Responsible Customer Care Policy

Section 1 – Complaints handling procedures

1. The Complaints Handling Procedures of Gallego should ensure any Complaint from a Relevant Customer is resolved to the Complainant’s satisfaction in a timely manner or where Gallego is unable to do so, that the Complainant is informed of their right to go to the ADR Scheme as soon as it is appropriate to do so.

Receiving, handling and resolving complaints by relevant customers with disabilities or who are in circumstances that may make them vulnerable

2. The Complaints Handling Procedures must be sufficiently accessible to enable the following to make, and progress, a Complaint:
   
   
   1. Relevant Customers with disabilities;
   2. Relevant Customers who Gallego has been informed or should otherwise reasonably be aware may be vulnerable due to circumstances such as age, physical or learning disability, physical or mental illness, low literacy, communications difficulties or changes in circumstances such as bereavement; and
   3. Third parties acting on behalf of such Relevant Customers.

Identifying and receiving complaints

3. Gallego must ensure that all staff or third party partners who communicate with Relevant Customers receive training on how to identify a Complaint.
4. Gallego will allow Relevant Customers to make Complaints by at least the following two methods:
   
   
   1. a Telephone Number which is either a ‘free to call’ number or a number charged at the equivalent of a geographic call rate;
   2. either an email address or an internet web page form dedicated to allowing Relevant Customers to lodge Complaints.
5. The means by which Gallego accepts Complaints:
   
   
   1. must be well publicised and readily available; and
   2. should not unduly deter Relevant Customers from making a Complaint.

Information to the complainant about process and timeframe

6. After having received a Complaint, Gallego will promptly inform the Complainant of:
   
   
   1. the process it will follow to investigate the Complaint with a view to resolving it to the Complainant’s satisfaction; and
   2. the timeframes in which Gallego will endeavour to carry out its investigation of the Complaint.

Taking steps to resolve complaints

7. Gallego must promptly take, and continue to promptly take, active steps to resolve the Complaint to the Complainant’s satisfaction until the Complaint has been resolved or otherwise closed.

Telling the complainant of the outcome of the investigation into the complaint

8. Gallego must promptly tell the Complainant of the outcome of its investigation into the Complaint.
9. When telling the Complainant of the outcome of its investigation into the Complaint in accordance with paragraph 8, Gallego must also tell the Complainant:
   
   
   1. that Gallego may consider it reasonable to conclude that the Complaint has been resolved to the Complainant’s satisfaction if Gallego promptly tells the Complainant of the outcome of its investigation into the Complaint and the Complainant does not let Gallego know within 28 days that they consider the Complaint remains unresolved; and
   2. where a copy of the Customer Complaints Code can be found on Gallego’s website and the contact details for the ADR Scheme of which Gallego recommends.
10. Where requested by the Complainant, Gallego must ensure that the information referred to in paragraphs 8 and 9 is issued in a Durable Medium.

Unresolved complaints and access to ADR

Issuing ADR letters

11. Gallego must immediately issue an ADR Letter to the Complainant at any time, where the following three cumulative criteria are met:
    
    
    1. Gallego has told the Complainant of the outcome of its investigation into the Complaint;
    2. the Complainant has told Gallego that they consider the proposed outcome does not resolve the Complaint to their satisfaction; and
    3. Gallego does not intend to take additional steps to resolve the Complaint to the Complainant’s satisfaction that would produce a different outcome.
12. Gallego must immediately issue an ADR Letter to the Complainant if the Complaint remains unresolved after 8 weeks have passed since the date on which the Complaint was first received, unless Gallego has already sent an ADR Letter in accordance with paragraph 11 above.
13. Any time Gallego is required to issue an ADR Letter under this Condition, the ADR Letter must comply with the following requirements:
    
    
    1. it must be written in plain English;
    2. it must provide information solely about the relevant Complaint;
    3. it must inform the Complainant that because the Complaint cannot be resolved to their satisfaction, they may exercise their right to take their Complaint to the ADR Scheme at no cost to the Complainant;
    4. it must provide the name and contact details of the body which administers the ADR Scheme of which Gallego recommends and state that the ADR Scheme is independent of Gallego; and
    5. it must be issued in a Durable Medium.

Closing complaints

14. Gallego must not close a Complaint unless:
    
    
    1. the Complaint has been resolved in accordance with the circumstances set out in paragraph 15 below;
    2. an ADR Letter has been issued to the Complainant in accordance with paragraphs 11 or 12 above; or
    3. it is reasonable for Gallego to consider the Complaint to be frivolous or vexatious.
15. A Complaint has been resolved where:
    
    
    1. the Complainant has expressly agreed that the Complaint has been resolved to the Complainant’s satisfaction;
    2. it is reasonable for Gallego to conclude that the Complaint has been resolved to the Complainant’s satisfaction because:
    1. Gallego has informed the Complainant of the outcome of its investigation in accordance with paragraph 8 and complied with its obligations under paragraph 9; and
    2. the Complainant has not come back to Gallego within 28 days to say that they consider the Complaint remains unresolved (see paragraph 9(a)).

Section 2 – Customer complaints code

16. The Customer Complaints Code that Gallego must:
    
    
    1. be concise and easy to understand;
    2. only contain relevant information about how Complaints from Relevant Customers are handled and how, and when, Complainants can take their unresolved Complaints to the ADR Scheme.
17. The Customer Complaints Code must be kept up to date and include information about:
    
    
    1. the contact details for making a Complaint to Gallego, including providing details about the means of lodging a Complaint required in paragraph 4 above;
    2. the steps Gallego will take to investigate with a view to resolving a Complaint;
    3. the timeframes in which Gallego will endeavour to resolve the Complaint;
    4. the right for a Complainant to take their unresolved Complaint to the ADR Scheme after eight weeks have passed since the date on which the Complaint was received, and the circumstance (under paragraph 11 above) where the Complainant can do so at any time;
    5. the name and contact details for the body which administers the ADR Scheme.
18. The Customer Complaints Code must be well publicised and readily available, including ensuring that it is:
    
    
    1. easily accessible on a webpage, with either:
       
       
       1. a weblink to the Customer Complaints Code being clearly visible on a Regulated Provider’s primary webpage for existing Relevant Customers (i.e. ‘1 click’ access); or
       2. a weblink to the Customer Complaints Code being clearly visible on a ‘how to complain’ or ‘contact us’ page, which is directly accessible from a primary webpage for existing Relevant Customers (i.e. ‘2 click’ access);
    2. referred to in the terms and conditions for all relevant products and services, which should signpost Consumers to how they can access a copy of the Customer Complaints Code;
    3. provided free of charge to Complainants upon reasonable request in hard copy or other format as agreed with the Complainant; and
    4. made available on request, free of charge and in a format reasonably acceptable to any Relevant Customer who is blind or whose vision is impaired. An acceptable format would, for these purposes, consist of print large enough for those Relevant Customers to read, Braille or electronic format appropriate to the reasonable needs of the Relevant Customer.

Staff awareness of Gallego’s customer complaints code

19. Gallego must ensure that all staff who deal with Complaints (for example, front- line staff who are the first point of contact for Complainants and/or responsible for dealing with Complaints, and those staff to whom Complaints are escalated):
    
    
    1. are fully informed of, and understand, the Customer Complaints Code; and
    2. know where, and how, to access the Customer Complaints Code on our website.

Section 3 – Record keeping

Record keeping for each complaint

20. For each Complaint received, Gallego must keep a record in writing of:
    
    
    1. the date on which the Complaint was received;
    2. how the Complaint was made (for example, by email or by phone);
    3. the identity and contact details of the Complainant;
    4. a description of what the Complaint is about;
    5. all communications made or received between Gallego and the Complainant regarding the Complaint, including, as a minimum:
       
       
       1. the date on which the communication was made or received;
       2. how the communication was made or received (for example, by email or by phone);
       3. a description of what was contained in the communication (for example, advice given and/or action proposed to be taken and/or action agreed with the Complainant to be taken, to resolve the Complaint);
       4. copies of any written communication; and
    6. the date on which the Complaint was resolved or otherwise closed.
21. Where the Complaint is resolved because:
    
    
    1. the Complainant expressly agrees that the Complaint has been resolved to the Complainant’s satisfaction, Gallego must keep a record in writing of that express agreement;
    2. the conditions set out in paragraph 9(a) and (b) have been satisfied as a result of which Gallego can conclude that the Complaint has been resolved to the Complainant’s satisfaction, Gallego must keep a record showing that those Conditions were met.
22. Where Gallego closes a Complaint on the basis of:
    
    
    1. paragraph 14(b), a record must be retained of the ADR Letter and why it was issued;
    2. paragraph 14(c), a record must be retained of why Gallego considered it reasonable to consider the Complaint to be frivolous or vexatious.

Monthly records

23. For each month, Gallego must retain a record of the following:
    
    
    1. the number of Complaints received in that month;
    2. the number of ADR Letters sent in that month for unresolved Complaints in accordance with paragraph 12 (i.e. after eight weeks have passed);
    3. the number of ADR Letters sent in that month for unresolved Complaints in accordance with paragraph 11 (i.e. at any time);
    4. the number of Complaints resolved because the Complainant expressly agreed that the Complaint has been resolved to the Complainant’s satisfaction;
    5. the number of Complaints resolved because the conditions set out in paragraph 9(a) and (b) have been satisfied as a result of which Gallego can conclude that the Complaint has been resolved to the Complainant’s satisfaction;
    6. the number of Complaints closed on the basis of paragraph 14(c).

Retaining records

24. Gallego must retain the written records referred to in paragraphs 20 to 23 for a period of at least twelve months after the Complaint was resolved or otherwise closed.
25. Gallego must retain the written records referred to in paragraphs 20 to 23 in an appropriate format such that the records are:
    
    
    1. clear in how they meet the requirements in those paragraphs; and
    2. readily accessible in order to assist in effective compliance monitoring.

Section 4 – Information in bills on ADR

26. Every Bill provided to Relevant Customers who are Consumers, excluding Bills provided by SMS, must also include, in a reasonably prominent manner, relevant text regarding the right of Relevant Customers to take unresolved Complaints to the ADR Scheme. That text must:
    
    
    1. provide the name and contact details of the body which administers the ADR Scheme of which Gallego recommendsband state that the ADR Scheme is independent of Gallego;
    2. state that the ADR Scheme offers dispute resolution for Complaints at no cost to the Complainant;
    3. inform Relevant Customers that the ADR Scheme can normally only be accessed after eight weeks have passed since the Complaint was first made to Gallego; and
    4. refer to the Customer Complaints Code, and where it can be found on Gallego’s website, for further information and, where possible, provide a web address for the Customer Complaints Code.