Part Three: How to Establish Quality Control

Theresa Farrell | April 27, 2022

You’ve set up your Law Enforcement Response Program (using tips from Part 2 of our blog series). You’ve trained your law enforcement specialists. They have process documentation to follow. You’ve made it easy for Law Enforcement to know how to submit their requests. But how do you know if everyone is following through with the plan? Don’t wait for Law Enforcement to push back notifying you of mistakes. Establish a Quality Control (QC) Process.

As we’ve discussed in previous parts of the series, there are risks involved when fulfilling Law Enforcement requests. There is a need for accuracy amidst high volumes of legal requests, which can lead to errors. One of the biggest risks is over- or under-disclosing data. If you over-disclose, you are compromising your customer’s data privacy. If you under-disclose, you may interfere in a criminal or civil investigation and face legal repercussions. Developing a Quality Control process and scoring system will incentivize legal response specialists to maintain high standards, thus reducing errors. 

What is Quality Control?

Quality Control is a monitoring process used to ensure that quality of work product is maintained and consistent. It allows you to confirm that everyone is following the procedure and providing Law Enforcement with the correct data per the law and company policy. It can take many forms depending on the business. Quality Control for Law Enforcement Response programs involves reviewing requests to ensure they follow the protocols you’ve established and that the records contain the correct information.

The Basics

The first step is choosing who will review the requests. Whether they are a manager or a senior specialist, they should be detail oriented and have comprehensive knowledge of the process.

After choosing who will review, determine what records to inspect. Best practice is to establish randomization to prevent biased results. You will also need to determine the percentage of results you wish to review. This percentage can be adjusted over time according to your results. Following are some factors to consider.

  • How established is your program? Are you still putting your program together? Still figuring out terminology? Are you training new specialists? You may want to QC more requests.
  • What is the seniority of the Law Enforcement Specialist? You may review more records for newer specialists and fewer for those with seniority and proven results.
  • How many errors are you seeing? If there seems to be an increase in the number of mistakes, you may want to review more. If mistakes are few, you may be able to spend less time on reviews.

Now that you have determined the requests to QC, what should you look for? As a law enforcement response specialist, you will be most interested in outgoing quality control. Once the records are filled out and the data is pulled, the requests can be reviewed for completion and errors. Was the legal request valid? Is the contact information correct? Does the pulled data match the legal request? Did they search for the correct identifiers? Supply the correct amount of data? Are there typos? Make note of any errors and keep statistics of the results.

Setting Benchmarks

If you are going to be reviewing requests, you need to know why you are doing it. So, set measurable goals. Identify critical success factors and stakeholders. Goals should be achievable and measurable. They should be shared with the team so each member knows what is expected of them. Then determine how many requests should be completed on average per specialist and any allowance for errors.

You should also create a scoring system. While ideally the request is completely accurate, issues like pulling data for the wrong identifier, providing more information than requested, or returning the data to an incorrect contact have more consequences than smaller errors and therefore should have bigger consequences.

Providing Incentive

As you compare the results to your benchmarks, use them to make a plan for continuous improvement and disseminate the information you’ve found. Use the results as a learning experience and plan for what to do when benchmarks are not met. For example, if several specialists are making the same mistake, it shows areas where you may need to improve training or set up a process review.

QC should be a cycle. Review. Provide feedback. Improve.

QC can also help with employee reviews and merit-based compensation. Once legal requests have been quality checked by the reviewer, provide your specialists with feedback so they know where they need to make improvements. In addition, you can compare the specialist’s results to the average to help them understand their performance.

In short, if your company is receiving data requests from Law Enforcement, it’s important to fulfill those requests timely and correctly. As you begin your program, consider adding a Quality Control component. Creating a QC process, setting benchmarks, and using your results to make changes will increase accuracy and incentivize law enforcement response specialists to work diligently and grow in their role.

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Theresa Farrell

Theresa joined IP Services over a decade ago after graduating with a bachelor’s degree in Finance. She previously worked on both the Fraud Prevention and Privacy & Compliance teams. For most of her tenure, she has worked in Program Management as a Program Support Specialist which includes event planning, metrics reporting, program development and communication management.