COMPLAINTS PROCEDURE
Effective date: 1 April 2022
Finance Health Group Ltd
Trading as: DentEuropa Implant & Orthodontic & Perio Centre
COMPLAINTS CONTACT DETAILS
Complaints Manager: Dr Emin Şimşek
Telephone: 020 8300 7659
Email: london@denteuropa.co.uk
Address: 300A Bath Road, Hounslow, TW4 7DN
Website: www.denteuropa.co.uk
POLICY STATEMENT
At Finance Health Group Ltd (trading as DentEuropa Implant & Orthodontic & Perio Centre), we believe that if a customer wishes to file a complaint or express dissatisfaction, it should be easy for them to do so.
It is our policy to receive complaints and consider them as an opportunity to learn, adapt, improve, and provide a better service.
In addition, a quick resolution of a complaint, in a way that respects and values the person’s feedback, can be one of the most important factors in recovering the person’s confidence in our products and services. It can also help prevent further escalation of the complaint. A responsive, efficient, and fair complaint management procedure can assist us to achieve this on each complaint.
The purpose of this policy is to ensure that complaints are dealt with consistently and properly and that all comments and complaints are taken seriously. This organisation expects staff at all levels to be committed to fair, effective, and efficient complaint handling.
OUR PRINCIPLES
Finance Health Group Ltd (trading as DentEuropa Implant & Orthodontic & Perio Centre) will ensure that our customers have a right to:
- Be treated fairly and sensitively
- Be kept informed about what is happening with their complaint
- Be advised of the service standards they should expect
- Be informed of the timescale for acknowledging and responding to a complaint
- Be informed of any right of appeal
All staff representing the business will:
- Be sensitive to the particular needs of customers
- Treat complaints as confidential, where possible
- Be accessible and clearly identified
Our policy will:
- Be open, easily accessible, and widely promoted to all our customers and those who represent them
- Be easy to understand and use by all customers and employees
- Set out how to complain and how a complaint should be handled
PURPOSE & SCOPE
This policy is intended to ensure that Finance Health Group Ltd handles complaints fairly, efficiently, and consistently.
This policy applies to all staff receiving or managing complaints from customers made to us, or about us, regarding our services, staff, and complaint handling.
Customers may contact us in the way that best suits their needs. We will ensure that customers calling us can do so on our local rate phone number.
The company’s objective is to ensure that its complaints procedure is implemented effectively and that complainants feel confident that their complaints, worries, or concerns are listened to and acted upon promptly and equitably.
Our complaints management system aims to:
- Record the customer complaint on their individual file and on the complaints register
- Allow us to respond to questions raised by people who file a complaint in a timely manner
- Increase the confidence of the person making a complaint or providing feedback and comments in our administrative procedures
- Provide information that helps us improve the quality of our services, staff training, and complaint handling
- Record any remedial actions taken and any redress that is paid to a customer (or both where appropriate), and the reasons for coming to those decisions
- Provide guidance to all staff and to individuals who wish to file a complaint about our key principles and the concept of our complaints management system
REMEDIAL ACTION
A remedial action is intended to correct something that is wrong or to improve a bad situation. This may include, where appropriate:
- A correction or repeat of a clinical step where clinically indicated
- Adjustments to a restoration/appliance/aligner plan (where clinically appropriate)
- Replacement or repair of a dental product supplied as part of treatment (where applicable)
- Additional appointments necessary to remedy an issue arising from treatment
- Where the complaint relates to a finance product, the way it was presented, the credit agreement, or the lender’s terms, we will review the concern and, where appropriate, liaise with the lender/provider
We endeavour to make remedial actions a “one-off” corrective measure wherever possible. Each case may differ due to the bespoke nature of dental treatment planning and clinical factors. However, we document all remedial action plans on the customer’s file and within our management system. This provides management information to identify recurring issues by treatment type, clinical process, administration, staff, and (where relevant) finance-related complaints.
We aim to provide a consistent approach to all complaints. Staff will follow the examples set out in our internal compensation guidelines to assist in deciding the appropriate level of payment (if any) so that customers are treated fairly and any compensation payments are consistently applied.
This may involve one or more of the following:
- Apology: A financial award is not always appropriate. Often, a simple, heartfelt apology will be sufficient.
- Redress: A payment to restore the customer to the financial position they would be in if things had not gone wrong (where appropriate).
- Distress: The emotional impact caused to the customer by something going wrong.
- Inconvenience: The time it has taken the customer trying to resolve something that has gone wrong.
All staff must be aware of their individual financial authority limits, and whether they have the authority to offer any payment or must refer it to their line manager for authorisation. We will comply promptly with any offer of remedial action or redress accepted by the complainant.
WHAT IS A COMPLAINT?
A complaint is an expression of dissatisfaction about our services, our staff, our actions, or lack of action regarding operations, facilities, advertising and marketing information, and anybody or any company acting on our behalf.
A formal complaint means a complaint that has not been successfully resolved through our complaint management systems outlined in this policy. The complainant has chosen to formalise the complaint by completing our complaint form, or by writing to us.
An informal complaint means a complaint that has been received by us by phone, email, postal mail, or in person, which has not been submitted on our complaint form.
COMPLAINT MANAGEMENT SYSTEM
All complaints will be recorded on both the client file and the complaint management system. This is a system we maintain to enable us to track the complaint and use management information for future developments and improvements to our services and procedures, as well as providing accurate information for external bodies and, where relevant, our lender partners.
We will confirm the complaint details to the customer in writing (this may be by email, text message, or letter depending on the customer’s preference) within 3 working days of receipt.
We will continue to keep the customer informed on the progress of the complaint weekly, in writing, using their preferred method of contact (e.g., email or post).
If the complaint involves a third party (for example, a laboratory, supplier, or manufacturer of a dental product), we will manage the complaint as the customer remains our customer. We will work with the third party to resolve the issue. We will inform the customer of the third party promptly, including the third-party contact details where applicable.
ORAL COMPLAINTS
Staff who receive a verbal complaint should try to resolve it immediately if possible.
Information is to be recorded on the customer’s file, including completion of the complaint form and a letter or email sent to the customer clarifying the complaint and the action to be taken, including estimated timeframes. This can also be communicated verbally but will always be followed up in writing. This is to be done within three working days of the oral complaint being received.
The complaint is to be discussed with the Complaints Manager: Dr Emin Şimşek.
Complaints Coordinator: Umur Kutay coordinates the complaint through the process on behalf of the Complaints Manager. When staff or management receive an oral complaint, they should listen sincerely to the issues raised by the complainant. Any contact with a complainant must be polite, courteous, and sympathetic. At all times, staff and management must remain calm and respectful.
After discussing the issues raised, the staff member or manager handling the complaint should suggest an action plan to resolve the complaint. If acceptable, they should clarify the agreement with the complainant and agree how the outcome will be communicated (for example, by meeting or in writing).
If the proposed action plan is not acceptable, staff or management should ask the complainant to make their complaint in writing and provide a copy of this complaints procedure and a complaint form.
WRITTEN COMPLAINTS
When a complaint is received in writing, it must be forwarded to the named complaints contact Dr Emin Şimşek (Complaints Manager), who must enter the details into the complaints log and send an acknowledgement of receipt within three working days in order to establish confidence with the person who raised the complaint.
If necessary, further clarification should be obtained from the complainant. If the complaint is not made by our customer but is made on their behalf, the customer’s consent (preferably in writing) must be obtained in advance.
After receiving the complaint, a copy of the complaints procedure must be provided to the customer. We will clearly and politely explain the complaints process, the time it may take, and realistic expectations. Where clinically appropriate, we may need to arrange a clinical review appointment. This should be arranged within 14 days where possible and confirmed in writing.
Immediately on receipt of the complaint, we will launch an investigation and within 28 days we will aim to be in a position to provide a written explanation or to arrange a meeting. On some occasions this may not be possible. In such cases, we will write to the customer explaining that we are still investigating, why there is a delay, and the date by which we expect to provide our findings.
MANAGEMENT INFORMATION
Complaints are an important management tool which allows us to learn about the services we provide. They are a useful source of information about how customers experience our services.
To ensure that we can learn from complaints, the following data should be collected for every complaint received:
- The name, address, and contact details of the complainant
- The name and role of the person internally dealing with the complaint
- The dates on which the complaint was received and on which it was responded to
- The nature of the complaint
- The outcome of the complaint
- How the complaint was received
- Remedial action and/or redress carried out in response to the complaint
- Lessons learnt from the complaint
It is important that complaints information is reported and considered on a regular basis and shared at all levels.
The following methods will be used to report complaints information:
- A weekly report to management
- A monthly overview report compiled by the management team
- A 6-monthly report showing data, causes, and actions taken to avoid recurrence
We use core principles to support effective management information and root cause analysis:
- Focus on correcting and remedying root causes rather than just symptoms
- Do not ignore the importance of treating symptoms for short-term relief
- Recognise there can be multiple root causes
- Focus on how and why something happened, not who was responsible
- Be methodical and find concrete cause-effect evidence
- Provide enough information to inform a corrective course of action
- Review guidance produced by relevant regulators, external bodies, and complaint-resolution organisations (where applicable) and communicate it to relevant staff
- Consider how a root cause can be prevented (or replicated as good practice) in the future
Good analysis is actionable analysis.
COMPLAINTS REPORTING
All customer complaints are recorded on our complaints log. Where a complaint relates to a finance arrangement (for example, a regulated consumer credit agreement arranged for a patient), we will record sufficient information to ensure the complaint is handled appropriately and, where required, to share relevant information with the lender/provider and any applicable external complaint-resolution body.
DATA PROTECTION
To process a complaint, we will hold personal data about the complainant. This includes data the complainant provides and information that other people provide in response to our enquiries. We will hold this data securely and only use it to help process the complaint.
The identity of the person making the complaint will only be made known to those who need to consider the complaint and will not be revealed to any other person or be made public by us. However, it may not be possible to preserve confidentiality in some circumstances, for example where relevant legislation applies, or where allegations involve the conduct of third parties (for example, a laboratory or supplier).
Under applicable data protection legislation, customers have rights to access their personal data, subject to certain exemptions. We normally destroy our complaint files six years after the complaint has been closed. We will maintain records for finance customers for a maximum of ten years.
OUR PROCEDURE
Any complaint, verbal or written (including electronically), will be referred to the Complaints Manager (Dr Emin Şimşek) at the earliest opportunity (and in any event within 24 hours) or to the next senior member of the team if Dr Emin Şimşek is unavailable. The Complaints Coordinator (Umur Kutay) may coordinate the process on behalf of the Complaints Manager.
We will also:
- Record details on the customer’s file
- Record details on the complaints management system
- Not delay the complaint by insisting it must be put in writing
- Acknowledge the complaint in writing within three working days, detailing our understanding of the complaint, our proposed approach, and expected timeframes (depending on the complaint this could take up to 28 days or longer)
- Make contact to seek clarification on any points where necessary
- Disclose to the customer any third parties that may be involved in resolving the complaint
- Fully investigate the complaint
- Keep the customer informed of our progress and timeframes
- Discuss with the customer our findings and proposed response, including whether remedial action and/or redress is appropriate
- Provide clear deadlines for responses where required
- Provide the customer with a final response
The customer will receive updates if we cannot respond immediately. We will provide our final response as soon as possible and not later than eight weeks from receipt of the complaint.
Customers may express dissatisfaction about our services, staff, or advertising. We will establish whether the complaint relates to the information given, the service, clinical treatment, administration, facilities, or any finance arrangement. If unclear, this will not delay investigation and we will proceed with our own enquiries.
Dr Emin Şimşek will review the matter, continue to investigate, and provide a written explanation and any supporting information where appropriate (which may include photos, checklists, clinical notes extracts where permitted, and remedial completion notes documenting any remedial work carried out and the customer’s acknowledgement).
INVESTIGATION
Dr Emin Şimşek will establish the nature and scope of the complaint and will:
- Deal with complaints promptly and fairly
- Give complainants clear replies and, where appropriate, fair redress
- If a third party is involved (for example a laboratory, supplier, or manufacturer), we will liaise with them directly. Our customer remains our customer. If we need to share data with a third party to resolve the matter, we will obtain appropriate authorisation from the customer beforehand where required.
- We may take up to 8 weeks to provide a final response but will provide weekly updates so the customer is aware we are working to resolve the complaint.
We will:
- Document and report the complaint
- Determine whether a clinical review appointment is required
- Arrange an appointment where clinically appropriate
- Interview relevant staff/clinicians
- Gather evidence including photographs (where appropriate), records, appointment logs, treatment plans, consent documentation, and relevant correspondence
- Involve third parties if required (informing the customer)
- Review and evaluate the information collated
- Take any necessary action, such as remedial treatment (where clinically indicated), staff training, feedback, or disciplinary action (where appropriate)
- Document our conclusions
- Follow up
ELIGIBLE COMPLAINANTS (FINANCE-RELATED COMPLAINTS)
We will treat all complainants fairly. Where a complaint relates to a finance arrangement (for example, a regulated consumer credit agreement arranged for a patient), additional rights and processes may apply depending on the lender/provider and the nature of the finance agreement. We will explain any relevant escalation options to the customer where applicable.
COMPLAINTS SETTLED WITHIN 3 BUSINESS DAYS
Complaints that can be settled to the customer’s satisfaction within three business days can be recorded and communicated differently.
Where we consider a complaint to be resolved to the customer’s satisfaction under this section, we will promptly send a Summary Resolution Communication (written communication) which:
- Refers to the fact that the customer has made a complaint and informs them that we consider the complaint to have been resolved to the customer’s satisfaction
- Explains that if they subsequently decide they are dissatisfied with the resolution, they may be able to refer the complaint back to us for further consideration and/or refer the complaint to an appropriate external complaint-resolution body (where applicable)
- Provides the website address of the relevant external complaint-resolution body (where applicable)
In addition to sending a Summary Resolution Communication, we may also use other methods to communicate the information where:
- We consider that doing so may better meet the customer’s needs; or
- The customer has already been using another method to communicate about the complaint (this may include recorded calls, emails, or text messages)
All communication will be recorded on the customer’s file.
CLOSING A COMPLAINT
We will consider a complaint closed when we have issued our final response to the customer.
This does not prevent a customer from exercising any rights they may have to refer the matter to an appropriate external complaint-resolution body where applicable.
Our final response may include:
- Accepting the complaint and, where appropriate, offering redress and/or remedial action, including details of any remedial clinical steps proposed and how we will record completion and patient acknowledgement
- Offering redress and/or remedial action without accepting the complaint
- Rejecting the complaint and providing reasons
Where applicable, we will provide customers with details of any relevant external complaint-resolution body, including contact details, and guidance on how to escalate.
If the customer remains dissatisfied, they will be informed of any available escalation route.
FINAL RESPONSE
This will be a written response and will clearly set out our decision and the reasons for it. If any redress is offered, a clear method of calculation will be shown. We aim to do this within 8 weeks of receipt of the complaint.
If we are not in a position to make a final response within this timeframe, we will explain why and indicate when we expect to be able to provide one. Where applicable, we will also inform the complainant of any right to refer the complaint to an external complaint-resolution body and provide relevant details.
We will let you know if we:
- Accept the complaint and, where appropriate, offer redress and/or remedial action; or
- Offer redress and/or remedial action (where appropriate) without accepting the complaint; or
- Reject the complaint and provide reasons for doing so.
Where applicable, we will explain any time limits for referring the matter to an external complaint-resolution body and indicate whether we consent to waive relevant time limits (if such a concept applies).
COMPLAINTS FORWARDING
There are circumstances where a complaint may be solely or jointly the responsibility of another organisation or third party (for example, a lender/provider, a laboratory, or a supplier). Where we have reasonable grounds to believe this may be the case, we may forward the complaint (or the relevant part of it) in writing to that organisation, provided that we:
- Do so promptly;
- Inform the complainant promptly of why the complaint has been forwarded and provide the other organisation’s contact details; and
- Continue to comply with our own obligations in respect of any part of the complaint that remains our responsibility.
Where we receive a forwarded complaint, standard time limits will apply from the date we receive it.
FINANCIAL OMBUDSMAN SERVICE (FOS) — FINANCE-RELATED COMPLAINTS (WHERE APPLICABLE)
Where a complaint relates to an eligible finance arrangement and the complainant has the right to refer the matter to the Financial Ombudsman Service, we will co-operate fully and provide the customer with the relevant details. The customer will be informed that they may be able to refer their complaint to the Financial Ombudsman Service free of charge, but that they must do so within applicable time limits (commonly within six months of the date of the final response letter, where this applies).
The Financial Ombudsman Service might not be able to consider a complaint if it is:
- Outside the allocated time frame of more than six years ago; and/or
- More than three years after the complainant realised (or should have realised) that there was a problem
- If a complaint is outside applicable time limits, this is ultimately a matter for the Ombudsman to decide.
CONTACT DETAILS FOR THE FINANCIAL OMBUDSMAN SERVICE
The Financial Ombudsman Service
Exchange Tower
London
E14 9SR
Tel: 0800 023 4567 (free for most people ringing from a fixed line) or 0300 123 9123 (cheaper for those calling using a mobile) or +44 20 7964 0500 (if calling from abroad).
Email: complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk
You can make a complaint through one of the Financial Ombudsman Service online forms and find out more about the information you’ll need before you start.
RESPONSIBILITY FOR THE POLICY
Dr Emin Şimşek is responsible for the overall policy and its reviews.
This policy is to be signed by all members of staff to confirm their understanding of the policy and that they have completed Complaints Policy training.
A signed copy is to be kept on the staff member’s personnel file, with annual training as a minimum. This policy will be reviewed and updated annually by th
