Prior posts discussed offshore outsourcing and TransUnion. Laurie has problems with TransUnion's credit monitoring service, TrueCredit, and support from its call center. Laurie is worried that if TransUnion and TrueCredit outsource portions of their operations, she won't have the same protections she would have otherwise -- since data security laws vary in other countries. I'd promised Laurie that I'd try to find some answers to her questions.
A wider search found information about TransUnion's participation in industry events for outsourcing professionals. The International Association of Outsourcing Professionals published information about a June 2007 event:
"Performance Monitoring Goals and Requirements for BPO Operations (Call Centers)
Brad Rubin, Director of Operations for TransUnion Interactive (formerly TrueCredit)
Brad Rubin is responsible for managing all BPO operations where he has transformed the service operations into a global multi-site operation. Prior to TransUnion, Brad was with Accenture in San Francisco.
- Overview of the business requirements for using tools to monitor the overall performance of BPO Call Center Operations
- Discussion of the functionality needed and the types of tools that were examined to achieve TransUnion’s goals.
So, it appears that TransUnion, parent company, and TrueCredit both perform offshore outsourcing. This is the first time I have ever heard of a credit monitoring service that performs offshore outsourcing. According to a 2006 Janeeva, Inc. press release:
"Janeeva, Inc., the industry leader in ORM (Outsourcing Relationship Management) software, today announced that TrueCredit, a division of TransUnion and a provider of credit management services, has implemented Janeeva Assurance™ software to manage multiple outsourced vendor relationships. True Credit is experiencing rapid growth, and customer care via their call centers is critical to their success. With multiple offshore call center locations comes increased complexity that Janeeva helps manage."
So, TrueCredit has contracts with several outsourcing firms. According to a November 2006 entry at Outsourcing Magazine (OM):
"About Blogger Brad Rubin: Brad Rubin is currently the Director of Operations for TrueCredit, a wholly-owned subsidiary of TransUnion, LLC. While at TrueCredit, Mr. Rubin has been responsible for managing all business process outsourcing (BPO) operations. He has successfully transitioned the TrueCredit service delivery platform into a global, multi-site operation. In addition to his work at TrueCredit, Mr. Rubin is an active speaker within the outsourcing community. In 2006, he participated in the Outsourcing Relationship Management Forum at the University of Michigan and the Telecommunications Risk Management Association (TRMA), Summer Conference. In 2007, he will be presenting a case study entitled Managing Multi-Vendor Environments with Relationship Management Software at the International Association of Outsourcing Professionals (IAOP), World Summit."
The OM site provides Mr. Rubin's e-mail address and his blog address: www.sourcingprofessional.com. I scanned several posts in Mr. Rubin's blog. He mentioned TransUnion's offshore outsourcing activities with vendors in Manila (Philippines), Central America, and New Delhi (India). According to Mr. Rubin's blog, TransUnion is considering new offshore outsourcing arrangements in Cebu (Philippines) and Guatemala. While I haven't read all of the posts in Mr. Rubin's blog, so far I haven't seen any posts about data security or data breach notification.
Now, my friend Laurie knows that both TransUnion and TrueCredit perform offshore outsourcing. We now have idea of some of the country locations. We don't know yet which outsourcing firms. Maybe Mr. Rubin can help Laurie resolve her problems with TrueCredit's customer service department. Maybe Mr. Rubin can explain the scope of TrueCredit's offshore outsourcing activities. Maybe Mr. Rubin can explain the data security processes TransUnion takes to ensure the protection of Laurie's and others' credit information. Maybe Mr. Rubin can provide a list of the specific offshore outsourcing locations and firms.
Last weekend, I wrote to Mr. Rubin asking for answers to the questions above. In my e-mail message to Mr. Rubin, I shared Laurie's message and concerns. So far, I haven't received a response from him, or from anyone at TransUnion. If he responds, I will post his reply in the I've Been Mugged blog.
The economic reasons for companies to outsource work are understandable: to manage costs and stay profitable in a competitive business environment. That's one reason why I titled these posts, "Is It Wise...?" and didn't title it "Is It Profitable...?" Of course, outsourcing and offshore outsourcing are profitable. That's why companies do it.
My point is this: should they? Is it wise to offshore outsource work involving sensitive financial data? Is it wise to do so without informing consumers? Is it wise to do so if consumers prefer otherwise? Is it wise to do so if the company can't provide a high-quality call center operation?
There has to be a balance between a company's need to manage costs, and consumers' need to trust the companies they do business with. Consumers intuitively sense that there's less risk to their sensitive data if companies keep it within their country borders. Some experts have identified the data security risks of offshore outsourcing.
I'll bet that when given a choice, consumers prefer that their credit and financial data is kept within their country's borders, rather than being transmitted around the globe. It all goes to risk. The fewer places credit and financial data are transmitted, the less chances for lost or stolen data. More importantly, it is unclear about exactly which country laws govern the protection of consumer credit and financial data. It is unclear which country laws govern the notification when the company (e.g., TransUnion, True Credit) suffers a data breach by an outsource call center vendor in another country.
That data breach in another country may never happen, but if and when it does, consumers have a right to know - promptly.
More about this next week.