Good practice for complaints investigations

The Customer Owned Banking Code Compliance Committee has issued a good practice note, recommending that phone recordings should be used wherever possible to avoid misunderstandings about complaints.

While a recent investigation into a Code breach allegation about privacy found that the Customer Owned Banking Code of Practice had not been breached in relation to a customer survey, the independent committee that monitors the Code identified a number of areas that might be of interest to Code subscribers seeking to achieve good practice.

It suggests:

  • Use call recordings where possible: This helps assess professionalism, achieve regulatory compliance, ensure high-quality customer service, enhance employee training and productivity, and resolve customer complaints.
  • Be mindful of how survey information is used: When using identifiable responses in a survey to inform customer experiences, be clear and transparent about how you will use survey information, and the purpose for which you will follow up a customer. Consider using a different employee to contact a customer to discuss their feedback than the customer’s usual business contact.
  • Internal dispute resolution processes: where possible it is vital that the person responsible for internal dispute resolution (IDR) is impartial and in a separate area from the issue complained about. A customer will always be more reluctant to speak to the staff who are the subject of the complaint than to a person who can assess the situation objectively (maybe a superior, and not associated with the conduct that is the subject of the complaint). A good IDR process includes the use of a facilitator who is impartial in providing a fair solution and handles complaints in a sensitive and transparent manner.

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David Jacobson

Author: David Jacobson
Principal, Bright Corporate Law
About David Jacobson
The information contained in this article is not legal advice. It is not to be relied upon as a full statement of the law. You should seek professional advice for your specific needs and circumstances before acting or relying on any of the content.

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