Complaints Policy

1. What is this policy?

Bristow & Sutor Group 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 seriously and we seek feedback from our customers and clients so that we can respond effectively and make improvements where necessary.

This policy outlines our commitment to receiving, addressing, and acting upon the feedback we receive via complaints to continually improve the way we deliver our services.

 

2. 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.

 

3. 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.

When a customer expresses dissatisfaction, the colleague who receives the communication tries 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 should try to resolve the matter without the need for the formal complaints process within 3 days.

In cases where neither the recipient nor the subject matter expert or manager can resolve the matter, the complaint is escalated to the Complaints Team, who will issue an acknowledgment of the complaint within one working day. 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 investigated fully. 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 circumstances where this is not possible, then complaints will be responded to in writing.

 

Overview of Complaints Investigation Process (Non-Regulated)

Stage 1

The Customer Resolution Specialist investigates the complaint and issues a full response to the complainant within ten days. Where it is not possible to complete a satisfactory investigation within that time, the Customer Resolution Specialist sends a holding communication to the complainant, outlining the reason for the delay and confirming the timescale for a full response.

If the complainant is dissatisfied with the response at this stage, they can request for the complaint to be escalated to Stage 2. This request can come via any communication channel.

 

Stage 2

The complaint is escalated to the Group Head of Customer Services who reviews the original complaint, the investigation and the Stage 1 response, and issues a full response to the complainant within ten days. Where it is not possible to complete a satisfactory investigation within that time, a holding communication will be sent to the complainant, outlining the reason for the delay and confirming the timescale for a full response.

If the complainant is dissatisfied with the response at this stage, they can request for the complaint to be escalated to Stage 3. This request can come via any communication channel.

 

Stage 3

The complaint is escalated to the Chief Operating Officer who reviews the original complaint, the investigation and the Stage 2 response, and issues a full response to the complainant within ten days. Where it is not possible to complete a satisfactory investigation within that time, a holding communication will be sent to the complainant, outlining the reason for the delay and confirming the timescale for a full response.

 

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

While we strive to resolve all complaints that are raised to us through our complaints process, in some cases complainants may feel we are unable to deal with the complaint to their satisfaction. In these cases, we provide information about external escalation routes which are suitable for their case type.

Local Authority Debts or Local Government Body (Council Tax, Non-Domestic Rates, Penalty Charge Notices, Commercial Rent Arrears)

Complainants can progress their complaint to the Local Authority who instructed us to recover the debt.

 

Information Commissioner’s Office

If your complaint relates to how or why we are processing an individual’s personal information, 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 Information Commissioner's Office (ICO)  

 

4. Who does the policy apply to?

 

Parties to a Complaint

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.

 

Customer Complaints

Complaints may be made by customers who we contact in order to resolve debts in their name.

 

Client Complaints

Complaints may be made by clients who have instructed us to resolve debts on their behalf.

 

Third Party Complaints

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

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.

 

5. How to comply with this policy

 

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.

 

6. Are there other interrelated policies?

This policy is related to and impacted by our Customer Service Framework and our Vulnerable Customers policy. It is applied in tandem with the Complaints Procedure documents.

 

7. 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 Feedback 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 Service 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.

 

8. 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.

 

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.