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Credit Services Association

2 Esh Plaza

Sir Bobby Robson Way

Great Park

Newcastle Upon Tyne

NE13 9BA

Additional Sections

Complaints Procedure

Useful Links

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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16-03-2016

Blog: How can the debt collection sector better support customers with mental health issues?

Peter Wallwork is CEO of the Credit Services Association (CSA), the UK trade body for the debt collection sector.

 

Last week saw the launch of MoneySavingExpert Martin Lewis’ new Money and Mental Health Policy Institute, which has been set up to research and find solutions to the worrying link between mental health and money problems. 

As a sector that works directly with people in financial difficulty every day, dealing with those with mental health issues (who are five times more likely to get into debt and take 18 months longer to recover from mental health issues if they also have money worries), is top of our agenda. Big strides forward have been made in recent years but it can’t be underestimated how complex this issue is and how much more needs to be done to ensure we all work together to support people in financial difficulty who are also suffering with mental health problems. We’re already in talks with the institute’s director Polly Mackenzie about how we can share insights from our member companies’ experiences of dealing with these customers.

 

How do we define vulnerability?

In recent months, we’ve seen various initiatives and reports on vulnerable customers published from the likes of the British Banking Association’s Vulnerability Taskforce and the Finance & Leasing Association/UK Cards Association. This best practice guide is designed to ensure that vulnerable customers are not only treated fairly, but with empathy and sensitivity – but what are these reports really achieving? By singling out ‘officially identified’ vulnerable customers (which is a multi-faceted and complex thing to do) are we not missing the point about all customers deserving the best possible treatment regardless of their circumstances? Vulnerability is difficult to define and by automatically labelling older people or those with a disability as vulnerable may not always be appropriate. Likewise, those who may not be classed as vulnerable (including those with an undiagnosed or short term mental health problem) may actually be in circumstances which prevent them from being able to physically make payments such as poor broadband connection which is completely unconnected with their vulnerability.

 

We’re working on a discussion paper that will address this issue from a customer service excellence point of view. Rather than vulnerability generally, we will be looking at people in ‘special circumstances’, one of which is a professionally diagnosed mental health issue, so that we can better understand a person’s capacity to make repayments and ensure that all customers are given a fair chance to find the best possible solution for their financial difficulty. The sooner people are freed of financial difficulty, the less likely they are to suffer from ongoing mental health issues. If we assume that all those suffering with mental health issues are unable to pay, we aren’t necessarily helping them.

 

The reality of dealing with vulnerable customers

The reality of dealing with vulnerable customers from a debt collection point of view is incredibly complex as we saw at our Annual Members’ Meeting in February when we invited a drama group to improvise an interaction between a collector and a vulnerable customer over the phone. When those who do not deal with these calls directly themselves saw first-hand how the ‘robotic’, process-driven nature of compliance-led call handling made things even more difficult for the customer (who admitted to considering suicide), it really brought home how unique every customer and every case is. There can be no one-size fits all approach, particularly when it comes to dealing with customers who may have mental health issues as they may not be in a position to be able to properly disclose their vulnerability. This is why our learning and development programmes are work-based and practical so that these scenarios can be played out.

 

We know that a big barrier to better customer engagement in the debt collection sector is the widely-held fear and cynicism consumers feel towards our industry. Better education, information and understanding which reassures people that being contacted by a debt collection agency isn’t a negative experience but rather an opportunity to find a resolution for the customer before problems spiral out of control, is important and is something that the media and wider society also have a role in.

 

Opening lines of communication across the financial services sector

The British Banking Association’s Vulnerability Taskforce report recommended that customers only have to disclose their personal circumstances once for each organisation so that they don’t have to keep explaining their plight to different teams across a bank. However, when customer information is passed on to a debt collection agency, this insight into their mental health and overall vulnerability also needs to be passed on so that any customer contact is made with a full understanding of the issues that the customer is facing and can therefore be managed appropriately.  We believe that by working together more effectively as a whole sector – lenders, debt collectors and debt advisers – we can reduce the negative impact on the mental health of customers. However, new EU data protection legislation and other regulation may make this more difficult and we need to find ways to overcome this whilst allowing customers to retain control over their data.

 

Referring vulnerable customers to specialists

Whilst we signpost customers to various sources of free, impartial debt help and encourage our member companies to do the same, the referral process needs to be much smoother to avoid any unnecessary stress and hassle for the customer. Citizens Advice have highlighted gaps in financial advice, especially for those who are considered vulnerable, in numerous different reports. NatWest is now piloting a scheme to refer vulnerable customers directly to Citizens Advice and we are keen to look at ways that our member companies can create a direct link with debt help.

 

We look forward to working with the Money and Mental Health Policy Institute to ensure that future legislation does more to enable us to protect those in financial difficulty, offering excellent customer service across the board.