The Glasgow Watch Company Ltd (“Glasgow Watch Co”) complaint handling policy has been created to meet general standards and requirements. We take all concerns and issues seriously and use our robust and structured complaint processes to ensure a satisfactory resolution is reached.
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 nature and details to help improve our services and reduce the occurrence of similar complaints.
We follow specific codes of conduct. We have an obligation to provide our customers with complaint handling procedures. This policy and our associated customer complaint procedures are aligned with the rules and requirements set out by the FCA.
We are committed to delivering a fair, open and clear process for complaints and ensure a satisfactory outcome for all customers who raise a complaint. We provide thorough staff training in our complaint handling procedures and support our staff in how to handle complaint situations in a face-to-face, written and telephone environment.
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 regarding the complaint, and to implement measures to prevent recurrences where applicable.
This policy applies to all staff within Glasgow Watch Co. Adherence to this policy is mandatory and non-compliance could lead to disciplinary action.
Our objectives are set out below regarding customer complaint handling. For the purposes of this policy, a complaint is defined as any customer contact whereby a negative communication or outcome has occurred. The customer does not have to formally address their communication as an official complaint or to request a response for the company to treat the incident as a complaint and to follow the related procedures.
Our objectives for complaint handling are:
Our objectives for our customer complaint procedures are:
Customers can raise a complaint by any reasonable means, including in person, letter, email, social media, text, and verbally. Customers who request our complaint handling procedure will be provided a copy of the procedure and form either by email, in a PDF format or in the post. All complaints even where received, for example, as a text message, will be referred to the appropriate person for review and response.
If a customer contacts us and wishes to raise a complaint, they will be passed through to Innes who will try to resolve the complaint then and there.
Even if the complaint is resolved at the time, the customer will be offered the option of receiving the complaints handling procedure and form prior to ending the call and the call recording will be retained and logged in the complaints record.
Where a complaint is related to the processing of personal data, this policy ensures that we comply with the 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 personal data relating to them infringes GDPR/DPA18 or we have breached data protection law. All individuals using our products or services and those employed by us are notified of this right via our Privacy Notice, in our complaint handling procedures, and in our information disclosures.
Innes is responsible for informing the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy where the supervisory authority does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged.
We consider and respond to all complaints and issues, no matter how they are raised or what they refer to. Some issues and complaints we can resolve immediately or within a 3-working day timeframe and are referred to as informal complaints.
Where Glasgow Watch Co Ltd deals with a complaint by the close of the third business day, it does not have to adhere to the following guidance detailed within the policy below. It does however need to undertake the following in the form of a ‘Summary Resolution Communication’:
A log of such complaints is to be made to record the number of such complaints versus that of a formal complaint.
In cases where complaints are not resolved within three business days, a written acknowledgement is sent to the customer within five business days.
Such instances are where an investigation is not required because the nature of the complaint is clear, and a resolution can be obtained without further review of the facts. Where we resolve a complaint within the timeframe, the details are still logged on our complaint log, and the complainant is still informed of their rights.
We take every opportunity to resolve complaints at the first initial point of contact where possible. Informal resolution is always attempted where the issues raised are straightforward and potentially easily resolved, requiring little or no investigation.
However, the complainant is always offered the option of making the complaint formal if the resolution is not to their satisfaction.
Frontline staff are trained to deal with basic issues and informal complaint resolution and are aware of their obligations and the subsequent reporting lines. Such employees are equipped to attempt to resolve a complaint relevant to their area of service or expertise, wherever possible.
It is our aim resolve informal complaints immediately, or at least within the first 24-hours. Such complaints and issues will have a quick, but informative response and do not need to have an investigation or enter the formal complaint process.
No matter how small or informal the complaint, if a satisfactory resolution has not been achieved within 3 working days of the complaint being raised or identified, the issue will enter the formal complaint process.
We have specific procedures in place for the receipt of a formal complaint, regardless of the medium in which it was received. This includes the progression of an informal complaint that we were unable to resolve during the initial point of contact.
For acknowledgements made by post, the procedures are enclosed in a hard-copy letter format. Where the customer has requested to correspond via email, we provide the complaint procedures.
Innes is the only staff member who responds to customers regarding their complaints. They have been provided with the time, resources, and training to communicate effectively with customers regarding concerns and formal complaints.
For all formal complaints, a written acknowledgement is sent to the customer within 3 working days. We provide approximate timelines and expectations for the investigation and future responses within the initial acknowledgement response.
All investigations take place within 6-weeks of the initial complaint being received. We aim to send our final response (decision letter) to the customer within our designated 8-week period. Where this is not possible, the customer will be updated using our 8-Week Holding Letter response to provide them with an update and reason(s) for the delay.
Innes will be assigned the role of investigating complaints and will gather all necessary documents, recordings, and information to make an independent review of the incident.
If internal interviews are to be conducted, a note taker will be present alongside the investigator and interviewee and a copy of the interview notes will be written up and signed by the interviewer and interviewee prior to them being added to the complaint history.
All investigations must take place within 6-weeks of the initial complaint being received so that a final response (decision letter) can be sent to the customer within our designated 8-week period.
Investigations must utilise all the facts and any previous, related information to produce an unbiased outcome and an expected course of action. A complaint reference should be assigned and all documents relevant to the complaint should have the reference written on them for continuity.
The reference will also be added to the Complaints log so that the complaint and document can be audited and traced back in the future.
All employees are provided with clear guidelines of when a complaint is formal and requires an appropriate investigation. Complaints must be referred to the Complaints Officer where:
After the complaint has been investigated in full and an outcome decision has been reached, Innes will draft a final response letter to the complainant with their findings and decision regarding any action(s) to be taken or compensation awarded.
The final response will be sent within 8 weeks of the initial complaint being raised and will also specify the complainants right to refer to or lodge the complaint with the appropriate body (where applicable) should the customer be unhappy with the final decision.
The final response will detail the Financial Ombudsman Service’s (“FOS”) telephone number and address and the financial ombudsman’s Services consumer leaflet will also accompany the final letter. The complainant will be provided with the options for taking the matter further and that they have only 6 months to log the complaint with the FoS.
For complaints related to personal data and/or breaches of the data protection laws and regulations, the final response will reiterate the complainants right to lodge a complaint with the supervisory authority (the Information Commissioners Office) and will detail the ICO’s telephone number and address, along with the possibility of seeking a judicial remedy.
If we have reasonable grounds to be satisfied that another party may be solely or jointly responsible for the matter detailed in the complaint, we will forward the complaint or the relevant part, in writing, to the other party. We will do so.
When a respondent receives a complaint that has been forwarded to it under DISP 1.7.1 R, this complaint is treated for the purposes of DISP as if made directly to that complaint and as if received by it when the forwarded complaint was received.
Complaints will be forwarded by email. On receiving a forwarded complaint, the standard time limits will apply from the date on which the respondent receives the forwarded complaint.
The FOS cannot consider a complaint if the complainant refers it to the FOS more than six months after the date on which Glasgow Watch Co Ltd sent the complainant its final response, redress determination or summary resolution communication; or more than:
Unless:
Glasgow Watch Co will accept complaints from a customer for a period of 6 years following the event complained about, after which the right to complain will lapse. If a customer submits a complaint regarding the alleged acts or omissions of Glasgow Watch Co that occurred more than six years ago, Glasgow Watch Co will seek to sensitively ascertain from the customer whether there are exceptional circumstances, such as incapacitation or another form of vulnerability, that prevented the customer from filing the complaint within the six-year timeframe. Should Glasgow Watch Co identify that there are exceptional circumstances related to the timing of the complaint, it will accept and process the complaint in accordance with the policies and procedures outlined herein.
Furthermore, if Glasgow Watch Co chooses to reject the complaint, Glasgow Watch Co is obligated to clearly explain the reason for rejection to the complainant in a final response, adhering to the requirements set out in DISP 1.6.2 R or DISP 1.6.2AR. This explanation will include information on the time limit restrictions as per the FOS and provide guidance on the complainant's rights and next steps.
All complaints, whether formal or informal, are recorded on a Customer Complaint Register. The register consists of the below information and is audited on a monthly basis to ensure that incidents are not being repeated and improvements are being made.
The register is made available to any relevant authority, ombudsman or body who relates to or oversees the firms’ complaints, as well as being made available with the local Trading Standards should a representative work alongside the organisation.
The complaint registers and forms are reviewed monthly by Innes to identify any patterns or reoccurring issues. We are dedicated to improving our performance, services and functions through the auditing of our complaint records and our investigation process.
We must identify and remedy any recurring or systemic problems and therefore minimise the risk of compliance failures, for example, by:
Where we identify recurring problems, we will consider whether other customers may have suffered detriment from, or been potentially disadvantaged by, such problems but who have not complained. If so, we will take appropriate and proportionate measures to ensure that those customers are given appropriate redress or a proper opportunity to obtain it.
We will collate management information on the causes of complaints and the products and services complaints relate to, including information about complaints that are resolved by the firm by close of the third business day following receipt.
We will carry out regular internal monitoring of complaints, feedback from customers and/or lenders, and MI to ascertain if customers have suffered foreseeable harm as a result of our acts or omissions.
Should we find that we identify foreseeable harm we will immediately initiate a thorough investigation to understand the underlying causes and circumstances leading to such outcomes. This will involve a comprehensive review of the specific complaint or feedback, analysing the patterns in our MI, and identifying any systemic issues within our operations.
Upon identification of the root causes, we will take swift and appropriate corrective actions, which may include process enhancements, staff training, or even revisiting our partnerships with the lender.
Additionally, we will engage in open communication with affected customers, reassuring them of our commitment to their satisfaction. Regular reviews and updates to our monitoring processes will be undertaken to ensure that such incidents are minimised in the future.
The FCA requires us to put in place procedures to ensure lessons learnt as a result of determinations by the FOS are effectively applied when investigating complaints. To ensure we take appropriate account of decisions and guidance produced by the FOS, the FCA we operate the following management processes:
We have a user-friendly version of our complaint procedures that are made available to customers. This provides them with easy to access and understand guidance on how to raise a complaint and the process and timeframes for resolution. The customer complaint procedures are published on our website at www.Glasgow Watch Co.co.uk
We also provide a hard-copy complaint procedure letter and a PDF digital version for responses by post and email.
We will ensure that all staff are provided with the time, resources, and support to learn, understand and deal with customer complaints and that full training will be provided for new and existing employees on the complaint handling policy, procedures and expectations.
Innes will be appointed the role of overseeing, investigating and recording all customer complaints and is responsible for regular monitoring of the complaint register to ensure mitigating actions and improvements are put into place where required.
As a smaller consumer credit firm, Innes will report our complaints data annually through the Regdata system.
We are required to keep a record of each complaint received and the measures taken for its resolution and retain that record at least 3 years from the date that the complaint was received.
Every 12 months we are required to submit a report to the FCA regarding all complaints received from eligible complainants, including those complaints resolved informally by the close of the third business day. Our reporting periods are aligned to our financial year-end must be submitted to the FCA within 30 business days of these dates.
To ensure complaint handling is given appropriate priority, Innes has responsibility for oversight of the firm’s compliance with the FCA’s complaint rules. While we are not required to notify the FCA or the FOS of the name of the individual, we must ensure that an appropriate individual is appointed and in place at all times so that, if requested, we can comply promptly with any request. In addition, we are required to provide the FCA with details of a single contact point for complaints. This is done at the time of authorisation and is made public on the FCA Register. Should these details change, we must update the FCA’s records.
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