Global Debt Recovery views complaints as a chance to put things right for the person that has made the complaint, as well as an opportunity to learn and improve for the future.
The aim of this policy is:
- To provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint
- To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint
- To make sure that all GDR staff know what to do should a complaint be made
- To make sure all complaints are investigated fairly and responded to in accordance with our regulators
- To gather information which helps us to improve what we do
A complaint is any expression of dissatisfaction, whether justified or not, about any aspect of Global Debt Recovery, or our clients.
This policy applies to all customers who wish to make a complaint. It is:
- Applied by staff in the Collections Team who are responsible for the recovery of overdue debt
- Applied by all staff in the Compliance and Call Audit departments who are responsible for the monitoring of the Collections Team
- Applied by staff in the Compliance Team
The benefits of having a robust complaints policy in place include:
- Effective engagement with customers who have cause to complain reduces levels of unsatisfaction
- Improves our relationship with our customers
- A reduction in the number of aggravated customers
- Less distressing experiences for both the customer and staff members, allowing them to be more empowered to make decisions that result in better outcomes
- Successful investigation and resolution of complaints
A failure to clarify, review and maintain our complaints policy may result in the following:
- Customer dissatisfaction/distress
- Involvement from regulators or ombudsman
- Confusion and lack of understanding for our customers and employees
- Risk to our reputation
- Ineffective compliance with regulatory bodies
- Financial impact for our clients
1.3.2 These procedures should
(1) Allow complaints to be made by any reasonable means; and
(2) Recognise complaints as requiring resolution
1.3.2A These procedures should, taking into account the nature, scale and complexity of the respondent’s business, ensure that lessons learned as a result of determinations by the Ombudsman are effectively applied in future complaint handling, for example by:
analysing any patterns in determinations by the Ombudsman concerning complaints received by the respondent and using this in training and development of the individuals dealing with complaints in the respondent; and
1.3.3 In respect of complaints that do not relate to MiFID business, a respondent must put in place appropriate management controls and take reasonable steps to ensure that in handling complaints it identifies and remedies any recurring or systemic problems, for example, by:
Considering whether such root causes may also affect other processes or products, including those not directly complained of; and
Correcting, where reasonable to do so, such root causes
1.3.4 In respect of complaints that relate to MiFID business, a firm should put in place appropriate management controls and take reasonable steps, in the same way as for complaints that do not relate to MiFID business (see DISP 1.3.3 R and DISP 1.3.3B G), in order to detect and minimise any risk of compliance failures (SYSC 6.1) and to comply with Principle 6 (Customers’ interests).
1.3.6 Where a firm identifies (from its complaints or otherwise) recurring or systemic problems in its provision of, or failure to provide, a financial service, it should (in accordance with Principle 6 (Customers’ interests) and to the extent that it applies) consider whether it ought to act with regard to the position of customers who may have suffered detriment from, or been potentially disadvantaged by, such problems but who have not complained and, if so, take appropriate and proportionate measures to ensure that those customers are given appropriate redress or a proper opportunity to obtain it. In particular, the firm should:
ascertain the scope and severity of the consumer detriment that might have arisen; and
1.3.7 (1) A firm must appoint an individual at the firm, to have responsibility for oversight of the firm’s compliance with DISP 1.
1.3.8 Firms are not required to notify the name of the individuals to the FCA or FOS but would be expected to do so promptly on request. There is no bar on a firm appointing different individuals to have the responsibility at different times where this is to accommodate part-time or flexible working.
investigate the complaint competently, diligently and impartially, obtaining additional information as necessary;
assess fairly, consistently and promptly:
the subject matter of the complaint;
whether the complaint should be upheld;
what remedial action or redress (or both) may be appropriate;
taking into account all relevant factors;
offer redress or remedial action when it decides this is appropriate;
explain to the complainant promptly and, in a way that is fair, clear and not misleading, its assessment of the complaint, its decision on it, and any offer of remedial action or redress; and
comply promptly with any offer of remedial action or redress accepted by the complainant.
all the evidence available and the particular circumstances of the complaint;
1.4.3 The respondent should aim to resolve complaints at the earliest possible opportunity, minimising the number of unresolved complaints which need to be referred to the Financial Ombudsman Service.
1.4.4 Where a complaint against a respondent is referred to the Financial Ombudsman Service, the respondent must cooperate fully with the Financial Ombudsman Service and comply promptly with any settlements or awards made by it.
1.5.4 Where the respondent considers a complaint to be resolved under this section, the respondent must promptly send the complainant a ‘summary resolution communication’, being a written communication from the respondent which:
indicates whether or not the respondent consents to waive the relevant time limits in DISP 2.8.2R or DISP 2.8.7R (Was the complaint referred to the Financial Ombudsman Service in time?) by including the appropriate wording set out in DISP 1 Annex 3R;
provides the website address of the Financial Ombudsman Service; and
refers to the availability of further information on the website of the Financial Ombudsman Service.
1.5.5 The information regarding the Financial Ombudsman Service required to be provided in a summary resolution communication should be set out clearly, comprehensibly, in an easily accessible way and prominently, within the text of those responses.
the respondent considers that doing so may better meet the complainant’s needs; or
1.5.7 An example of DISP 1.5.6G(1) may be where a respondent is aware that a complainant is visually impaired. An example of DISP 1.5.6G(2) may be where a respondent has been communicating with a complainant about a complaint by telephone.
send the complainant a prompt written acknowledgement providing early reassurance that it has received the complaint and is dealing with it; and
ensure the complainant is kept informed thereafter of the progress of the measures being taken for the complaint’s resolution.
a ‘final response’, being a written response from the respondent which:
accepts the complaint and, where appropriate, offers redress or remedial action; or
offers redress or remedial action without accepting the complaint; or
rejects the complaint and gives reasons for doing so;
encloses a copy of the Financial Ombudsman Service’s standard explanatory leaflet;
provides the website address of the Financial Ombudsman Service;
indicates whether or not the respondent consents to waive the relevant time limits in DISP 2.8.2 R or DISP 2.8.7 R (Was the complaint referred to the Financial Ombudsman Service in time?) by including the appropriate wording set out in DISP 1 Annex 3R; or
a written response which:
explains why it is not in a position to make a final response and indicates when it expects to be able to provide one;
informs the complainant that he may now refer the complaint to the Financial Ombudsman Service: indicates whether or not the respondent consents to waive the relevant time limits in DISP 2.8.2 R or DISP 2.8.7 R (Was the complaint referred to the Financial Ombudsman Service in time?) if it becomes apparent that the complaint has been made or is referred outside those time limits;
encloses a copy of the Financial Ombudsman Service standard explanatory leaflet; and
provides the website address of the Financial Ombudsman Service.
- To register a complaint please contact our Customer Relationship Manager by email firstname.lastname@example.org or phone 020 8336 7000, Monday to Friday between 8am and 6pm.
We want to give our customers the best possible service. We also know that sometimes we get it wrong. When that happens we want to know about it, put it right and learn from it.