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Complaints Procedure

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Making a complaint

We work hard to ensure our Members act within the rules set by the industry regulators.

Please click on the following link and read our Code of Practice. If you think a Member has broken the rules of this Code you can make a complaint by downloading our Complaints Form.

Before making a complaint we would encourage you to carry out the following activities:

 

  • Go to the Members Directory and check whether the company you wish to complain about is a Member of the CSA. If you are still unsure, feel free to contact us. If the company is a Member of the CSA then we are able to help you with your complaint.
  • On first instance, we recommend you contact the Member company to discuss any issues you have and enquire about their complaints process. If you are still dissatisfied with the outcome then you can review our Complaints Procedure.
  • If you believe that the Member has acted in breach of our Code of Practice and the complaint meets the necessary criteria, please complete, sign and return the Complaint Form to our registered address.

CSA Complaints Procedure

 How we deal with your complaint.

All complaints must be submitted in writing, with a signed complaint form. We require the form to be signed so that we, and our Member, have the requisite authorisation to share information.

The following is the sequence of events after the CSA receive a complaint form;

  • CSA receive a signed complaint form
  • CSA register the complaint and send a copy to the relevant Member company
  • The Member is given four weeks to respond directly to the complainant
  • CSA get a copy of the response from the Member company
  • CSA considers both positions and determines whether the Code of Practice has been breached
  • Appropriate action is taken (if required) to remedy the situation
  • If further information is required the CSA contact the relevant party (the complainant or the Member company).
  • After a full review, the CSA provides a formal response to the complainant

 

If you remain unhappy with the outcome of the complaint, you may have justification to escalate the matter to our our head of compliance, Claire Aynsley, claire.aynsley@csa-uk.com.

 

Please note: The CSA can only intervene when;

  • a Member company is in breach of the Code.
  • the company is a Member of the CSA (we cannot act when the complaint is about the client of a Member company, a bank or building society for example).
  • the information supplied by a Member company appears from the facts to be incorrect.

Methods of Contact

 

Address

Credit Services Association

Complaints Department

2 Esh Plaza

Sir Bobby Robson Way

Newcastle-upon-Tyne

NE13 9BA

 

Why the CSA need a signed copy of your complaint

 

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FENCA Code of Conduct: General Data Protection Regulation (GDPR) and e-Privacy in the European collections market

31 August 2017

 

Leigh Berkley is External Affairs Director at Arrow Global, a CSA Board Director and Vice President of the Federation of European National Collections Associations (FENCA). He will be delivering a session at the CSA’s UK Credit & Collections Conference in September 2017 on the new FENCA Code of Conduct as part of the conference’s General Data Protection Regulation stream (GDPR). Book your place here: http://ukccc.csa-uk.com/

 

 

 

While the dust has long since settled on the various rounds of negotiations and debate that ultimately gave birth to the EU General Data Protection Regulation (GDPR) which comes into force next year, it is certainly not the end of the story. Indeed, in many ways, it is only just beginning.

Hopefully, your organisation will already be well down the road of preparing to implement GDPR. And for several months now FENCA, the Federation of European National Collection Associations, has been working towards creating a Code of Conduct for GDPR across Europe, to provide a level playing field for all customers and employees, and to help interpret the new regulation for our industry.

 

European Standard Business Practices

Having engaged legal representation, the first stage was to formulate and agree common European Standard Business Practices (ESBPs), which was basically a flowchart looking at the passage and use of personal data, and how such data is used throughout the collections process. Feedback on the ESBPs has now been received from all the FENCA members (including the CSA) and their responses are being assimilated.

In general terms, the ESBPs have met with almost universal approval. Of course, there are particular nuances within individual countries – especially when it comes to the point at which legal action is appropriate and how it works – but these specifics are going to be addressed in a more detailed questionnaire that is now being prepared. The purpose of this questionnaire is to define every step of the process for each country, after which the FENCA lawyer, Dr. Gero Ziegenhorn, will produce a first draft of the Code over the summer/autumn. A FENCA steering Committee and Working Party consisting of experts from credit firms across Europe have been established, and we are looking for representatives from European purchasers and collection agencies for the working party.

 

The CSA leading the way

The Credit Services Association has, of course, played a leading role throughout the GDPR debate, and has formed its own dedicated GDPR Working Party to support its members in the UK. The terms of reference and aims of the Working Party have now been set, with a particular focus on developing tools to support members, and the wider credit industry, in implementing the new regulations. Those wishing to lend their support and expertise on either the FENCA or CSA working parties can get engaged by contacting Claire Aynsley at the CSA on claire.aynsley@csa-uk.com.

It will also be one of the key themes of the UK Credit & Collections Conference on 14 September 2017 with a keynote presentation from the Information Commissioner’s Office’s Jo Pedder and a whole stream of workshops dedicated to GDPR including my session on the FENCA Code and others on data privacy impact assessments, and individual’s rights.

 

e-Privacy regulation

Riding in tandem with GDPR has been proposed regulation called the e-Privacy regulation. Whereas GDPR covers the issues of processing and storing personal data, the new e-Privacy regulations are concerned with how that data is actually transmitted. It is looking at, for example, how data is sent between the creditor and the debt purchaser/debt collection agency, as well as communications from the customer to the purchaser/collector direct.

Scheduled to come into effect in May 2018, at the same time as GDPR, the new regulation has not been without its challenges. Although a first European Commission draft has been out since January, extensive amendments have now been tabled by the European Parliament, led by MEP Marju Lauristin, who is the rapporteur for e-Privacy. FENCA has produced a position paper on the new proposals, strongly arguing that the provisions of the e-Privacy regulation should be harmonised and aligned with GDPR.  The proposed EU Parliament amendments are ill-timed and ill-informed, and both FENCA and the CSA are now lobbying hard to prevent issues that were asked and answered in the original GDPR debate from resurfacing, so close to implementation.

The timescales are short, and implementation of e-Privacy may end up being delayed, but there is a clear urgency in agreeing our negotiating position and lobbying against particular excesses, such as a proposal to deny member states the right to vary the strict rules of the regulation to take into account local conditions, along with major restrictions on the transmission of data which is held perfectly legitimately under GDPR. Such amendments would not be in the best interests of CSA members, but more importantly, would similarly not be in the best interests of the digital consumer or the economy.

There is still plenty of water to flow under this particular bridge before GDPR and its supportive cast can finally be put to bed and I look forward to discussing all the issues further at the UK Credit & Collections Conference.

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