CUSTOMER COMPLAINT PROCESS – FINANCIAL PRODUCTS
POLICY STATEMENT
H.R. Owen Plc wants to build a lasting and committed relationship with its customers and will act upon any complaints that are made. We will try to resolve any issues as quickly and as easily as possible. A complaint is defined as an expression of dissatisfaction, whether in writing, verbally in person or by telephone.
The resolution plan has 3 steps:
1 STEP ONE – INFORMAL
The Sales Executive involved with the sale of the vehicle to which these products relate will address the initial problem when the customer highlights what the dissatisfaction related to. He or she will try to address those concerns and find a way to resolve it to the satisfaction of the customer. The employee will keep his line manager informed of progress and the employee will notify the Compliance & Risk Director to record the complaint centrally.
2 STEP TWO – LINE MANAGER ESCALATION
When a complaint about financial products has not been resolved to the customer’s satisfaction, they will be invited to email the responsible line manager within that business. The relevant Departmental Manager will investigate and attempt to find a resolution to the customer complaint. The complaint will be acknowledged in writing by email within 24 hours of receipt and a proposed resolution will be made within 3 working days in writing.
If this fails to resolve the matter to the satisfaction of the customer, the third and final step internally within the Company will apply.
3 STEP THREE – DIRECTOR ESCALATION
The customer will be invited to email the Compliance & Risk Director to summarise the problem. The C&R Director will acknowledge this upon receipt and will start an investigation internally. A final response on behalf of the Company will be sent to the customer within 10 working days. This will be the final response on behalf of the Company.
The entire complaint timescale will not exceed 8 weeks.
FINANCIAL OMBUDSMAN SERVICE (FOS)
If the customer remains unhappy with the Company’s response, they are encouraged to refer to the FOS who will review the handling of the Complaint and adjudicate on the issues. They can be contacted at www.financial-ombudsman.org.uk or write to them at Financial Ombudsman Service, Exchange Tower, London, E14 9SR. This service is free to use.
https://www.fca.org.uk/consumers/how-complain
https://www.gov.uk/complain-financial-service
UPDATED 25 JANUARY 2024
The FCA intervention on motor finance complaints where they involve Discretionary Commission Arrangements (DCAs) was announced in January 2023 and this affects the way complaint timescales are managed, if your complaint relates to this arrangement. The time restraints are paused 37 weeks while the Regulator uses its powers to investigate potential harm.
Whilst we will always endeavor to resolve any issues to your satisfaction, this intervention means that the timescales for a final resolution are extended. See the link below, section 2.21
If a complaint about a financial product doesn’t include references to a DCA finance agreement, we will continue within the normal timescales.
See also the FCA handbook, DISP App 5.2 for their exact wording.
CUSTOMER COMPLAINTS POLICY – VEHICLES
H.R. Owen Plc wants to build a lasting and committed relationship with its customers and will act upon any complaints that are made. We will try to resolve any issues as quickly and easily as possible. A complaint is defined as an expression of dissatisfaction, whether in writing, verbally in person or by telephone.
The resolution plan has 3 steps:
STEP ONE – INFORMAL
The Sales Executive or Service Advisor, once made aware of a customer’s dissatisfaction, will try to address those concerns and find a way to resolve it to the satisfaction of the customer. The employee will keep his line manager informed of progress.
STEP TWO – LINE MANAGER ESCALATION
When a complaint has not been resolved to the customer’s satisfaction, they will be invited to email the responsible line manager within that business. The relevant Departmental Manager will investigate and attempt to find a resolution to the customer complaint. The complaint will be acknowledged in writing by email within 24 hours of receipt and a proposed resolution will be made within 3 working days in writing
If this fails to resolve the matter to the satisfaction of the customer, the third and final step will apply.
STEP THREE – DIRECTOR ESCALATION
The customer will be invited to email the Brand Director to summarise the problem. The Brand Director will acknowledge this upon receipt and will start an investigation internally. A final response on behalf of the Company will be sent to the customer within 3 working days.
ALTERNATIVE DISPUTE RESOLUTION
If the Brand Director is unable to resolve the complaint to the customer’s satisfaction, the customer’s co-operation will be sought to engage in Alternative Dispute Resolution to achieve an outcome that is fair and reasonable to all Parties.
The customer will be advised in writing of The Motor Ombudsman Limited (Tel: 0345 241 3008 – www.themotorombudsman.org), an Alternative Dispute Resolution service which the Company has subscribed to. The complaint may then be referred by the customer to The Motor Ombudsman Limited in order to utilise their Alternative Dispute Resolution service accordingly.
PRIVACY POLICY (SEPTEMBER 2022)
This privacy policy is operated by H.R. Owen Plc (a multi-franchised motor retailing group) comprising its wholly owned subsidiary companies, particularly H.R. Owen Dealerships Limited, Jack Barclay Limited, Broughtons of Cheltenham Limited, Bodytechnics Limited and H.R. Owen Servicing and Repairs Ltd.
If you purchase a new or used vehicle from us, we will also share your data with our subsidiary company (H.R. Owen Insurance Services Ltd), who will contact you at the time regarding road risk insurance. If you require body work repair on your vehicle, as the result of an accident, we will also share your data with our subsidiary company (H.R. Owen Bodytechnics) who may contact you regarding completing the required safety bodywork.
We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on:
- the personal information we collect about you;
- what we do with your information; and
- with whom your information might be shared.
Who we are
H.R. Owen and its wholly owned subsidiary companies (‘we’ or ‘us’) are a ‘data controller’ for the purposes of the relevant data protection legislation including the Data Protection Act 2018, the UK General Data Protection Regulations (UK GDPR) and any subsequent legislation as appropriate (i.e. we are responsible for, and control the processing of, your personal information).
What information we collect
Personal information provided by you
We collect the following personal information about you when you register with us, express an interest in or purchase products or services from us in person, over the telephone or online.
Personal information provided by third parties
We may receive information about you from other sources (such as our manufacturer partners and credit reference agencies), which we will add to the information we already hold about you in order to help us provide the products and services you require and to personalise our service to you. We will always seek your permission to contact these people for your information, or our manufacturer partners will have gained your permission to provide this information to us.
The information we collect may include
- Basic personal details such as your name, address, e-mail address, telephone number, date of birth or age, gender, marital status;
- Additional information regarding your vehicle including the registration, VIN number, service history, any works undertaken, insurance policy details, MOT and Tax status of the vehicle; and
- Financial details where required to facilitate payment.
Sensitive personal information may be collected where a vehicle is purchased under the Motability scheme. This may include details of any medical conditions. We will always be clear to explain when and why we need this information and the purposes for which we will use it and will obtain your explicit consent to use sensitive personal information. We also fit vehicle tracker devices to our vehicles in order to know where they are and how they are driven for insurance risk purposes. These will be active if you drive one of them. Should H.R. Owen be asked by a Competent Authority to provide data from any vehicle pursuant to the investigation of an offence or a crime, H.R. Owen will provide the data requested; this may include data about your use of the vehicle.
Personal information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her personal data;
- receive on his/her behalf any data protection notices; and
- give consent to the transfer of his/her personal data abroad.
Sensitive personal information
We may ask you to provide sensitive personal information, for example where you require us to tailor our goods or services to an existing physical condition, e.g. as part of the Motability scheme, or where you are applying for a finance or an insurance product and we are required to enquire whether you have committed a criminal offence. If we request such information, we will explain why we are requesting it and how we intend to use it. Sensitive personal information includes information relating to:
- Your physical or mental health or condition; and
- Whether you have committed a criminal offence.
We will only collect your sensitive personal information with your explicit consent.
Monitoring and recording communications
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of the provision of goods and services, quality assurance, training, fraud prevention and compliance.
Use of cookies
A cookie is a small text file which is placed onto your computer (or other electronic device) to identify you when you use our website. We use cookies and other similar tracking technologies such as web beacons, action tags, Local Shared Objects (‘Flash cookies’), single-pixel gifs on our website. For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
You can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.
For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies please see our Website cookie policy.
For further information on cookies generally visit www.aboutcookies.org or wwww.allaboutcookies.org.
How will we use the information about you?
We collect information about you so that we can:
- identify you and manage any accounts you hold with us;
- process your order;
- maintain a service record for your vehicle, conduct research, statistical analysis and behavioural analysis;
- carry out customer profiling and analyse your purchasing preferences;
- if you agree, let you know about other products or services that may be of interest to you – see ‘Marketing’ section below;
- detect and prevent fraud;
- verify your identity and carry out anti-fraud checks (see ‘Credit checking’ section below);
- provide you with payment options;
- assess your application for a product, service or quote;
- ensure that you can afford any financial agreement offered;
- ensure that any insurance products are suitable for you;
- administer your finance agreements including updating you on and delivering our services; and
- monitor your use of our Websites and any response to advertising campaigns.
We may also offer enhanced services including MOT and service reminders, warranty updates and safety recalls where we believe this would be helpful or of interest.
Where your vehicle manufacturer maintains an electronic service record of your vehicle, we may share details of any work with your manufacturer so that an accurate record can be kept.
Marketing
We would like to send you information by post, email, telephone, text message (SMS) or automated call about our sales, service and news (which may contain information about our products and services, events, competitions and special offers) which we feel may be of relevant interest to you.
We will ask whether you would like us and other businesses within our group to send you marketing messages when you first engage with us either in person, over the telephone or online. You have the right to withdraw or revise your marketing permissions at any time. See ‘What rights do you have?’ below for further information.
Credit and identity checking
We may do a credit check on you using your personal data to facilitate the provision of financial services broking and to prevent and detect financial crime. If you provide false or misleading information, we will record this.
If you want to see your credit file, please contact the credit reference agency which we use i.e. Experian or the agency used by the relevant Finance House.
In order to comply with money laundering regulations and to prevent financial crime, we will check your identity and home address with external databases if you decide to transact with us. This will require you to show photo identity documents alongside your face. The external data suppliers have been checked by us and are also subject to UK GDPR.
Who your information might be shared with
We may disclose your personal data to:
- other companies within our group;
- our manufacturer partners;
- our agents and relevant service providers;
- credit reference agents—see ‘Credit checking’ above;
- law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
- our business partners in accordance with the ‘Marketing’ and opting out section above.
For Brand or corporate events that you elect to join promoted by us, we will draw your attention to this Privacy Policy as a reminder that we may share your data with agents and service providers in relation to those events. They will retain your data in respect of the events only for as long as is necessary and will destroy the data thereafter.
Keeping your data secure
We will use technical and organisational measures to safeguard your personal data, for example:
- Access to your account is controlled by a password and user name that are unique to you.
- We store your personal data on secure servers.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below).
Our website may include links to third party websites, plug-ins and applications, as we use and post events photography on social media platforms. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices and statements. When you leave our website, we recommend that you read the privacy notice of other websites you visit.
What can I do to keep my information safe?
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Transfers of your information out of the UK
We may need to transfer your personal data to countries and territories which are located outside the UK, for the purpose of the provision of our goods and services. We will not transfer your personal data to any territory without an equivalent level of data protection.
What rights do you have?
Right to request a copy of your information
You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or all of it, please:
- email, call or write to us (see ‘How can you contact us?’ below);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know the information you want a copy of, including any account or reference numbers, if you have them.
Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below);
- let us have enough information to identify you (e.g. account number, user name, registration details); and
- let us know the information that is incorrect and what it should be replaced with.
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below). You can also click on the ‘manage your preferences’ button at the bottom of each of our marketing emails;
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
How to contact us
Please contact our Data Manager if you have any questions about this privacy policy or the information we hold about you.
If you wish to contact us, please send an email to data.manager@www.hrowen.co.uk or write to us at H.R. Owen Plc, Melton Court, Old Brompton Road, London SW7 3TD, or call us on +44 (0)20 7245 1122.
Changes to the privacy policy
We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website.
Do you need extra help?
If you would like this policy in large print please contact us (see ‘How can you contact us?’ above).
REGULATORY INFORMATION
H.R. Owen Dealerships Limited, Jack Barclay Limited Broughtons of Cheltenham Limited is an appointed representative of ITC Compliance Limited which is authorised and regulated by the Financial Conduct Authority (their registration number is 313486). Permitted activities include advising on and arranging general insurance contracts and acting as a credit broker not a lender.
We can introduce you to a limited number of finance providers. We do not charge a fee for our Consumer Credit services. We do not act as a financial adviser, or fiduciary. We act in our own interest, whichever lender we introduce you to, we will typically receive commission from them based on either a fixed fee or a fixed percentage of the amount you borrow. Any and all commission
amounts will be fully disclosed to you as part of your sales journey. You will be required to give your fully informed consent to our receipt of this commission. By doing this, you acknowledge that you understand our role as a credit broker, and that we will receive a financial incentive if you take out a loan from a lender that we introduce you to.
All finance applications are subject to status, terms and conditions apply, UK residents only, 18s or over, Guarantees may be required.
TERMS AND CONDITIONS
Unless otherwise stated, you are hereby permitted to copy and use material published by H.R. Owen Plc on this Web service for the internal purposes of your organisation, provided you retain any copyright notice applying to the material. Individual items may have more specific terms and conditions associated with them, in which case those terms and conditions will apply to that item in place of this general permission. If the copyright owner of any material published on this service is not H.R. Owen Plc your rights in respect of that material will be as defined by the copyright owner of the material concerned.
Except as set out above, all rights are reserved and no right or licence is granted or implied under any copyright, patent, trademark or other intellectual property right of H.R. Owen Plc or any other party as a consequence of the publication of any material on this Web service.
H.R. Owen Plc has no responsibility in relation to any material you obtain from any other Web site, even if you access it via a link from this service.
All material published on this Web service is provided “AS IS” WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you. Whilst every effort has been made to ensure the accuracy of the information contained on this website, errors may occur. Do not rely entirely on this information, check with the dealer about items that may affect your decision to purchase.
In no event shall H.R. Owen Plc be liable, in contract, tort (including negligence or breach of statutory duty) or otherwise for any increased costs or expenses, for any loss of profit, business, contracts, revenues, or anticipated savings or for any special indirect or consequential damage of any nature whatsoever arising out of or in connection with your use of this Web service or of any material obtained from it.
COOKIES
This web site uses cookies in a number of ways which are as follows:
Aggregated Site Usage Statistics
Cookies may be placed on your computer, phone or other Internet device to provide us with aggregated data of the usage of this site and the mediums which are driving traffic to the site. The data gathered by these is aggregated and therefore your individual usage of this site cannot be attributed to you.
Essential Site Features
May be placed upon your computer, phone or other Internet device in order to provide essential site features such as allowing you to compare different cars in stock and complete enquiry forms quickly.
Complimentary Site Features
The site may also use Cookies for certain complimentary purposes such as showing you the car that you last looked at on the home page. All these functions are designed to improve your experience of using the site. If you don’t want this site to place Cookies on your device you can disable these using your Internet Browser settings.
Advertising with Cookies
Our website uses cookies/advertising IDs for the purpose of advertising. This enables us to show our advertisements to visitors who are interested in our products on partner websites, apps and emails. Re-targeting technologies use your cookies or advertising IDs and display advertisements based on your past browsing behaviour. You can opt-out of interest-based advertising by visiting the following websites:
http://go.pardot.com/e/126241/choices-/3yy9lv/114140831
http://go.pardot.com/e/126241/2017-04-12/3yy9lx/114140831
We may share data, such as technical identifiers derived from your registration information on our website or our CRM system with our trusted advertising partners. This allows them to link your devices and/or environments and provide you a seamless experience across the different devices and environments that you use.