Does your Complaints Policy have to be on your website?

No, it doesn’t. What the TCP Code requires is that a summary of your full Complaints Handling Process  is posted, and it sets out minimum requirements for the content of that summary.

Can you satisfy the requirement by posting your full Complaints Handling Process? We think so, but there are some comments around that.

It has to be concise and accessible

The Code requires that customers have access to a version of your Complaints Process that they can readily ‘digest’. So if your full process is long and technical and really designed for internal use, it may not be suitable as a complaints process summary.

It may include confidential info

The Code requires your complaints processes to be clear and accessible. But that doesn’t mean that everything in your full process document needs to be, or should be, posted on your website. Your business has legitimate commercial interests, just as customers have their own interests. For instance, it may be brilliant for your customer care staff to have the mobile number of the department head, in case an urgent and difficult matter needs their attention while he’s not in the office. But the fact that the number is in your internal process documents shouldn’t mean it is made public as well.

What should your summary include?

This is another area where the TCP Code doesn’t win any clarity awards. But we’ve prepared a Complaints Handling Process Summary template that ticks as many of the boxes as we can identify, and you can adopt it or adapt it to your business.


About Peter Moon

A telco lawyer with a truckload of experience
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