Handling of Privacy Complaints
This document describes the complaint management process that Target uses to handle Privacy related complaints. It describes an effective and responsive process that reflects the needs of both the complainant and Target.
It provides Target with both a customer focused, consistent and systematic approach to resolving complaints received relating to the Privacy.
Information on how to make a complaint forms part of the Privacy Statement and is available on Target’s website and on request from Customer Relations.
The complaints handling process is easily accessible. Contact for making a complaint, or requesting access to information, is made by phoning a dedicated toll free phone number or emailing (firstname.lastname@example.org). This phone number is 1800 814 788
Each complaint is received by email, mail or phone and acknowledged as received at that time. Each complaint is assigned a case number using the Customer Relations system and the case number is provided to the complainant. Expectations of complaint resolution timelines are to be provided to the complainant at the time the complaint is acknowledged and recorded.
Each complaint will be handled in an objective and unbiased manner.
Each complaint will be treated confidentially and information collected concerning the complaint will remain confidential as per Target internal policy and procedures. Non-disclosure agreements are in place with all team members handling complaints and individuals are covered by acceptance of the Target Code of Conduct as part of employment with Target. Where third party service providers are involved with the investigation or resolution of the complaint, their involvement is covered by the confidentiality and privacy obligations contained in the services provision contract.
Accountability for receiving complaints relating to the Privacy is assigned to the Target Customer Relations Team.
Accountability for resolution of complaints relating to the Privacy is assigned to the Privacy Compliance Officer and may be delegated to the Customer Relations Manager.
Accountability for communicating significant breaches to the Finance Director and Managing Director is assigned to the Privacy Compliance Officer.
A significant breach includes, but is not limited to:<
- a material compliance breach, or
- a breach that may lead to material brand reputational damage, or
- a breach has a high probability to lead to an individual or the company incurring a fine.
Complaints handling framework
Collection of information
An individual with a complaint will raise a complaint using established procedures by using the contact details publicised in the Privacy Statement.
All complaints pertaining to the Privacy will be entered into the Customer Relations system by a member of the Customer Relations team. The Customer Relations team will investigate the complaint to establish the facts and recommend a resolution to the Customer Relations Manager.
If the complaint requires follow up in order to close the case it will be referred from Customer Relations to the Privacy Compliance Officer at email@example.com
The mailbox will be permanently opened in Outlook, and will also be accessible on request by other nominated Target team members (to cater for leave, illness, etc).
The mailbox is included in the Target disaster recovery planning and is backed up regularly to safe guard data. All traffic received/sent from the mailbox is logged.
All incoming emails will be assessed for the nature and severity of the complaint.
Investigation of Privacy related complaint
A Customer Relations team member as selected by the Customer Relations Manager will conduct analysis on each complaint to determine the resolution required. Each complaint will be handled based on the nature of the complaint and the information concerned.
Target Customer Relations will continue to manage each case when referred to other Target internal functions and will be responsible for follow up and eventual closure of the case in the Customer Relations system.
All complaint details will be recorded in the Customer Relations system. Details including the date the complaint was received/closed, current status of the complaint (open/closed), details of the complaint made, details of the resolution provided and communications material pertaining to the complaint.
Once a complaint has been resolved, all received and sent emails pertaining to the complaint will be filed in the Resolved_Complaints folder, details in the Customer Relations system updated and the case set to closed status.
Customer Relations will provide reporting on a regular basis to the Privacy Compliance Officer to monitor all cases pertaining to Privacy complaints.
Reporting to management will contain the following;
- Number of cases logged
- Time taken to resolve complaint on closed cases
- Number open cases at current time
- Length of time elapsed on current open cases
- Severity of open/closed cases
Statistical information concerning Privacy related complaints will be reported on a weekly basis.
High-level statistical information concerning Privacy complaints will be reported to the privacy Compliance Officer on a monthly basis.
All email items over 30 days are “vaulted’ into corresponding folders via the Symantec Enterprise Vault and these emails retained for 7 years.
Any items remaining in the Inbox and/or Sent box will by default still be open complaints, with the initial date of complaint receipt visible.
Acknowledgement of a complaint
Each complaint will be acknowledged at the time that the complaint is received and a case number advised to the complainant at this time.
Commitment to resolution of complaints
Target commits to providing a final response for complaints that it receives within 30 days of receipt of the complaint.
Response to a complaint & communication of decision
Contact will be made to each complainant within 5 working days of receiving the complaint to provide either a reply with a resolution or the current status of the complaint. Refer process flow Annex A ‘Privacy – Complaint Management process’
Monitoring of the complaints handling process
All cases in the Customer Relations system will be reviewed;
For complaints older than 10 working days, perform follow-up action; such as status/progress checking with area the complaint was referred to.
For complaints older than 15 working days, reported and escalate the status/progress check to management of responsible area via the Customer Relations Manager.
For complaints older than 20 days, reported and escalate the status/progress check to the Privacy Compliance Officer via the Customer Relations Manager.
For complaints older than 25 days, reported and escalate the status/progress check to the General Manager of the responsible area via Privacy Compliance Officer.
It is anticipated that NO complaints will be unresolved after 30 working days.