Complaints Handling
Table of Contents
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Document Control
1.1 Document Change History
| Version |
Date |
Description |
Section Changed |
Author |
| 1.0 |
06/2014 |
New procedure |
N/a |
Garry O'Sullivan |
| 1.1 |
01/2024 |
Update |
Contact details |
Garry O'Sullivan |
1.2 Circulation List
| Name |
Role |
Sign off |
Review |
For Info |
Comments |
| Garry O'Sullivan |
Owner |
Y |
Y |
|
|
| Diarmuid Moloney |
|
Y |
Y |
|
|
2.0 Introduction
This document outlines the full process and procedure to be followed when handling a complaint received by or against SuperValu Financial Services Ltd.
Customer Complaints are managed in compliance with the Consumer Protection Code (CPC) guidelines at all times and without exception and in addition, all complaints are handled with a view to achieving a satisfactory outcome for the customer in the fastest possible time. All complaints relating to the Insurance Product will be handled by the insurers of the SuperValu Financial Services Ltd Insurance scheme and not by the SuperValu staff in store. All complaints made to SuperValu staff in respect of information provided by SuperValu Financial Services Ltd or the SuperValu store in which the advertising material is placed, will be handled by a core team in SuperValu Financial Services Ltd under the supervision of the Head of Risk and Compliance.
2.1 Scope
This document covers all complaints regardless of source, reason or cause that are received by SuperValu Financial Services Ltd, or notified to them. The process to be followed applies to each complaint regardless of whether it was received by phone, electronically or physical mail.
2.2 Objectives
The objectives of this document are to:
- Provide a definition of a complaint
- Provide a consistent framework for handling customer complaints
- To ensure that all complaints are handled in a fair and transparent way, and resolved in the fastest time possible for the customer
- To provide a defined audit and monitoring program for the quality control of complaint handling
- To ensure that all employees of SuperValu Financial Services Ltd and their partners understand their obligations relating to complaints
- To ensure customer complaints are managed in compliance with the Consumer Protection Code
The objectives of the SuperValu Financial Services Ltd Complaints Handling policy are to:
- Address reported customer dissatisfaction, quickly, courteously and effectively
- To ensure a fair and reasonable resolution to the complaint
- To identify the root-cause and address it to avoid a re-occurrence of complaints which can be avoided
- To ensure a consumer understands how to proceed if they remain dissatisfied with the outcome of their complaint
- To be compliant at all times
- To provide all managers and relevant employees with data and information to enable them to understand the volumes, causes and impact of complaints received
- To ensure all employees are aware of the scale, outcome and impact of complaints to the customer
- To provide the process owners with visibility of the adherence with the objectives of this policy
2.3. Definitions / Interpretation
|
Term
|
Definition
|
|
Complaint
|
Any expression of grievance or dissatisfaction, either verbally or in writing, in connection with: The provision of a product or service to a consumer by us or any one of our Service Providers, or the failure to provide a product or service to a consumer.
|
|
FSOB
|
Financial Services Ombudsman
|
|
Fully Upheld complaint
|
Complaint where root cause analysis determines that there has been a failing on the part of SuperValu Financial Services Ltd in terms of service, product offering, etc.
|
|
Not upheld complaint
|
Complaint where root cause analysis determines that there has been no failing on the part of SuperValu Financial Services Ltd in terms of service, product offering, etc.
|
|
Upheld in Part
|
Breakdown in communication on the customer and SuperValu Financial Services Ltd behalf, the resolution is a mutual compromise.
|
|
Working Days
|
Any day excluding a Saturday, Sunday or Public Holiday within Ireland.
|
2.4 Guidance - Complaint states
| Open |
A complaint that has yet to be resolved. |
| Reopen |
A complaint that was previously closed correctly but additional information has come to light that requires further investigation. The complaint is awarded a status of ‘re-opened’.
CPC timeframes commence from the date the complaint was reopened as it is permitted that these initiate re-start of the CPC timeframe |
| Closed |
A complaint is moved to "closed" status when:
- The complainant has confirmed they do not want to proceed with their complaint
- The complainant has been provided with a full and accurate response to their complain
- A settlement has been issued to the customer as part of the final resolution
- A settlement cannot be reached and the final resolution states that the customer can refer to the FSOB or
- We have requested outstanding information and chased this from the consumer at least twice which they have not provided within 40 working days. As a result we have closed the case and sent the final response letter stating the reason for closing the case
|
| Refer to Ombundsman |
The case has now been referred/ investigated by the FSOB.
|
3.0 Complaint Handling
3.1 Definition of a Complaint
Any expression of grievance or dissatisfaction by a consumer, either verbally or in writing, in connection with:
- The provision of a product or service to a consumer by SuperValu Financial Services Ltd Insurance or any one of our Service Providers, or
- The failure of SuperValu Financial Services Ltd to provide a product or service to a consumer
3.2 What is not a Complaint?
- Any dissatisfaction over delays arising for tactical purposes such as fraud are not deemed complaints
- Complaints about a service not provided by SuperValu Financial Services Ltd e.g. Issue with shopping experience, Real Rewards points, quality of grocery etc
- Feedback regarding a price increase that has occurred within the provision of the standard business of providing insurance, ( e.g. Inflation at renewal, increase due to penalty points, or other underwriting rules) as long as the increase in price is not in breach of any legislation
3.3. Type of Complaint
There will be two distinct types of complaint
1. Insurance Company Related Complaints
2. Complaints against SuperValu Financial Services Ltd
3.4 Insurance Company Related Complaints
Any complaint that relates to claims handling, product servicing, policy terms and conditions, online registration etc. must be dealt with by the Insurance Company, underwriting the product. For all complaints of this nature the following procedure applies:
- Identify the main cause of complaint
- Identify the insurance product about which the complaint is being made
- Ensure that the complaint is against the product. E.g. T&C’s, claims decision etc
- Provide the Insured with the appropriate contact details for the product
- For Travel Insurance contact.. 0818 01 01 01
- For Home and Motor contact…. 0818 01 01 01
- For Life and Mortgage Protection contact 0818 01 01 01
- If complaint is via post, forward the letter of complaint to the appropriate company
- If the complaint is via telephone, transfer the complainant through to the relevant company
- Please note all subsequent correspondence in relation to this type of complaint will be between the Insurer and the customer as this complaint will be handled directly and solely by the Insurer
3.5. SuperValu Financial Services Ltd Related Complaints
- These complaints will relate to information provided to the consumer by SuperValu Financial Services Ltd and SuperValu employees who will display advertising material in store and distribute information leaflets, a Key Facts document regarding the insurance offer
- SuperValu staff are not permitted to advise, recommend or sell insurance on behalf of SuperValu Financial Services Ltd
- They are only allowed to introduce the products by way of informing the customer that they are available, providing them with the details of how to enquire about the product, i.e. online, by phone etc. and providing them with leaflets outlining the product offering as per the Key Facts Document which will be displayed in store
- If there is a complaint against SuperValu staff or SuperValu Financial Services Ltd in relation to this process the following procedure must be followed:
- Transfer the customer or forward the correspondence to Garry O’Sullivan, Compliance Officer with SuperValu Financial Services Ltd
- The Compliance Officer will then have the complaint handled in accordance with Chapter 10 of the Consumer Protection Code 2012 and it will be adjudicated on by an appropriately qualified person as set out under the Minimum Competency Requirements
- The following process will then be followed:
- All complaints will be logged on the Complaints Register once received
- We will endeavour to handle and resolve the complaint within 24 hours of receipt
- Where we cannot resolve within 24 hours, we will issue an acknowledgement letter within 5 business days of the receipt of the complaint
- This letter can be by post or email but must be in a durable medium
- We will provide the customer with the name and contact details of the person handling the complaint up to the point of resolution or until the complaint cannot be progressed any further
- In intervals of not more than 20 business days we will update the customer by letter or another durable medium on the current status of the complaint. A copy of this correspondence will be retained with the complaint file
- We will endeavour to resolve all complaints within 40 business days, however if this is not possible we will advise the customer in writing of the reasons why the complaint is still outstanding and the anticipated timeframe in which we expect to resolve the complaint. At this stage we will also advise the customer of their right to refer the complaint to the relevant Ombudsman, and will provide the contact details of that Ombudsman
- Within 5 business days of completing the investigation of the complaint we will inform the customer by letter or another durable medium of the outcome of our findings, the offer if any being made, the customer’s right to refer the matter to the Ombudsman and the contact details of such Ombudsman
4.0 Records of Complaints
SuperValu Financial Services Ltd will maintain an up-to-date log of all complaints from consumers subject to the complaints procedure. This log will contain:
- details of each complaint
- the date the complaint was received
- a summary of our response(s) including dates;
- details of any other relevant correspondence or records
- the action taken to resolve each complaint
- the date the complaint was resolved; and
- where relevant, the current status of the complaint which has been referred to the relevant Ombudsman.
SuperValu Financial Services Ltd will maintain up to date and comprehensive records for each complaint received from a consumer.
SuperValu Financial Services Ltd will undertake an appropriate analysis of the patterns of complaints from consumers on a monthly basis including investigating whether complaints indicate an isolated issue or a more widespread issue for consumers. This analysis of consumer complaints must be escalated to the Head of Risk and Compliance and senior management in SuperValu Group. The appropriate remedial action will be taken immediately to close out any breach or gap.
If an error is identified this will be handled and recorded in accordance with errors provision of Chapter 10 of the Consumer Protection Code 2012 and as outlined in the Insurance Intermediary Compliance Manual.
5.0 Governance and Reporting
5.1 Weekly Complaints Report
A weekly complaints report will be compiled by the Head of Risk and Compliance in SuperValu Financial Services Ltd in relation to complaints about the insurance product or service.
This will be shared with the senior management team and will be used to identify trends and to take immediate remedial action to close out any gaps or breaches identified. It will detail:
- Number of complaints received in previous week
- % of complaints resolved on the day reported
- % of complaints resolved within 5 working days
- % of complaints resolved within 20 days
- Number of complaints outstanding
- CPC breaches identified
- % complaints audited and audit outcome
- Top complaint categories
- Any complaints referred to the Ombudsman and the outcome if known
- Root cause analysis and follow up actions
5.2 Monthly Complaints Reporting
- On a monthly basis we will receive MI Reporting from our Insurers which will contain the following information
- Number of complaints received in the month
- % of complaints resolved within 5 working days
- % of complaints resolved within 20 days
- % of complaints resolved within 40 days or final letter issued if not possible to progress any further
- Number of complaints outstanding
- CPC breaches identified
- % complaints audited and audit outcome
- op complaint categories
- Any complaints referred to the Ombudsman and the outcome if known
- Trend on complaint numbers and % resolved against previous months
- Root cause analysis and follow up actions
5.3 Monthly Review Meeting
Complaints’ reporting is a standard agenda item on all Service agenda’s and Senior Management Team meetings. The monthly report and Root Cause Analysis will be discussed.
5.4 Root Cause Analysis and Corrective Action
Root Cause Analysis and Corrective action is reported on in the Monthly Complaints report. Where appropriate, action owners will be assigned and progress reported on at the next meeting.
6.0 Training
All employees and customer facing agents must attend a training workshop on complaints handling on an annual basis. This will ensure all staff are;
- Aware of the correct complaints handling procedure to which they must adhere at all times
- Equipped with the tools to allow them to effectively handle complaints when they are initially received
- This training workshop must be facilitated by each business area and every employee must attend the workshop
Attendance by all individuals within the business is a mandatory requirement for both induction (including back to work individuals) & refresher sessions. The training will be broken down into 2 distinct areas;
- Complaints Handling Process & Procedures
- Soft skills on knowing how to handle complaints and / or difficult customers
