nealthy - digital asset management

Customer Complaint Procedure

Version: 1.0
Last revised: 01. September 2023

1. Raising a Complaint

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

NOTE: Complaints are to be raised in writing, however verbal complaints will be accepted and dealt with as per the same procedures.

If a customer telephones the Company and wishes to raise a complaint, they should be passed through to a senior member of staff or the Complaints Officer who will try to resolve the complaint then and there.

Even if the complaint is resolved at the time, the customer must still be offered the option of receiving the complaints handling procedure and form prior to ending the call and the call recording must be retained and logged in the complaints record.  

1.1 Data Protection Related Complaints

Where a complaint is related to the processing of personal data, this policy ensures that the Company complies 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 or we have breached data protection law. The supervisory authority with which the complaint has been lodged 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.

2. Informal Complaint Resolution

The Company considers and responds 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.

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 register, and the complainant is still informed of their rights.

The Company takes every opportunity to resolve complaints at the first initial point of contact where feasible and possible. Informal resolution is always attempted where the issues raised are straightforward and potentially easily resolved, requiring little or no investigation.

Where an informal complaint is received, it is acceptable for the point of contact or addressed employee to attempt to resolve the issue without involving the Complaints Officer. However, any issue relating to data protection infringes or breaches, no matter how small or informal, are always brought to the attention of the CO or appointed person.

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.

2.1 Timeframe for Informal Resolution

It is the aim of the Company to 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 is passed to the Complaints Officer to enter the formal complaint process.

3. Formal Complaint Resolution

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.

The CS Department and Senior Management are the only staff members who respond to customers regarding their complaints. The have been provided with the time, resources and training to communicate effectively with customers regarding concerns and formal complaints.

3.1 Response Time for Formal Response

For all formal complaints, a written acknowledgement is sent to the customer within two working days. We provide approximate timelines and expectations for the investigation and future responses within initial acknowledgement response.

All investigations take place with 4-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.

3.2 Investigating the Complaint

The CS Department 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.

All investigations must take place with 4-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 Register so that 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 Compliance Officer where:

  • The complainant has requested such a referral or investigation
  • The complaint involves any type of personal data issue
  • The informal complaint resolution stage failed or was inappropriate
  • There is a conflict of interest between the complainant and an employee
  • The issues are complex and require an investigation
  • The complaint represents a high or serious risk to the company
  • The facts are unclear, or the complaint will require additional time to resolve
  • The complainant is identified as being vulnerable
  • There has been any media contact or attention
  • Child protection issues are involved
  • The issues do or may affect more customers (whether identified or not)

4. Decision Letter

After the complaint has been investigated in full and an outcome decision has been reached, the CS Department 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.

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, along with the possibility of seeking a judicial remedy.

5. Third Party Complaints

We understand that our customers may have interactions with third-party service providers that are associated with our platform. In the interest of comprehensive customer care, we extend our complaint-handling procedures to include issues that may arise from these third-party interactions. Customers are encouraged to address any complaints or concerns related to third-party services directly to us. Upon receiving such complaints, we will take the necessary steps to address these concerns with the respective third-party service provider on behalf of the customer.

It's important to note that all of our goals, procedures, and standards for customer care, including transparency, fairness, and prompt resolution, are equally applicable when handling third-party complaints. Whether the issue is directly with our services or involves a third-party, our commitment to delivering good outcomes for retail customers remains consistent. We aim to resolve all matters efficiently, keeping the customer informed throughout the process, and ensuring compliance with the Fair Treatment guidelines.