Complaints procedure

How to complain

You can complain in writing or by phone. You don't need to use the word "complaint". If you tell us you're unhappy, we'll treat it as one. Please include your name, your claim reference if you have one, and what went wrong.

What happens next

1. We try to sort it out straight awayWithin 3 working days

   Many complaints can be resolved on the spot or within 24 hours. If we can't resolve your complaint within 3 working days, it moves to our formal complaints process.

2. We acknowledge your complaint in writingWithin 3 working days

   For a formal complaint, we write to you explaining our complaints procedure and when you can expect to hear from us.

3. A trained member of staff investigatesWithin 6 weeks

   Our Complaints Officer, or another trained manager, reviews all the documents, call recordings and information relating to your complaint and reaches a fair, unbiased decision.

4. We send you our final responseWithin 8 weeks

   We write to you with our findings and any action we will take or compensation we will pay. We will also tell you about your right to refer your complaint to the Financial Ombudsman Service.

If you're still unhappy

If you're not satisfied with our final response, or we haven't sent one within 8 weeks, you can refer your complaint to the Financial Ombudsman Service. It's free to use. You must contact them within 6 months of the date of our final response.

If your complaint is about how we have used your personal information, you can also complain to the Information Commissioner's Office, and you may be able to seek a remedy through the courts.

1Policy statement

Core Financial Compensation LLP's (the "Company") complaint handling policy and procedure has been created to meet general standards and requirements and complies with standard complaint handling procedures, including the Financial Ombudsman Service (FOS) regulations.

The aim of this policy is to ensure that all customer complaints, either written or verbal, are handled in a consistent and regulated manner and that further complaint incidents are mitigated and, where possible, prevented. Where a customer has cause to complain, the complaints handling procedure will be followed in every instance and a record will be made of the complaint's nature and details to help improve our services and reduce the occurrence of similar complaints.

2Purpose

The Company is committed to delivering a fair, open and clear process for complaints and to ensuring a satisfactory outcome for all customers who raise a complaint. We provide thorough staff training in our internal complaint handling procedures and support our staff in how to handle complaint situations face to face, in writing and on the telephone.

This policy sets out our intent and objectives for how we handle complaints, from offering a clear and approachable system for customers to complain, through to conducting root cause analysis on all complaints received to identify the cause, issues and corrective actions, and to implement measures to prevent reoccurrences where applicable.

3Scope

This policy applies to all staff within the Company (meaning permanent, fixed-term and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Company in the UK or overseas), and pertains to the processing of personal information. Adherence to this policy is mandatory and non-compliance could lead to disciplinary action.

4Objectives

For the purposes of this policy, a complaint is defined as any customer contact where a negative communication or outcome has occurred. The customer does not have to formally call their communication an official complaint, or request a response, for the Company to treat it as a complaint and follow the related procedures.

Our objectives for internal complaint handling

• To provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint.
• To ensure that our complaints procedure is fully accessible so that people know how to contact us to make a complaint.
• To make sure everyone at the Company knows what to do if a complaint is received.
• To make sure all complaints are investigated fairly and in a timely way.
• To gather information which helps us to improve what we do and how we do it.
• To ensure that the Data Protection Officer (or appointed person) is involved in any complaints relating to personal data.

Our objectives for the complaint handling process

• Complaints will be investigated and responded to within 8 weeks from the initial customer contact.
• Customers will be sent a copy of the formal complaints procedure along with any relevant or mandatory consumer leaflet (such as the Financial Ombudsman Service leaflet).
• Complaint responses will always be provided in writing (unless the complainant asks for an alternative form of communication, which will be provided in addition to the written format).
• Complaint procedures and forms will be available on the Company website, and on written or verbal request.
• All complaints will be investigated by a trained member of staff and a full outcome summary provided to senior management.
• Complaint records will be used to revise Company procedures and to improve communication and business practices where applicable.
• Complainants are advised of their rights and given details of any relevant body they can refer their complaint to, with contact details (for example the FOS, the FCA or the ICO).

5Procedures and guidelines

Raising a complaint

Customers who request the Company's complaint handling procedure will be given a copy of the procedure and form by email in PDF format, or by post, and will be asked to raise their complaint in writing as soon as possible after the incident.

Complaints should be raised in writing; however, verbal complaints will be accepted and dealt with under the same procedures.

If a customer telephones the Company and wishes to raise a complaint, they should be passed to a senior member of staff or the Complaints Officer, who will try to resolve the complaint there and then. Even if the complaint is resolved at the time, the customer must still be offered the complaints handling procedure and form before the call ends, and the call recording must be retained and logged in the complaints record.

Data protection related complaints

Where a complaint relates to the processing of personal data, this policy ensures that the Company complies with data protection laws and notification requirements.

Every individual has the right to lodge a complaint with the supervisory authority where they consider that the processing of their personal data infringes the UK General Data Protection Regulation (UK GDPR) or that we have breached data protection law. Everyone using our products or services, and those employed by us, are told about this right in our Privacy Policy, our complaint handling procedures and our information disclosures.

The supervisory authority with which the complaint has been lodged is responsible for informing the complainant of the progress and outcome of the complaint, including the possibility of a judicial remedy where the supervisory authority does not handle the complaint or does not inform the individual of its progress or outcome within three months.

Informal complaint resolution

The Company considers and responds to all complaints and issues, however they are raised and whatever they relate to. Some issues can be resolved immediately or within 3 working days. These are called informal complaints. They are cases where no investigation is needed because the nature of the complaint is clear and it can be resolved without further review of the facts. Where we resolve a complaint within this timeframe, the details are still logged on our complaint register and the complainant is still told about their rights.

The Company takes every opportunity to resolve complaints at the first point of contact where possible. Informal resolution is always attempted where the issues raised are straightforward and need little or no investigation. Most face-to-face and telephone issues can be resolved in this way, but the complainant is always offered the option of making the complaint formal if they are not satisfied with the resolution.

Where an informal complaint is received, the point of contact may try to resolve the issue without involving the Complaints Officer. However, any issue relating to data protection infringements or breaches, however small or informal, is always brought to the attention of the Data Protection Officer or appointed person.

Frontline staff are trained to deal with basic issues and informal complaint resolution, and are aware of their obligations and reporting lines.

Timeframe for informal resolution

The Company aims to resolve informal complaints immediately, or at least within the first 24 hours. If a satisfactory resolution has not been reached within 3 working days of the complaint being raised or identified, however small or informal the complaint, it is passed to the Complaints Officer and enters the formal complaint process.

Responding to a complaint

Where a formal complaint has been received, or an informal complaint could not be resolved at the first point of contact, a written acknowledgement is sent to the customer within 3 working days. This explains the complaint handling procedure and gives approximate timescales and expectations for the investigation and future responses.

Only a trained manager, the Data Protection Officer or the Complaints Officer may respond to customers about their complaints.

Investigating the complaint

The designated employee investigating the complaint will gather all necessary documents, recordings and information to make an independent review of the incident. If internal interviews are held, a note taker will be present, and the interview notes will be written up and signed by the interviewer and interviewee before being added to the complaint history.

All investigations must be completed within 6 weeks of the complaint being received, so that a final response (decision letter) can be sent to the customer within 8 weeks.

Investigations must use all the facts and any previous related information to reach an unbiased outcome and course of action. Each complaint is given a reference, which is written on all related documents and added to the Complaints Register so the complaint can be audited and traced in future.

Complaints must be referred to the Complaints Officer and/or Data Protection Officer where:

• the complainant has asked for this,
• the complaint involves any type of personal data issue,
• informal resolution failed or was inappropriate,
• there is a conflict of interest between the complainant and an employee,
• the issues are complex and need investigation,
• the complaint represents a high or serious risk to the Company,
• the facts are unclear, or the complaint will need extra time to resolve,
• the complainant is identified as being vulnerable,
• there has been any media contact or attention, or
• the issues do or may affect other customers, whether identified or not.

Decision letter (final response)

Once the complaint has been fully investigated and a decision reached, the investigator or Complaints Officer will send the customer a final response letter setting out their findings and any action to be taken or compensation awarded.

The final response must be sent within 8 weeks of the complaint being raised, and will explain the complainant's right to refer the complaint to the appropriate body if they are unhappy with the decision:

• Financial Ombudsman Service: the final response will give the Financial Ombudsman Service's telephone number and address, and will include the Ombudsman's consumer leaflet. It will explain the complainant's options for taking the matter further, and that they have 6 months to refer the complaint to the Financial Ombudsman Service.
• Personal data: for complaints about personal data or breaches of data protection law, the final response will explain the complainant's right to complain to the Information Commissioner's Office, give its telephone number and address, and explain the possibility of seeking a judicial remedy.

6Complaint recording

All complaints, formal or informal, are recorded on a Customer Complaint Register. It records the date, the nature of the complaint, the departments involved, the complaint reference, the lead investigator, whether a decision letter was sent, and the date the complaint was closed. The register is audited regularly to make sure issues are not being repeated and improvements are being made.

The register is made available to any relevant authority, ombudsman or body that oversees the firm's complaints, and to local Trading Standards if a representative works alongside the organisation.

Patterns and analysis

The complaint log is reviewed monthly by the appointed person to identify patterns or recurring issues. Where gaps or patterns are identified, corrective actions are put in place as soon as possible, and the function, process or person is kept under weekly review until a satisfactory improvement is seen.

7Responsibilities

The Company makes sure all staff have the time, resources and support to understand and deal with customer complaints, and provides full training on the complaint handling policy and procedures for new and existing employees.

The Compliance Officer or a dedicated Complaints Officer oversees, investigates and records all customer complaints, and is responsible for regularly auditing the complaints log to make sure improvements are put in place.

The Complaints Officer

The Company has an appointed Complaints Officer who is trained and supported to understand, investigate and respond to complaints of all types. Where a complaint involves personal data, the Complaints Officer is assisted by the Data Protection Officer or appointed person to make sure data protection law is followed and individuals' rights are respected.

The Complaints Officer handles complaints independently and without bias, and each complaint is checked for any conflict of interest. If there is a conflict (for example, the complaint involves the investigating person), a trained deputy handles the complaint.

The Complaints Officer has full authority to ask questions, carry out investigations and interviews, obtain and analyse evidence, recommend policy and process changes, and be involved in any department's work for the purposes of complaint handling.