Customer Feedback Policy

Approval Date: February 2023
Review Date: February 2025
Review By: Customer Service Manager and COO

This policy concerns the management of feedback, comment or complaints received by phone or other contact with Insight or its charity clients regarding raffle fundraising by Insight for the respective client. Matters which do not relate to a raffle or client fundraising are the sole concern of the client or Insight as the case may be.

Context of Feedback Received
a) The purpose of the contact made with potential supporters, usually by telephone is an offer to sell and the sale of entries in a raffle game for the purpose of charitable fundraising.
b) Insight holds or receives contact particulars for prospective supporters, new supporters and existing supporters. Insight is communicating with supporters to create the purchase, answer queries and to fulfil the purchase and to offer further purchases.
c) The agreement to buy is completed by the provision of a confirmation of the acceptance, the payment and any conditions of the purchase. Asking to make a recorded confirmation is Insight Policy but is not a necessary pre-condition of a valid sale. A customer may decline to provide a recording or consent to destruction of the recording.
d) Any confirmation of the purchase is made to provide quality assurance in the event of a query between Insight’s sales agent (for the client and Insight) and the potential customer or contact and to provide a record of the provision of payment records (not the card details) for paperless direct debit and to confirm understanding of the concluded purchase.
e) Insight’s systems may record customer communications in accordance with this policy and the NSW Surveillance Devices Act 2007 by obtaining a consent to record from the contact.

Procedure
1. Management of the receipt of complaints and feedback shall follow this policy.
2. Delivery of all responses to clients and reports to any involved party shall be primarily undertaken by InsightCFS on a day-to-day basis.
3. Insight shall appoint a complaint manager (normally the Insight Client Manager) and each client will provide a single point of contact for complaints and reports.
4. Whenever a complaint is received by the client the issue shall normally be referred to Insight for resolution and for a report to be provided to the client.
5. Where the Client undertakes to resolve the complaint itself Insight is bound by this policy only.

Insight shall maintain the following process for dealing with Feedback and Complaints under these steps:
Receiving
Prioritizing
Analyzing
Investigating
Addressing the Customer
Report all complaints.
Review of processes
Receiving

1. Insight shall deal with complaints as either:
A. receipt of the complaint, assurance and provision of information and if requested refund and cancellation of the purchase, or
B. client development opportunities, that is for the contact to be informed about the work of the client and the importance of fundraising, for the contact to be maintained as a sales prospect, for any funds received to be secured, for the customer to feel satisfied with the outcome or for the customer to be encouraged to maintain or increase his or her support.
2. Any threshold issues should be addressed as early as possible normally within the initial call.
3. All rights and entitlements under applicable legislation shall be addressed or kept in mind including:
Cooling off period for cold sales over $100.
Responsible Gaming Rules
Vulnerable Contact issues.
Privacy and data queries.
Australian Consumer Law Compliance generally.

Prioritising
1. Insight shall prioritise all complaints as:
Number 1. Involving a serious issue. Perceived dishonesty, gross rudeness.
Number 2. A routine complaint involving a contact or transaction which may jeopardise reputation. Purchase conditions, product query, privacy.
Number 3. Customer information or query. No anger or distress involved.

This last group are not complaints but are managed as customer service and may upon consideration be re-rated to Number 2.
Insight uses a classification method to code complaints each of which may fit within these broad categories depending on the process and content of the complaint.
2. When dealing with a complaint the contact shall be informed;
• That insight has a method for assisting contacts
• What action (e.g. investigation and response) is to occur
• That an answer or action will be provided within 7 days
• What initial action is to be taken.
• How data shall be handled for confidentiality or privacy implications of the information provided. (Information is retained as part of personal information. See Privacy Policy.)
3. The contact shall be suspended from further sales calling contact by Insight until the complaint is resolved and the customer may be reinstated to calling lists.
4. Number 1 and 2 type complaints shall be referred to an Insight manager for supervision or to be handled by that person.
5. Number 1 complaints shall be notified to the client immediately and as the need arises particularly if the client has previously been involved or the subject content recommends client involvement.

Call records
Insight maintains the following records of calls:
1. Calling records being phone call data maintained by Insight from its dialing systems.
2. Phone call recording where the contact and agent have consented to recording and where Insight obtained consent from the contact and retains the recording of the sales agent’s work.
3. Sale record means the sale record including contact, fulfilment, purchase, payment and customer service data, recording of the phone call which is consented to by the customer.

Investigating
Insight shall gather all relevant information from the customer by reference to information in its records and as provided by the sales agent.
Recordings shall only be considered if either:
A. The customer consented to the sale recording.
B. The legal personal representative of the customer who was recorded agrees to hear a sale recording.
C. The sales agent consents to its use as part of the complaint resolution.

Call recordings may under conditions A, B or C above be considered by the Insight Complaint Manager and in the event of category 1. complaints may be played over the phone or at a meeting to the Client Representative where necessary to support a proposed or recommended action.
Insight Call recordings (copies of the voice file) shall not be provided to anyone outside Insight absent a Court order.

When resolving a complaint Insight shall consider and decide:
i. what issue is at stake:
ii. what the contact has said
iii. if the nature of the complaint has regulatory or client reputation implications.
iv. If the complaint is true or false
v. the sufficiency of the evidence or support for the complaint

Insight shall determine:
• If the complaint was established.
• What data or information supports the conclusion.
• What action Insight is obliged to take (where it is in the wrong) and what action it wishes to take in order to:
a. Protect the reputation of the client; and
b. Maintain the contact as a potential further of continuing supporter.

Addressing the Customer
A complaint should be resolved simply with:
• Provision of an explanation or description of what occurred and why
• An oral apology
• Correction of any record

Generally, the Compliant officer for each party (Insight and a client) must:
i. Resolve any complaint from a third party within 7 days of receiving that complaint.
ii. In resolving all complaints Insight shall advise the complainant of the basis or authority for the solution (policy, regulation, raffle rules, etc.).
iii. If the complainant is not satisfied with the outcome, the contact person will advise the complainant of other avenues of enquiry such as the Department of Consumer Affairs, raffle regulator, ACMA or legal advice.
iv. Inform the other party of the details of the complaint within seven business days of being notified of the complaint; keep the other party regularly informed of the progress or resolution of any unresolved complaint.
v. If the client or Insight in managing a complaint is unable to resolve a complaint within the timeframe requested or agreed, that party must notify the client of the reasons for the delay in resolving the complaint. The parties will then agree on an appropriate timeframe to resolve the complaint.
vi. Where a contact has been treated unfairly or misled or did not understand the purchase and the complaint is addressed to a sales room supervisor at Insight or of the client, a refund may be offered. That is, a sales agent or customer service officer must not authorise refunds at their own initiative.
vii. All complaints shall be dealt with over the phone unless raffle fulfilment material needs to be re-sent. Letters of apology are not to be written.

Report all Complaints
Insight shall collate complaint records and provide monthly reports of the complaint event to its clients. The reports shall identify the customer and the nature of the complaint and its resolution.

Review of Processes
Insight shall review complaint reports to determine the source and what measures can be used to prevent complaints.
Policy revised 7 February 2023