Caring for our customers in private hearing care

 

1. Developing a Consumer Code for the future

 

The British Society of Hearing Aid Audiologists together with companies in the sector, recognised the need to demonstrate self-regulation and good standards of customer care following the abolition in 2010 of the Hearing Aid Council along with its specific consumer regulations.

 

We have negotiated with the British Healthcare Trades Association to allow our members to join the take advantage of their  voluntary Consumer Code, approved by the Office of Fair Trading, which will give customers benefits beyond the protection afforded by law.

 

The aim of the Consumer Code Approval Scheme is to put the 'self' back into self-regulation.

 

We recognise that adopting and delivering consistent standards, procedures and expectations across our sector will give our customers the confidence in our service which is critical to our profession and to our businesses as we go into the future.

 

2.  Addressing customer concerns now

 

2.1 We also recognise that early adoption of a user-friendly procedure for resolving complaints, and the application of good customer care practice in line with, but in advance of, full participation in a Consumer Code, will help and benefit customers now.

 

It will deal proactively with any concerns customers have about the service they have received.

 

It will give customers assurance that they will continue to receive good standards of care throughout the period of transition between regulatory regimes and beyond.

 

It should address, resolve and ultimately reduce the number of complaints which need to be formally considered by the Hearing Aid Council.

 

It will give companies and their staff the impetus to adopt and undertake training in new customer care practice.

 

It will send a strong signal that we - businesses in the sector, and professional practitioners - are rising to the challenge. We are seizing the opportunities to ensure effective self-regulation of private hearing care services.

 

2.2  Any size of company and sole traders will be able to benefit from participating in complaints resolution now and, in future, a Consumer Code. The term "participating company" is used inclusively throughout this guidance.

 

3. Resolving complaints

 

3.1   The procedure and good practice for resolving complaints is based on the principles that will be eventually included in a comprehensive Consumer Code, and is as far as possible compliant with Code guidance and the requirements of the Office of Fair Trading.

 

3.2   This requires all participating companies to have:

 

• A speedy, responsive, accessible and user-friendly procedure for customer complaints.

• A specific reasonable time limit for responding to complaints.

• A requirement that participating companies co-operate with local consumer advisers or any other intermediary acting on behalf of a consumer when making a complaint.

• A conciliation service directed at arranging a decision acceptable to both parties.

• A low-cost, speedy, responsive, accessible and user-friendly independent redress scheme to resolve customer complaints which are not resolved by conciliation.

• Decisions from such a scheme are binding on participating companies.

 

4   Complaints handling procedure

 

4.1   Participating companies will have a speedy, responsive and user friendly procedure for the resolution of complaints, i.e. any expression of dissatisfaction regarding the product and / or service supplied.

 

 Participating companies will normally expect to respond to complaints within 5 working days of receipt and aim to resolve complaints within 20 working days.

 

4.2  Customers will be informed how to make a complaint; to whom within the company they should address their complaint; what information they are required to provide; and the timescales that will apply to dealing with the complaint.

 

Procedures for dealing with customer complaints will have no more than:

• 3 levels of management within large companies and two for medium, which includes the opportunity for the complaint to be considered by someone other than the original decision maker and for ownership of the complaints process at the top of the organisation;
• 1 level for self-employed.

 

4.3  The customer will be informed by the company that should the complaint not be resolved to the satisfaction of the customer, they have the right to contact the Conciliation Officer at BSHAA, who will follow the procedure outlined later in this document for conciliation and, if need be, in order to access independent redress.

 

4.4   Participating companies will offer maximum co-operation with consumer advisers or any other intermediary consulted by the consumer, such as a Citizens Advice Bureau, or Trading Standards Officer.

 

4.5 Participating companies will ensure that staff are trained in customer care.

 

4.6  Participating companies will ensure that all complaints are logged and a step by step log of progress on the complaint is kept and can be made available to the conciliation or independent redress service if required. Likewise a log of all communications and copies of all correspondence relating to the complaint will be kept and made available if required.

 

5 Informing Customers

 

5.1 Participating companies will produce a "How to complain" leaflet, using the good practice standards for client information, and use it to ensure that each customer is fully informed about how to raise any concerns and if necessary, register any complaint about the service; at every stage from point of sale, through pre-contract to contract and into after care.

 

6 BSHAA Conciliation service

 

6.1 BSHAA will provide, at no cost to either party, a conciliation service with the aim of resolving the complaint in a manner acceptable to both parties.

 

6.2.On receipt of any new complaint, the Conciliation Office will confirm the status of the customer and complaint with the company contact in order to ensure that in-company resolution procedures have been exhausted and if not, refer the customer back to the company.

 

6.3 The Conciliation Office will seek information from the complainant on the nature of the complaint; and a report from the company, including the customer's documentation, within 5 working days.

 

6.4 The Conciliation Office will allocate the complaint to one of a panel of trained conciliators, who will seek to facilitate resolution within 15 working days of receipt of the customer's request for conciliation.

 

6.5 The company will make available to the conciliator any further information, documentation or access to personnel, which the conciliator deems necessary to facilitate successful conciliation.

 

6.6 The conciliator may access, via BSHAA, any specialist advice which they deem necessary to facilitate successful conciliation. 

 

6.7 Conciliation is aimed to resolve the matter in a manner acceptable to both parties. It is not an investigation.

 

Should the Conciliator receive information pointing to a potential responsibility for the company to report within the Hearing Aid Council's guidance on serious matters of employer or dispenser fitness, such information would be immediately referred back to the company for investigation.

 

Should the conciliator receive information pointing to a potential breach of BSHAA Codes of Practice by a member of the Society, such information would be referred to the Society to institute any investigation, which would be entirely separate from, and not affecting or delaying conciliation.

 

7 Independent Redress

 

7.1 If the complaint is not resolved by conciliation, the customer will be offered access to independent redress via arbitration, binding on both parties. The customer has the right to forego arbitration and pursue other legal avenues of redress, but at the risk that failure to take up the offer of arbitration could seriously prejudice their chances of redress through the courts.

 

7.2 Where referral to the Independent Arbitrator is chosen, an Arbitrator will be appointed, via BSHAA Conciliation Office, at no cost to the complainant. The company will meet the costs of arbitration.

 

The objective of the Arbitrator is to arrive at a conclusion that is fair and reasonable in the circumstances, looking at all the evidence presented by both parties. The Arbitrator is an individual who is completely independent from BSHAA and from the industry. 

 

7.3 BSHAA will use the OFT-approved Independent Consumer Arbitration Service administered by IDRS Ltd.  ICAS_Rules_Application.pdf

 

7.4 The Conciliation Officer will pass all the evidence gathered, including copies of all correspondence between the parties and BSHAA, to the Independent Arbitrator within five working days.

 

How to Complain