IDR processes

This section describes our business approach to the management of complaints and the framework within the business that supports this.

Over IDR processes are aligned with our membership of the EDR scheme which is.
COSL

We adopt the definition of ‘complaint’ in AS ISO 10002-2006, namely ‘an expression of dissatisfaction made to an organisation, related to its products or services, or the complaints handling process itself, where a response or resolution is explicitly or implicitly expected’. This means we will treat informal complaints seriously and refer them to IDR unless they are resolved by the end of the next business day.

Receiving complaints

Complaints can be lodged by contacting John McNamara, the Complaints Officer by:

• telephoning: 07) 54300 900
• e-mailing: This e-mail address is being protected from spam bots, you need JavaScript enabled to view it
• writing to: SMS Finance, Complaints Officer, PO BOX 56 Cotton Tree QLD 4558
• or by speaking to any representative of our business who will refer complainants to the Complaints Officer.

Complaints against Credit Representatives and Representatives:

A credit licensee’s IDR procedures must cover disputes relating to its credit representatives.
Note: A credit representative is a person authorised to engage in specified credit activities on behalf of a credit licensee or registered person under s64(2) or 65(2) of the National Credit Act. The employees and directors of a credit licensee do not need to be formally authorised—they can act as representatives of the credit licensee without a specific authorisation. A person can also be authorised as a credit representative by more than one credit licensee.

Complaints must be resolved as expeditiously as possible.

Complainants must be:-

• treated with respect and provided with all documentation and evidence in support of their concerns;
• informed of the complaints handling process, including the avenues for further review of decisions such as an External Dispute Resolution Scheme (EDRS); and
• informed of decisions and the reasons for those decisions.
  

Complaints handling officer

Option 1: The Complaints Officer reports directly to the business owners. The Complaints Officer will make a written report annually as a minimum. The Complaints Officer will ensure that these procedures are reviewed at least annually and a report on the review provided to the business owners.

Investigating complaints

The Complaints Officer will review the complaint carefully and promptly, taking such steps and reviewing such documents as a reasonable person would do.
Responding to complaints within appropriate time limits and referring unresolved complaints to an EDR scheme
The Complaints Officer will provide a written ‘final response’ to the complainant within 45 days which states:

• the final outcome of the dispute at IDR
• the right to take their dispute to EDR (no matter what the result of the investigation was at IDR)
• the name and contact details of your EDR scheme.
• If the Complaints Officer is unable to give a final response within the specified period, the Complaints Officer will, before the end of the period:
• inform the complainant of the reasons for the delay
• advise the complainant of their right to complain to EDR
• provide the complainant with the name and contact details of your EDR scheme.

Annual Review

The IDR process will be reviewed annually by John McNamara. The review will ensure continuing compliance with applicable laws, the requirements of any Licence issued to our business and relevant industry standards. The review will also ensure the guidance remains applicable to our business and continues to achieve its purpose.

Any amendments to the IDR process will be communicated to staff via email and updated in our internal guidance document

Complaints resolution (under business 1 day)

Where a complaint or dispute is resolved to the customer’s satisfaction by the end of the next business day from when the complaint or dispute was received, we understand that we will not be required to apply the full IDR process with respect to capturing and recording the complaint or dispute and providing a final response on resolution of the complaint.

However, if a complaint or dispute is received and not resolved by the next business day, the incident must be recorded as a complaint.

Recording of the initial complaint (template)

If the complaint discloses a systemic issue, the Complaints Officer will immediately bring the matter to the attention of the business owners. Our company policy is to first look at the system before looking at the person.

The types of remedies available for resolving complaints or disputes

If a complaint is justified, the Complaints Officer will recommend a solution comprising one or more of the following:

• an apology
• compensation
• vary contractual obligations
• a free service.

Guiding Principles

Visibility – We will take reasonable steps to ensure customers know about the existence of our IDR procedures and how to make a complaint or apply for hardship or postponement. This information will be readily available, not just at the time a consumer wishes to make a complaint or dispute. All staff who deal with customers, not just complaints or disputes handling staff only, should have an understanding of our IDR procedures.
Objectivity – We will address each complaint in an equitable and objective manner. Where possible, the complaint should be investigated by staff not involved in the subject matter of the complaint.
Charges – The IDR procedures are free of charge.
Confidentiality – We will keep information confidential.
Customer focused approach – We will be helpful, user friendly and communicate in plain English, showing our commitment to resolving complaints.
Commitment – We are actively committed to efficient complaint handling. Our procedures are published on our website.
Analysis and Evaluation of Complaints – All complaints will be classified and then analysed to identify systemic recurring and single incident problems and trends.

Non Compliance Register

If a complaint has resulted in a breach or relates to any issue of non-compliance, we maintain a register in which we record any material breaches of any law. Given the sphere of our operation we expect that there will be no material complaints or breaches. The format of our non compliance register appears below.

Non Compliance Register

Complaints communication example

Our reputation is built on matching the appropriate product(s) to the individual’s requirements. We go to great lengths to ensure satisfaction with our services and offerings. However, there may be instances from time to time, where clients may be dissatisfied with the outcomes of our consultation process. If you have a complaint about the service that we provide, the following steps or avenues for resolution are available to you.

Step 1
Most complaints arise from miscommunication and can usually be fixed quickly. So, please contact John McNamara first and tell them about your concerns.

Step 2
We pride ourselves on the company’s reputation, and want to ensure that all concerns and complaints are fully documented, investigated and resolved in a timely manner. So, if the issue is not satisfactorily resolved within 1 working day by talking with John McNamara, we will apply our internal complaints process to manage your complaint appropriately. In this instance the complaint will be internally escalated to our Complaints Contact Representative. You may also contact our main office and ask to speak with our Complaints Representative directly.

By using our internal complaints process we hope to assist you to resolve your complaint quickly and fairly. The maximum timeframe in which to provide a response to you is 45 days, although in pursuit of best practice and the reputation of our organisation, we aim to resolve these issues in a much shorter time frame.

Step 3
Although we try hard to resolve a customer’s concern in the most considerate and direct manner, sometimes it may need to be referred to a dispute resolution scheme, which is external to our organisation. Therefore, if you are not completely satisfied after the above steps have been attempted, you still have other avenues available to resolve the dispute.

This external dispute resolution process is available to you, at no cost. The details of our External Dispute resolution scheme are below:
Credit Ombudsman Service Limited
Level 6 50 Park St, Sydney, NSW 2000
Phone 1300 78 08 08
Fax 02 9267 3125

Email This e-mail address is being protected from spam bots, you need JavaScript enabled to view it
Web www.creditombudsman.com.au

External Dispute Resolution Requirements

We are a member of COSL.

We will ensure that our IDR processes is complaint with the nominated EDR scheme.

If the licensee ceases, or becomes aware that it will cease, to be a member of an approved external dispute resolution (EDR) scheme, we will, within three business days of the date the licensee’s membership ceased or the licensee became aware that its membership would cease:
(a) notify ASIC in writing of the reasons the licensee’s membership of the EDR scheme ceased or will cease (including circumstances where the EDR scheme is no longer operating, failure by the licensee to renew its membership or where the EDR scheme has terminated the licensee’s membership); and
(b) if the licensee has not obtained membership of another approved EDR scheme, give ASIC a written explanation that includes:
(i) the reasons why the licensee has not obtained membership of another approved EDR scheme;
(ii) details of the EDR scheme the licensee proposes to become a member of;
(iii) details of steps that the licensee has taken, and will take, to become a member of that EDR scheme; and
(iv) the expected timeframe for becoming a member of that EDR scheme.