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Handling of Privacy Complaints

General

This document describes the complaint management process that Changing Habits uses to handle Privacy related complaints. It describes an effective and responsive process that reflects the needs of both the complainant and Changing Habits. It provides Changing Habits with both a customer focused, consistent and systematic approach to resolving complaints received relating to the Privacy.

Visibility

Information on how to make a complaint forms part of the Privacy Statement and is available on Changing Habits’ website and on request from Customer Relations.

Accessibility

The complaints handling process is easily accessible. Contact for making a complaint, or requesting access to information, is made by phoning a dedicated phone number or emailing enquiries@changinghabits.com.au. This phone number is 07 5493 7135

Responsiveness

Each complaint is received by email, mail or phone and acknowledged as received at that time. Each complaint is assigned a case number using the Customer Relations system and the case number is provided to the complainant. Expectations of complaint resolution timelines are to be provided to the complainant at the time the complaint is acknowledged and recorded.

Objectivity

Each complaint will be handled in an objective and unbiased manner.

Confidentiality

Each complaint will be treated confidentially and information collected concerning the complaint will remain confidential as per Changing Habits internal policy and procedures. Non-disclosure agreements are in place with all team members handling complaints and individuals are covered by acceptance of the Changing Habits Code of Conduct as part of employment with Changing Habits. Where third party service providers are involved with the investigation or resolution of the complaint, their involvement is covered by the confidentiality and privacy obligations contained in the services provision contract.

Accountability

Accountability for receiving complaints relating to the Privacy is assigned to the Changing Habits Customer Service Team. Accountability for resolution of complaints relating to the Privacy is assigned to the Privacy Compliance Officer and may be delegated to the Customer Service Manager. Accountability for communicating significant breaches to the Finance Director and Managing Director is assigned to the Privacy Compliance Officer. A significant breach includes, but is not limited to:

  • a material compliance breach, or
  • a breach that may lead to material brand reputational damage, or
  • a breach has a high probability to lead to an individual or the company incurring a fine.

Complaints handling framework

Collection of information

An individual with a complaint will raise a complaint using established procedures by using the contact details publicised in the Privacy Statement. All complaints pertaining to the Privacy will be entered into the Customer Relations system by a member of the Customer Service team. The Customer Service team will investigate the complaint to establish the facts and recommend a resolution to the Customer Service Manager. If the complaint requires follow up in order to close the case it will be referred from Customer Service to the Privacy Compliance Officer. The mailbox will be permanently opened in Outlook, and will also be accessible on request by other nominated Changing Habits team members (to cater for leave, illness, etc). The mailbox is included in the Changing Habits disaster recovery planning and is backed up regularly to safe guard data. All traffic received/sent from the mailbox is logged. All incoming emails will be assessed for the nature and severity of the complaint.

Investigation of Privacy related complaint

A Customer Service team member as selected by the Customer Service Manager will conduct analysis on each complaint to determine the resolution required. Each complaint will be handled based on the nature of the complaint and the information concerned. Changing Habits Customer Service will continue to manage each case when referred to other Changing Habits internal functions and will be responsible for follow up and eventual closure of the case in the Customer Service system.

Monitoring performance

All complaint details will be recorded in the Customer Service system. Details including the date the complaint was received/closed, current status of the complaint (open/closed), details of the complaint made, details of the resolution provided and communications material pertaining to the complaint. Once a complaint has been resolved, all received and sent emails pertaining to the complaint will be filed in the Resolved Complaints folder, details in the Customer Service system updated and the case set to closed status. Customer Service will provide reporting on a regular basis to the Privacy Compliance Officer to monitor all cases pertaining to Privacy complaints. Reporting to management will contain the following;

  • Number of cases logged
  • Time taken to resolve complaint on closed cases
  • Number open cases at current time
  • Length of time elapsed on current open cases
  • Severity of open/closed cases

Statistical information concerning Privacy related complaints will be reported on a weekly basis. High-level statistical information concerning Privacy complaints will be reported to the privacy Compliance Officer on a monthly basis.

Data storage

All email items over 30 days are “vaulted’ into corresponding folders via the Exchange Archive and these emails retained for 7 years. Any items remaining in the Inbox and/or Sent box will by default still be open complaints, with the initial date of complaint receipt visible.

Acknowledgement of a complaint

Each complaint will be acknowledged at the time that the complaint is received and a case number advised to the complainant at this time.

Commitment to resolution of complaints

Changing Habits commits to providing a final response for complaints that it receives within 30 days of receipt of the complaint.

Response to a complaint & communication of decision

Contact will be made to each complainant within 5 working days of receiving the complaint to provide either a reply with a resolution or the current status of the complaint.

Monitoring of the complaints handling process

All cases in the Customer Service system will be reviewed; For complaints older than 10 working days, perform follow-up action; such as status/progress checking with area the complaint was referred to. For complaints older than 15 working days, reported and escalate the status/progress check to management of responsible area via the Customer Service Manager. For complaints older than 20 days, reported and escalate the status/progress check to the Privacy Compliance Officer via the Customer Service Manager. For complaints older than 25 days, reported and escalate the status/progress check to the General Manager of the responsible area via Privacy Compliance Officer. It is anticipated that NO complaints will be unresolved after 30 working days.

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