Autosecure is committed to abiding to the Principles of Business laid out by the Financial Services Regulator. This Policy privides guidance on how we look after the best interests of out customers by ensuring all the information we provide to them is clear, fair and not misleading. That we handle all matters including conflicts of interest with care, skill and thought.
Treating Customers Fairly (TCF)
How Autosecure Achieve Treating Customers Fairly
How we achieve this
We have considered all areas where we consider a risk or have used examples that other companies have found a risk and assessed each potential situation. Our actions will ensure that the Unfair Treatment of Customers is eliminated or kept to a minimal risk and that we monitor those areas. We also conduct surveys with our customers to provide best practise and identify new areas .
Why we have a policy
The policy has been written to communicate to thos working within our firm to deliver the best possible service to customers. This is in the interests of customers and staff alike.
TCF Outcomes These are the outcomes that regulators want fro customers and the outcomes we want for ourselves in order to provide a better service.If customers are disatissfied then we will take immediate action
1. If you deal with Autosecure you can be sure that treating customers fairly is part of our culture 2. Products and services used , sold and marketed are targeted to meet consumer needs. 3. Consumers are provided with clear precise information before during and afte r the point of sale 4. Advice is suitable for consumers circumstances 5. Products will perform as we claim, and the service is of a level that we have indicated. 6. We will not impose unreasonable barriers to change a product, a service provider or make a complaint.
Action Plan The way we will actively measure our performance is each area is as follows
Client Feedback We actiavely promote client feed back from the initial enquiry through to delivery and beyond. All lost sale customer receive and automated survey to give feedback.
During the sales process, we ask customers to fully review the new, used or vehicle modification document to ensure that the product matches their needs and that we have correctly identified their needs. We actively encourage Trustpilot Ratings in a transparent manner.
Real Time Staff Monitoring
Sales staff are subject to monthly monitoring in the course of the sales process using a backend CRM and call recording. An manager checks that customers are dealt with. All sals staff are subjected to weekly meetings to ensure compliance and to aid with sales. The meetings also serve to identify issues as they arise and take action accordingly.
We have a regular file audit programme taken out by an independent consultant, who assess the clarity of the information provided and the suitability of our products offered to clients. Information gained is immediately fed back to Autosecure to report our failings
Advertising and Promotions Checking
All our own advertising and the website is checked by our Marketing Executive and signed off by the MD or Sales Managers to ensure clear non misleading advertising.
Our policy of remuneration of sales and support staff will include Key Performance Indicators in compliance, training, and competence and treating customers fairly. The monitoring ensures that no pressured selling occurs, nor inappropriate methods. All staff are subject to an annual assessment to assist outcomes 1,3,4,5 and 6
We conduct quarterly business reviews in which changes procedures and marketing strategies are considered and the impacts on our customers.
We will review sales and persistency figures split by provider, product and advisor on a monthly basis to monitor any trends that emerge If an unusual pattern of change is noticed we will investigate this and take out corrective action, and document findings, to address outcomes.
Training and Competence Regime We will record our training competency procedures to ensure advisors have up to date knowledge of products in which they are involved. We will ensure regulatory standards are met to satisfy CONC requirements to address Point 4
We keep a log of all customer concerns and a summary response of the outcome.
Where the complaint is directed at a supplier or provider we will investigate and take the appropriate action
Where specific issues arise we will add this to our policy where things come to light
Client Understanding We need to know how much knowledge customers have of our products
Assumptions such that customers already know our products could lead to a lack of clarity and confusion, and this in turn offer the wrong products that could have a negative impact on their fiscal wellbeing in the future tense. We cannot assume that a customer understands the agreement .
We will endeavour that simple terms and language is used to clients to facilitate their understanding and shall seek a clear process to ensure that the correct products are offered. To clearly point out cancellation rights and encourage customers to ask questions
Controls We monitor the suitability of what we recommend by undertaking internal file audits for compliance and quality. The results are subject to management meetings and business reviews. Reviews should be clear, features explained including exclusions and limitations. Descriptions of options if appropriate e.g Affordability vs Financial Commitment showing a risk warning If features are not present these need to be reported as a training issue
If a customer complains and does not receive a satisfactory outcome we are risking a poor business reputation. Obstructing complaints fails to treat customers fairly. Staff who are not familiar with this or do not follow procedure may mislead customers as to their rights.
Complaining customers must be treated seriously, and dealt with in accordance with the prescribed procedure and “Soft “ complaints that do not involve financial loss or material distress or inconvenience be rectified as soon as possible .
Staff must read and sign off the complaints training materials provided every 12 months and whenever personnel involved or changes made by the regulator of governing body. A copy is made available for staff to refer to and given to customers
We have an appointed complaints manager who will investigate any complaints made and act accordingly, looking for the root cause. All staff to be signed off for complaints training forming part of their appraisal and competency Addressing 6
Regulatory and Legal changes We need to keep up to date with legislation, regulation and best practise within the consumer credit sector in order to serve correctly
If we continue to suffer compliance failures we jeopardise our authorised status and this will impact on the business and the service of existing clients. Consumer regulation is usually brought in to make improvements so failure to adopt these measures could lead to a decline in services offered to the customers in comparison to the competition.
Our compliance officer ensures that legal updates are noted by undertaking professional development, subscribing to trade publications and reading literature from our providers and business partners. Changes as necessary .
Compliance issues are a standard topic in our business agenda.
How we pay staff and contractors, how we appraise performance and what we reqrs with pay incentives
A focus on items such as sales targets might lead to mi selling and poor record keeping and lack of diligence
The firms systems that relay on performance related pay is designed to reflect our commitment to complaint practices and treating customers fairly. Salary and bonus should not be dictated purely by sales performance. Also are customer retention, suitability and delivery within timescales .
Compliance performance is monitored by file audit reviews and business reviews. Review results feature in staff appraisals and key performance indicators, record keeping and used when reviewing pay and bonuses.
This is the quantitative and qualitative information that we use when reviewing our business strategy and performance
Failure to product accurate, timely and clear information will hinder us in identifying trends and to identify issues
The key to the information we provide is our back office recording system This is kept up to date and accurate We are looking for indicators such number of new enquiries, speed of service provided, level of conversions and lost sales
Record keeping is a key performance indicator.
How we consider the effects of any strategic decisions made
Customers may be adversely affected every time a change is made to the firm e. New Telephone or computer system Changes or other failures in the business can cause less hours being devoted to customer care within the business.
The management team ensure a business plan is in pace to anticipate these strategic changes. Controls If there is a major change in the business its necessary to clarify every staff members role and position to avoid panic to continue business without disruption. Conflicts Of Interest Means a financial or time involvement that conflicts with the service provided by an individual or create an unfair advantage
If our interest conflict with those of a client for client detriment Close links with another group Higher commission rates or incentives placing orders with a particular provider such as gifts or incentives Or where customers may be involved in conflict with each other
We make sure all our services are independent of providers and do not create a tie to specific provider We record gifts or hospitality Any conflicts declared
Our files and audits will reveal the split of providers used so we can investigate any
abnormalities . Staff are aware of our policies and ensure customers needs are placed first . If a conflict of interest is noticed between clients we make them aware and let them choose
Autosecure Complaints Procedure
Complaints please send to email@example.com
or write to
Unit 5, Penllyne Way,
Vale Business Park, Llandow,
Vale Of Glamorgan,
What we do if we receive a complaint from you We will try and resolve your complaint immediately. If the complaint cannot be solved immediately then we will send you acknowledgement within 5 working days and a final response where possible within 10 working days. The Financial Ombudsman requires that a final response is within 8 weeks.
If you are still not happy with our decision
BVLRA Conciliation Service Autosecure is a member of the British Vehicle Leasing Association, and any unresolved disputes may be referred to the BVLRA
British Vehicle Rental and Leasing Association River Lodge Badminton Court Amersham HP7 0DD
The BVLRA Conciliation Service will investigate potential breeches in the BVLRA Code of Practise and aim to reach a resolution using information submitted by both parties. Any information requested will be sent by Autosecure within 5 working days The BVLRA aims to resolve disputes within 30 days
Financial Ombudsman If you have a regulated consumer contract and not satisfied with the final response of the BVLRA you may be eligible to refer the matter to the Financial Ombudsman Service within six months of our final response.
Data Protection Policy
Autosecure Data Protection Policy
Our data protection policy sets out our commitment to protecting personal data and how we implement that commitment with regards to the collection and use of personal data. We are committed to:
• ensuring that we comply with the eight data protection principles, as listed below
• meeting our legal obligations as laid down by the Data Protection Act 1998
• ensuring that data is collected and used fairly and lawfully
• processing personal data only in order to meet our operational needs or fulfill legal requirements
• taking steps to ensure that personal data is up to date and accurate
• establishing appropriate retention periods for personal data
• ensuring that data subjects’ rights can be appropriately exercised
• providing adequate security measures to protect personal data
• ensuring that a nominated officer is responsible for data protection compliance and provides a point of contact for all data protection issues
• ensuring that all staff are made aware of good practice in data protection
• providing adequate training for all staff responsible for personal data
• ensuring that everyone handling personal data knows where to find further guidance • ensuring that queries about data protection, internal and external to the organisation, is dealt with effectively and promptly
• regularly reviewing data protection procedures and guidelines within the organisation.
Data Protection Principles
Personal data shall be processed fairly and lawfully.
• Personal data shall be obtained for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
• Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
• Personal data shall be accurate and, where necessary, kept up to date.
• Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
• Personal data shall be processed in accordance with the rights of data subjects under the Data Protection Act 1998.
• Appropriate technical and organisational measures shall be taken against unauthorised and unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Autosecure Conflict of Interest Policy
All staff, volunteers, and management committee members of Your-OrganisationName will strive to avoid any conflict of interest between the interests of the Organization on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.
The purposes of this policy is to protect the integrity of the Organization’s decisionmaking process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of volunteers, staff and committee members.
Examples of conflicts of interest include:
- A committee member who is also a user who must decide whether fees fom users should be increased.
- A committee member who is related to a member of staff and there is decision to be taken on staff pay and/or conditions.
- A committee member who is also on the committee of another organisation that is competing for the same funding.
- A committee member who has shares in a business that may be awarded a contract to do work or provide services for the organisation.
Upon appointment, each committee member will make a full, written disclosure of interests, such as relationships, and posts held, that could potentially result in a conflict of interest. This written disclosure will be kept on file and I will be updated as appropriate.
In the course of meetings or activities, committee members will disclose any interests in a transaction or decision where there may be a conflict between the organisations best interests and the committee members best interests or a conflict between the best interests of two organisations that the committee members is involved with.
*Option 1: After disclosure, I understand that I may be asked to leave the room for the discussion and may not be able to take part in the decision depending on the judgement of the other committee members present at the time.
Any such disclosure and the subsequent actions taken will be noted in the minutes.
This policy is meant to supplement good judgment, and staff, volunteers and management committee members should respect its spirit as well as its wording.
Date Adopted: _______________14/11/2016_______
* chose which option you prefer.
Advert explanation clear and simple
At Autosecure we are dedicated not only to presenting you with the best deals but showing you in simple terms how we reach these deals and any potential risks generally to using them
Our Promise to You
- Not to use misleading headlines
- Not to use unfair comparisons
- Not to display important information in small print
- Not to not display risks non prominently
- To try and explain in basic terms
- Please see above for details for risks and charge that are common
- To make sure those doing the advertising understand the rules