Complaint Handling Guide

What is a Complaint?

The FCA defines a complaint as:

 'Any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about the firm's provision of, or failure to provide, a financial service'.

It alleges how you have suffered (or may suffer): financial loss; material distress; or. material inconvenience.

Financial Loss – Our actions have caused a customer to suffer a direct financial loss which can be quantified.

For example, the client’s direct debit was set up for the wrong date which caused a default and bank charges.

Material Distress – Our actions have directly affected a customer’s emotional state. This may be stated or implied, and would include the following types of feelings…upset, embarrassment, anxiety, stress, suffering, sorrow, pain (this list is not exhaustive)

Material Inconvenience – Our actions have had a direct impact on a customer’s life, causing a disproportionate amount of disruption or difficulty.

For example, we haven’t renewed the client’s policy correctly, the client receives a police notice and cannot drive their car for a time period.

Process for Managing Complaints

Complaints can be verbal or written. We MUST NOT ask a complainant to put their complaint in writing, to do so breaches our procedures and FCA regulation. Valid complaints can be made against:

• The firm itself;
• The product provider (Insurer);
• The claims handling firm;
• Or any other third party associated with the firm. (Breakdown)

Telephone/Live Chat/Email complaints

• Log the complaint on OGI by selecting Process Frames>Client Complaint/Feedback and complete the fields
• Try to resolve the complaint within your delegations for compensation (see delegations’ allowance below)
• If you are unsure or uncomfortable dealing with a complaint always refer to management for advice.
• Complaints need to be resolved OR an acknowledgement issued if more time is needed within 3 working days.
• If the complaint needs more work or you cannot resolve it within 5 days refer to the Customer Success Manager/Customer Outcomes Manager for investigation, i.e. listening to calls etc.
• Add clear notes of the complaint throughout, keep them factual without opinions as notes can be requested by the client.
• If compensation is to be paid refer to a manager on how this is issued.
• When the complaint has been resolved and the final response issued update Zendesk and close the ticket.

Third party complaints

If a client is complaining about a Third Party (CCA, AXA Assist, the Insurer) log the complaint as normal on OGI and mark it against the insurer, make notes of the details of the complaint and mark it as resolved but not upheld.

Pass the complaint to the Third Party to deal with directly.

Roadside Assistance - Complaint email for AXA assist AA_IE_SM_Athlone_Complaints [e-mail] and CC Elaine Little [e-mail]

CCA complaints - Gillian Miller

Smartfob Keycare - [e-mail]

Insurer – Complaint info will be in the insurer policy book

Courtesy Car - Policy Booklet asks the client to send their complaint to Stroll so we are first point of contact on this. Refer these cases for further investigation.

Legal Expenses - [e-mail] 

CBPF - [e-mail].

Complaint Timescale

Complaint Terms & Info

Upheld/Not Upheld – An upheld complaint means that we have made an error and we agree with the client’s complaint. Not upheld means that we did not find any errors on our part.

Acknowledgement letter – All complaints must be resolved or acknowledged within 3 days. If we need more time to resolve the complaint an acknowledge letter is issued stating that we have received the complaint and we are working on it.

FOS – Financial Ombudsman Service is a service that settles complaints between consumers and businesses that provide financial services. They resolve disputes fairly and impartially and have the power to put things right. Clients can only go to the FOS, free of charge, after we have issued our final response letter which will have the FOS contact details, clients must do this within 6 months of complaining. Each case that goes to the FOS costs us £750.

DSAR – Data Subject Access Request. This is any request for data by the client, these include letters, call recordings, policy notes etc. We have 30 days to provide the client with their requested documents. All DSAR to be sent to Group Compliance.

Ex-Gratia – An ex-gratia payment is a goodwill payment made to resolve a complaint. A client can accept a goodwill payment and still take their case to the FOS.

What is Negative Feedback?

Negative Feedback is a reaction, criticism, or comment from a client about a service we have provided. The difference between this and a complaint is that it has not caused the client financial loss, material distress or material inconvenience.

Negative Feedback examples:

• Phone options are confusing
• MTA rates/Admin fees too high
• Client doesn’t like the wording of our letters
• Client didn’t receive documents

Process for Negative Feedback

• Log the feedback on OGI by selecting Process Frames>Client Complaint/Feedback and select Negative Feedback - complete all the relevant fields
• Pass any relevant information to the correct department. i.e. IVR issue to Marketing/IT
• Negative feedback will be reviewed weekly, and changes made if needed.

Delegations

Compensation Delegations
Role	Sign Off Needed	Maximum Payment
Customer Success Team Member	Manager Sign Off	£30
Customer Success Manager		£100
Customer Outcomes Manager		£250
Senior Management	Anything over £250 requires Director Sign off	£250+

Refer to management re issuing payment to client.