What is this document?
This document is a simplified version of our Group Complaints Policy, for customers who have a complaint relating to action we’ve taken to recover regulated commercial consumer debts, for example a loan or a finance agreement. For more information about what is covered by this policy statement, see section 8 for the Financial Conduct Authority definition of a complaint.
You can still find the full version of our Group Complaints Policy here.
If you are not certain which policy statement applies to you, please be reassured that the first stage of the process is the same for all our customers, and we will provide more information about the complaints process in our response.
Who are we?
Bristow & Sutor Group (hereinafter referred to as “BSG”, “we”, or “us”) comprises Bristow & Sutor, Debt Recovery Plus Ltd., and Credit Style Ltd.
What is this policy?
BSG aims to achieve the highest possible standards in all areas of our business, and particularly in dealing with our customers and with those we contact regarding accounts we are collecting. There are of course times when things go wrong. We treat all expressions of dissatisfaction with our service seriously and we seek feedback from our customers and clients so that we can respond effectively and make improvements where necessary.
This policy statement outlines our commitment to receiving, addressing, and acting upon the feedback we receive via complaints to continually improve the way we deliver our services.
Why do we need this policy?
All companies will receive complaints from time to time, and it is vital that we use the information provided by our complaints to inform the way we develop our services. As we deal with a range of debt types across our different teams and locations, it is also important that we ensure that all complaints are dealt with fairly, accurately, and consistently, regardless of how the complaint is received or what it relates to. This policy is supported by our Complaints Procedure documents, which lay out in detail the process that each debt type follows as this may differ due to regulatory or industry requirements; however, in all cases our procedures are governed by the overarching principles outlined in this policy.
What is BSG’s approach to implementing this policy?
Complaints can be made via any channel by which we communicate to customers, clients, and third parties. This includes by telephone, by email, via our website contact form, by webchat, by post, by SMS and by WhatsApp where available.
If you, as the complainant require support in making a complaint, you can contact us via any channel and one of our colleagues would be pleased to assist you. This includes by telephone, by email, via our website contact form, by webchat, by post, by SMS and by WhatsApp.
When a customer expresses dissatisfaction with our service, the colleague who receives the communication will try to resolve it immediately where possible on the day of receipt. Where immediate resolution is not possible, the expression of dissatisfaction is escalated to an appropriate subject matter expert or manager who will try to resolve the matter without the need for the formal complaints process within a maximum of 3 working days.
In cases where neither the recipient nor the subject matter expert or manager can resolve the matter, the complaint is escalated to the Customer Resolution Team, which will issue an acknowledgment of the complaint within a reasonable timeframe. At this point, the complaint enters the relevant Complaints Investigation Procedure for the case debt type which can be found in that debt type’s Procedure document. The colleague that escalates the complaint to the Complaints Team has the responsibility to ensure it is correctly logged, and that the case is placed on hold while the complaint is investigated.
With all complaints, our aim must be to resolve the issue as early in the process as possible while ensuring the complaint is fully investigated. Where appropriate we will seek to resolve the complaint by telephone, as this affords the opportunity to provide a more personal and empathetic response in the quickest possible time. In circumstances where this is not possible, then complaints will be responded to in writing.
Overview of Complaints Investigation Process
The complaint is reviewed by a Customer Resolution Specialist who acknowledges the complaint within 5 working days. The Customer Resolution Specialist conducts a full investigation into the complaint with the applicable Line Manager and any other relevant colleagues. The Customer Resolution Specialist completes the Complaint Investigation Record, and issues a full response to the complainant within a maximum of four weeks. This Final Response will include details of the complaint, the investigation, and the actions taken to resolve it. It will also include information about the complainant’s rights under the Financial Ombudsman Service, or the Legal Ombudsman Service where the complaint relates to Legal Services.
Where it is not possible to complete a satisfactory investigation within four weeks, the Customer Resolution Specialist sends a holding communication to you within 15 days, as the complainant, outlining the reason for the delay and confirming the timescale for a full response. If a Final Response is not issued within eight weeks, you (as the complainant) will receive regular updates from us until the complaint is satisfactorily resolved. These updates will include details of your rights as the complainant under the Financial Ombudsman Service, or the Legal Ombudsman Service where the complaint relates to Legal Services.
Recording Complaints
Whether or not a complaint reaches the formal investigation process, it is recorded using the Complaints Recording Spreadsheet. The responsibility for initially recording a complaint lies with the colleague that receives the complaint, and the record is updated at every stage of the process to document the responsible party at each stage.
All complaints that progress to the formal investigation process are investigated using the Complaint Investigation Record. This record and any additional supporting information are saved to the case file. Records of all complaints are kept for three years.
Complaints About Our Clients
Sometimes we may receive complaints from customers relating to our client, or we may be told that our customer has lodged a complaint with our client directly. In these cases, we will ensure we pass this information to our client and place the case on hold until the complaint is investigated.
Where the client is FCA regulated, or where requested by the customer, this will be confirmed in writing.
External Regulation and Escalation Points
Credit Style Limited is a full member of the Credit Services Association and abides by its Code of Conduct. If the account is a private sector debt, but does not relate to a Consumer Credit Agreement, you (as the complainant) can refer you complaint to the Credit Services Association. Complaints must include a signed complaints form which can be downloaded from the following website: https://www.csa-uk.com/page/complaints
If you, as the complainant, aren’t able to submit your complaint in writing, you can contact the CSA to discuss this further:
By telephone on 0191 217 0775
By email to info@csa-uk.com
Information Commissioner’s Office
If the complaint relates to how or why we are processing your personal information as an individual, we have very able data protection teams and a Data Protection Officer and, in the vast majority of situations, will make best efforts to resolve the complaint ourselves. However, in the unusual situation where we are not able to resolve the issue, you should refer the complainant to the website of the Information Commissioner’s Office (ICO) at IInformation Commissioner's Office (ICO)
Legal Ombudsman Service
If the complaint relates to legal services we have provided to you, the Legal Ombudsman can help you if we are unable to resolve your complaint ourselves. They will look at your complaint independently and it will not affect how we handle your case. Before accepting a complaint for investigation, the Legal Ombudsman will check that you have tried to resolve your complaint with us first. If you have, then you must take your complaint to the Legal Ombudsman:
- Within 6 months of receiving a final response to your complaint; and,
- No more than 1 year from the date of act/omission; or,
- No more than 1 year from when you should reasonably have known there was cause for complaint.
By telephone on 0300 555 0333
By email to enquiries@legalombudsman.org.uk
By post to
Legal Ombudsman
PO Box 6167
Slough
SL1 0EH
Solicitors Regulation Authority
If your complaint relates to our behaviour as providers of legal services, for example if you believe we have behaved dishonestly, taken or lost your money, or treated you unfairly due to a protected characteristic, you can raise your concerns with the Solicitors Regulation Authority. More information is available on their website at: https://www.sra.org.uk/consumers/problems/report-solicitor/
Bristow & Sutor Group recognizes that complaints can come from a variety of different sources, and we have briefly outlined how our policy applies to each of these parties below.
Complaints may be made by customers who we contact in order to resolve debts in their name.
Complaints may be made by clients who have instructed us to resolve debts on their behalf.
Complaints may be made by individuals or organisations who are not directly connected to a case but have been affected by the actions of our business, or who are complaining on behalf of someone who has.
Anonymous complaints will be investigated as far as is possible and a record of the complaint will be kept in accordance with our normal procedure.
| Role | Responsibility |
|---|---|
| Management | Provide feedback and guidance to colleagues who receive complaints. |
| Governance, Risk & Compliance Team | Review compiled complaints outcomes to monitor risk level from complaints. |
| Customer-Facing Colleagues | Diffuse complaints where possible, accurately document and manage complaints where not. |
| Customer Resolution Specialist | Complete and document formal investigation process, provide complaints response to complainant. |
| Customer Resolution Manager | Review complaints responses for quality. |
| Group Head of Customer Service | Provide point of escalation for Stage 2 of complaints process. |
| Chief Operating Officer | Provide point of escalation for Stage 3 of complaints process. |
Are there other interrelated policies?
This policy is related to and impacted by our Customer Service Framework and our Group Vulnerability Policy. It is applied in tandem with the Complaints Procedure documents.
How will this Policy be Monitored?
Feedback and lessons learned from complaints will be provided to those involved in handling cases which gave rise to complaints via their manager on a timely basis.
Complaints are analysed for trends and common causes by Customer Resolution Specialists in conjunction with the Customer Resolution Manager and reported monthly to the Operations Senior Leadership Team to identify actions that can be taken to prevent the occurrence of similar complaints, and to continually improve our internal processes, training and the Complaints Process. Actions resulting from this analysis are tracked and reported by the Customer Feedback Manager, with escalation to the Group Head of Customer Services and Chief Operating Officer where necessary.
A complaint summary detailing relevant trends such as the volume of complaints as a percentage of total caseload and upheld vs not found will be reported to the Risk, Audit and Compliance Committee. All customer-facing colleagues and Customer Resolution Specialists receive annual complaint-handling training to ensure complaints are managed effectively.
Complaint responses will be regularly checked for quality and accuracy by the Customer Resolution Manager. This policy will be reviewed annually in line with an overview of the year’s complaints to ensure it remains effective and fit for purpose.
Definitions
Bristow & Sutor Group deals with a range of scenarios that can give rise to disputes; however, it is important to recognize that a dispute is not a complaint, and the resolution process is therefore different.
What is a dispute?
A dispute is a disagreement with certain facts of the debt itself. A dispute may include:
- Disputing the merits of a parking charge notice or penalty charge notice that has been registered against the customer.
- Disputing the customer liability for a debt that we are collecting.
Disputes do not constitute a complaint against our services and therefore cannot be resolved through the complaints process. Disputes should be dealt with as part of our normal customer service conversations.
What is a grumble?
A grumble is a communication received about dissatisfaction with our service or staff which does not seek redress. A grumble may include:
- A customer mentions the length of time they were waiting for the phone to be answered.
- A customer mentions they found it difficult to find information on our website.
Grumbles do not require elevation to the complaints process but provide a key source of feedback on friction in the customer experience and offer us additional opportunities for improvement.
What is a complaint?
A complaint is a communication received about dissatisfaction with our service or colleagues which seeks redress. A complaint may include:
- We have failed to do something we agreed to do..
- We have not acted within regulatory requirements.
- We have treated a complainant unfairly or rudely.
- We fail to provide information.
- The complainant is concerned with the quality of the service we provide.
“Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service, claims management service or a redress determination, which:
(a) alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and
(b) relates to an activity of that respondent, or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products or claims management services, which comes under the jurisdiction of the Financial Ombudsman Service.”
In order to be an FCA regulated complaint, the complainant must allege that they have suffered (or may suffer) one of the below:
- Financial loss – An example would be incurring bank charges as a result of our actions.
- Material distress – An example of material distress is a customer feeling highly stressed due to our collection strategy or the consequences of our actions could result in the customer feeling ill or not being able to sleep due to the worry.
- Material Inconvenience – An example of this would be a customer having to wait so long on hold that they missed an appointment.
The complaint must also be from someone who the Financial Ombudsman Service have jurisdiction over. This means any consumer accounts and the below guidelines for businesses:
If the complaint is about an event that took place before 1st April 2019, then complaints from micro-enterprises’, which means a business with:
- a turnover or annual balance sheet that does not exceed two million euros and
- fewer than 10 employees.
Or, if the complaint is for events that took place after 1st April 2019, we can also deal with complaints from small businesses that have:
- an annual turnover of less than £6.5 million (or its equivalent in any other currency); and either:
- a balance sheet total of less than £5 million (or its equivalent in any other currency); or
- fewer than 50 employees.
| Term | Definition |
|---|---|
| Our People | All directors, employees, contractors and all other people who undertake work for BSG. |
| Customer-Facing Colleagues | All employees and contractors who have direct contact with our customers, whether in person or via another medium of communication. |
| Customer | Parties who owe amounts to Clients of BSG and who BSG connects with to collect those amounts on behalf of clients. |
| Client | Third parties who have engaged one or more of the Trading companies to connect with and collect amounts owing to them by their customers. |
| Third Party | Individuals or organisations who are not directly connected to a case but have been affected by the actions of our business, or who are acting on behalf on someone who has. |
| Complaint | A communication received about dissatisfaction with our service or staff which seeks redress. |
| Grumble | A communication received about dissatisfaction with our service or staff which does not seek redress. |
| Dispute | A disagreement with certain facts of the debt itself. |
Bristow & Sutor group welcomes all client and customer feedback and all complaints, regardless of whether upheld or otherwise, are taken seriously and objectively reviewed.
Bristow & Sutor group uses feedback and complaints as an opportunity to identify root causes and implement improvements to our processes, procedures and interactions with clients and customers, ensuring lessons are learnt as we seek to continuously improve in order to provide all clients and customers with the best possible service and look to exceed expectations in delivering this.