Complaint Handling Policy

(web version)

Version V06/26

Complaint handling policy

We are committed to providing a service of the highest quality and we take any complaint seriously. If at any time you would like to discuss how our service to you could be improved, or if you are dissatisfied with the service you are receiving, we hope that you will bring your concern to our attention. If your complaint relates to a personal data protection matter, then please use the Personal Data Protection Complaint Policy on page 4, which involves escalation to the Information Commissioner’s Office (ICO).

Step 1 – Let your usual point of contact know

In the first instance, we recommend that you discuss any problems with the person responsible for handling your affairs, your account manager. They are available on 01204 890 760, Monday – Friday 9am to 5pm. If you have a customer reference number (CLIENT ID) then we recommend that you have this to hand. You will be asked some straightforward security questions so that we can access your file.

If you feel this is not appropriate or prefer, you can write to us at Debt Advisory Services (Scotland) Limited trading as Debt Advisory Services, Crescent House, Lever Street, Bolton BL3 6NN or email us at complaints@debt-advisory-services.co.uk. Please address this to our Complaints Officer.

We will do all we can to resolve your complaint within 3 business days. If we are unable to do this, we will write to you to tell you what we have done to resolve the problem, or acknowledge your complaint and let you know when you can expect a full response. Any complaint verbal or written will be referred to our Complaints Officer at the earliest opportunity or to a member of the senior management if the Complaints Officer is unavailable. We aim to:

• Promptly acknowledge the complaint in writing (i.e. by letter or email)
• Give details in our acknowledgement letter of the Financial Ombudsman Service
• Make contact to seek clarification on any points where necessary
• Fully investigate the complaint
• Keep you informed of our progress, including a unique complaint reference
• Discuss with you our findings and proposed response

You will receive contact from us advising on progress if we cannot respond immediately. We will let you have our final response as soon as possible and not later than eight weeks. The timescale can be dependent on the complexity of the case, which may sometimes involve a third party.

Our investigation approach

We will establish the nature and basis of your complaint having due regards to the Financial Conduct Authority’s direction on complaint handling by consumer credit firms:

• Deal with complaints promptly and fairly
• Give complainants clear replies and, where appropriate, fair redress

Eligible complainants

It is our policy to treat all complainants the same, however, eligible complainants are legally defined and have additional rights in law that we must acknowledge and adhere to.

The Financial Conduct Authority complaints rules apply to complaints:

• Made by, or on behalf of an eligible complainant
• Relating to regulated activity
• Involving an allegation that the complainant has suffered, or may suffer, financial loss, material distress or material inconvenience.

Complaints settled within 3 business days

Complaints settled to your satisfaction within 3 business days can be recorded and communicated differently.

Where we consider a complaint to be resolved to your satisfaction under this section, we will promptly send you a ‘Summary Resolution Communication’, being a written communication from us which:

1. Refers to the fact that you have made a complaint and informs you that we now consider the complaint to have been resolved to your satisfaction
2. We will tell you that if you subsequently decide that you are dissatisfied with the resolution of the complaint you may be able to refer the complaint back to us for further consideration or alternatively refer the complaint to the Financial Ombudsman Service
3. Indicates whether or not we consent to waive the relevant time limits
4. Provide the website address of the Financial Ombudsman Service (see below)
5. Refer to the availability of further information on the Financial Ombudsman Service website (see below).

In addition to sending you a Summary Resolution Communication, we may also use other methods to communicate the information where:

• We consider that doing so may better meet your needs; or
• We have already been using another method to communicate about the complaint (e.g. email).

Final response

This will set out clearly our decision and the reasons for it. If any compensation is offered then a clear basis of the calculation will be shown. We consider a complaint closed when we have made our final response to you. This does not prevent you from exercising any rights you may have to refer the matter to the Financial Ombudsman Service.

Step 2 – The Financial Ombudsman Service

If we do not respond to you within 8 weeks from the date you first raised your complaint or if you remain dissatisfied with our response, you can ask the Financial Ombudsman Service for an independent review.

The Ombudsman will only consider your complaint once you’ve tried to resolve it with us, so please take up your concerns with us first and we will do all we can to help. You have to register a complaint with the Ombudsman within six months of receipt of our final response.

You can write to the Financial Ombudsman Service at: Exchange Tower, London E14 9SR.

Tel: 0800 023 4567 (free for most people ringing from a fixed line) or 0300 123 9123 (cheaper for those calling using a mobile) or 020 7964 0500 (if calling from abroad). From 8 June 2026, email can only be used in exceptional circumstances.

Online form: https://complaintsubmission.financial-ombudsman.org.uk/

Web: www.financial-ombudsman.org.uk

The complaints-handling rules are published as part of the Financial Conduct Authority’s Handbook – in the section called Dispute resolution: complaints.

Our Data Protection Complaints Policy

This Data Protection Complaints Policy meets the requirements of the Data (Use and Access) Act 2025 (DUAA), Information Commissioner’s Office (ICO) guidance, and the Financial Conduct Authority (FCA) DISP rules where the complaint may be a hybrid of a data protection complaint and one that relates to conduct under the FCA rules.

Effective Date: 19 June 2026

Regulated Status: Authorised and Regulated by the Financial Conduct Authority (FCA)

Scope: Covers all complaints regarding personal data privacy, handling, or breaches

Legal Mandate: This policy establishes our internal process for resolving data protection complaints under Section 164A of the Data Protection Act 2018 (amended by the DUAA).

No Exemptions: This policy applies universally across all business units, handling data for retail customers, employees, suppliers, and third parties.

FCA Consumer Duty Alignment: In line with the FCA Consumer Duty, this process supports consumer understanding, acts in good faith, and ensures clients face no unreasonable barriers when asserting their data rights.

FCA Reporting Alignment: If a data complaint also triggers FCA DISP definitions (e.g., financial loss or material distress due to a data error), the investigation will track toward the standard FCA 8-week final response limit, but communication updates will be issued to satisfy DUAA “keep informed” requirements.

1. Overview

We take your personal data privacy seriously at every stage of your personal journey with us.

This policy explains how you can complain if you feel we have mishandled your personal information. It outlines our timelines, your rights, and how we investigate concerns.

This is closely linked to our Privacy Policy which can be found at:

https://debt-advisory-services.co.uk/privacy-policy

2. How to make a complaint

You do not need to use legal language or quote laws to complain. You can submit your data protection complaint through any of the following channels:

• Email: complaints@debt-advisory-services.co.uk
• Phone: Call our Data Compliance Team on 01204 890 760, Monday – Friday 9am to 5pm
• Post: Write to Data Protection Officer, Debt Advisory Services (Scotland) Limited, Crescent House, Lever Street, Bolton BL3 6NN

3. Our response timeline

We manage data complaints according to the statutory deadlines set by the DUAA 2025:

• Acknowledgment: We will confirm receipt of your complaint within 30 days.
• Investigation: We will begin checking your issue without undue delay.
• Updates: We will update you regularly if the investigation takes time.
• Final Outcome: We will send you our final decision in writing without undue delay once resolved.

4. How we investigate

Our Data Protection Officer (DPO) oversees all data complaints. Our Complaints Officer is also listed on the FCA register. We will:

• Log the exact date we received your complaint.
• Review how your data was collected, stored, or processed.
• Assess if a data breach occurred and fix any security gaps immediately.
• Keep a complete, auditable record of our actions and decisions.

5. Link with the FCA Rules

As an FCA-regulated firm, we run this data policy alongside our standard financial services complaints procedure as a debt purchaser.

• Separation: We will not delay resolving your data complaint while waiting for a separate financial dispute to settle, if applicable.
• 8-Week Rule: If your data complaint directly impacts a broader financial service issue, we will aim to resolve all aspects within the standard FCA 8-week limit where possible.

6. Escalating your complaint

If your dissatisfaction relates specifically to how we handled your personal information, your data rights, or a data protection breach, you have a statutory right under Section 164A of the Data Protection Act to escalate your matter to the Information Commissioner’s Office (ICO).

• Website: www.ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113
• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Final Response letter alignment

When drafting our final resolution letter for a joint complaint that relates to FCA rules and data protection rules under ICO oversight, we will provide 2 distinct escalation routes. Our letter will explicitly state:

1. If you remain unhappy with how your personal data was handled, you have the statutory right to escalate to the ICO.
2. If you remain unhappy with the financial service or financial impact, you have the right to go to the Financial Ombudsman Service (FOS) within six months.