevidenceable. The brand consolidated. The compliance function consolidated. The customer communications layer underneath did not, because it was never anybody's job to consolidate it.
What usually goes wrong
The same customer exists more than once. Across brands, across platforms, with different identifiers. Outcome monitoring at group level is therefore an estimate, not a measurement.
Contact rules are local. Suppression, frequency, vulnerability flags and consent are applied per system. There is no group answer to how a vulnerable customer is treated, only several answers.
Sends are recorded, outcomes are not. Delivery, open and click data exists. Whether the communication achieved understanding, and what happened when it did not, is inferred rather than evidenced.
Remediation is asserted. The board is told an issue was fixed. The data that would confirm the fix was effective sits in the system that caused the issue.
Nobody owns it. Compliance owns the obligation. Marketing owns the sending. Neither owns the layer in between.
The Review
Two to three weeks. Read-only. No system changes, no vendor selection, no disruption to the reporting cycle.
Week one. Interviews with the people who produce the report, the people who send the communications, and the people who own the platforms. Documentation review. Access is read-only throughout.
Week two. Assessment of what your communications data can currently evidence against Consumer Understanding and Consumer Support, brand by brand. Identification of where the evidence chain breaks, and why.
Week three. Findings, prioritised remediation, and the operating model changes required to make the next cycle defensible.
What you receive
A written assessment covering:
What each brand can and cannot evidence today, rated Strong, Moderate or Developing
Where customer identity fragments across the group, and the effect on outcome monitoring
How contact rules, suppression, consent and vulnerability handling differ by brand
The gaps most likely to attract supervisory challenge, rated High or Medium impact
A prioritised remediation sequence with ownership recommendations
What must be true before the next annual report to evidence rather than assert
A structured walkthrough with the report owner and, if useful, with the board.
Scope
This review addresses the customer communications and data layer that feeds your board report.
It does not write your board report, assess your products, price your services, or advise on regulatory interpretation. Those belong with your compliance function and your regulatory advisers.
The work is operational. It establishes whether the evidence your compliance colleagues need actually exists, and what to do where it does not.
Who this is for
Regulated firms with more than one customer-facing brand, particularly those assembled through acquisition. Wealth and advice consolidators. Insurance broking groups. Any firm where the customer communications estate was inherited rather than designed.
The people who commission it are usually the Chief Operating Officer, the Chief Customer Officer, the Director of Commercial and Customer, or the individual accountable for compliance oversight.
Why Saiga
Nine years inside CRM and lifecycle functions at Disney+, Barclays, Informa and ICAEW. Enterprise scale, regulated environments, and the platforms this work runs on: Salesforce Marketing Cloud, Braze, Eloqua, HubSpot, Dynamics 365, Dotdigital.
Saiga is independent of every vendor. There is no implementation to sell you afterwards and no platform to recommend.
After the review
Most firms find the review answers the immediate question and creates a second one: who now owns the remediation.
Saiga can deliver that work, or govern it while your team delivers it. Neither is assumed, and neither is priced into the review.
Price
From £9,750. Fixed. Two to three weeks.
The next board report is a year away. The evidence problem is not.
Remediation identified this cycle has to be delivered and proven before the next one. That work starts now, or it starts late.
FAQs
Is this a compliance service?
No. It is an operational review of the customer communications and data layer that your compliance function depends on. Regulatory interpretation stays with your advisers.
Will you need system access?
Read-only access is sufficient. Nothing is changed, configured or migrated during the review.
We already have a CRM team.
Then this is probably not for you. The review is built for groups where responsibility for the communications layer is distributed across brands rather than held centrally.
Can this be done before 31 July?
Not credibly, and it should not be attempted. The review is most useful once the current report is approved and the gaps in it are known.
Do you work with our existing agencies and platforms?
Yes. Saiga does not replace them and does not compete with them.