Customer or business makes a complaint or provides feedback about Centrepay 103-09030080

A Service Officer may become aware of a complaint during discussions with a customer.

Does the customer want to record a complaint?

• Yes, go to Step 3
• No, go to Step 2

Note: If you have concerns or the customer discloses they are experiencing vulnerable circumstances, see Identifying customer vulnerability and risk issues.

If the Service Officer determines the complaint should be recorded and there is sufficient information to investigate:

• record anonymous feedback in the Customer Feedback Tool (CFT)
• for assistance with coding and management, refer to Recording complaints and feedback in the Customer Feedback tool and the Complaints and feedback index – Centrepay
• if the complaint issue is a potential systemic issue, see Level 1 – Manage complaints and feedback

The Service Officer must:

• record the complaint in the CFT
• discuss the importance of providing their express consent so their details and concerns can be raised directly with the business
• confirm and document their express consent in the CFT, including the date consent was obtained

For help recording and managing the Centrepay complaint:

• follow Recording complaints and feedback in the Customer Feedback Tool and the Complaints and feedback index - Centrepay
• see Resources for FAQs about Centrepay complaints or feedback
• for potential systemic issues see Table 7 in Level 1 – Manage complaints and feedback

Within 2 business days, open the complaint in the Customer Feedback Tool (CFT). Note: staff must have access to the Customer Feedback Tool.

• For complaints received by email, select the Feedback ID link in the email
• For complaints allocated through Workload Manager, select the work item

For Level 1 complaints only, not managed by Personalised Services:

The receiving Centrepay Complaints Officer must take ownership the complaint.

Update the CFT:

• select the Parties involved tab and update Employee responsible
• select the Notes tab and record receipt of the email and to confirm Centrepay Complaints team will action the investigation
• select the Details tab and update the feedback status to Investigation in progress
• add an on hold expiry date for expected timeframe

Note: Staff must update the notes in the CFT as the complaint progresses, or earlier where required. If a complaint escalation reason is met as the complaint progresses, escalate to Level 2.

For all complaints including Level 1, Level 2 or managed by Personalised Services

• update complaints register which is stored locally with complaint details
• if the complaint is about a Centrepay business create a DOC on the business record with the following details. Make sure no personal details of the customer are included:
• Heading: Centrepay Complaint
• Feedback ID number
• Details of complaint (for example – fee passing)

If the complaint is about a Centrepay business, confirm if the complainant has given consent to disclose their personal details to the business.

Has the complainant given consent to disclose their personal details to the business?

• Yes, Centrepay Complaints may conduct an assurance check by investigating the complaint with the business, on complainant’s behalf. Go to Step 4
• No, if complaint is:
• anonymous or the customer does not provide consent to contact the business on their behalf, go to Step 2
• from a customer and their consent to contact the business has not been documented in the CFT, go to Step 3

If complainant has not provided consent to disclose personal details to the business, their details are to remain anonymous.

If there are any compliance concerns raised in the complaint, send an email to Centrepay Compliance and include:

• Complaint Feedback ID
• Details of the complaint and compliance concerns identified
• Note customer consent has not been provided
• Actions required

Note: If customer details are available and if further information is required, contact the customer to confirm complaint will be actioned anonymously and then finalise the complaint. See Level 1 - Manage complaints and feedback.

Procedure ends here.

If the complaint is about a Centrepay business and customer consent is not identified within the CFT, contact the customer. Advise of the importance of providing their express consent so their details and concerns can be raised directly with the business.

If the complaint is Level 2 or managed by personalised services, contact the employee responsible to contact the customer to discuss their consent.

When contacting the customer, send a pre-call SMS if registered for this service and make 3 genuine attempts to contact the customer. Authenticate the customer and establish Proof of Record Ownership (PoRo) See Authenticating a Centrelink customer.

If contact is:

• successful and consent is provided, record consent in the CFT. Go to Step 4
• successful and consent is not provided, go to Step 2
• unsuccessful:
• Level 1 complaints - follow process for unsuccessful contact in Level 1 - Manage complaints and feedback
• Level 2 complaints – respond to the employee responsible for the management of the complaint. Advise details of the unsuccessful contacts. Centrepay complaints require consent to be documented in the CFT to directly investigate the complaint
• Procedure ends here

Registered Centrepay businesses must comply with the Centrepay Policy and Terms and the Centrepay Procedural Guide for businesses. See Resources for a link.

Review the feedback to determine the complaint issue. Refer to Resources for frequently asked questions and answers about issues that may lead to a complaint about Centrepay.

Investigate the complaint and address any program management issues. See References page for a link to the Centrepay Framework documents.

Review:

• all supporting documents
• the customer record and any related deductions. If a deduction is still in place, discuss this with the customer or nominee. If the customer wants to cancel the deductions, support the customer to cancel using:
• self service
• payment line, or
• book and appointment at a service centre
• the business record

Use the below steps to investigate both the customer and business record:

• Check the Customer Feedback Tool and the Document List (DL) screen for any previous complaints the customer may have made about the business or any other information relating to the complaint
• Update the notes in the complaint record as the complaint progresses. Only add details relating to outcomes for the customer on the customer’s record. Do not include any investigation and findings against the business
• Upload supporting documents to the customer record. See Attaching electronic documents to a Centrelink customer's record using Document Tools in Customer First Note: do not upload any documents relating to other customers
• Go to the Payment Instruction Summary (PINS) screen and Payment Instruction History (PIHS) screen to investigate the complaint and determine:
• if the customer has a current deduction with the business
• if there appears to be any consent concerns. This is indicated by the business continually restarting the deduction after the customer has cancelled it
• any other relevant information to investigate the complaint

• Check the Document List (DL) screen and use the search function in Workspace to view Customer Feedback History for any previous complaints and the outcomes
• Check the Contract/Agreement summary page on !TPOCAS screen and the M3RV screen to view a history of the business’s assurance/compliance outcomes
• Check the Direct Deduction Record Selection (DDRS) screen to investigate customer deductions received by the business. To do this, on the DDRS screen:
• Code ‘C’ in the Deduction type field
• Code ‘DC’ in the Delivery Method field
• Enter customer CRN in the Customer CRN field
• Press [Enter], the Direct Deduction Summary (DDS) screen will show

If more information is required from the customer, go to Step 5.

If sufficient information has been provided to start an investigation, go to Step 6.

Where further information or contact is required with the customer

Send a pre-call SMS if registered for this service and make 3 genuine attempts to contact the customer.

If contact is:

• successful
• Authenticate the customer and establish Proof of Record Ownership (PoRo). See Authenticating a Centrelink customer
• Request required information from customer and discuss timeframes for the management of the feedback. Add relevant notes to the CFT following contact. When sufficient information has been received go to Step 6
• unsuccessful
• Level 1 complaints – Continue investigation if appropriate and contact business if consent has been provided. If further information is required and is unable to be obtained, or if consent cannot be established, follow the process for unsuccessful contact in Level 1 - Manage complaints and feedback. This may include an email or letter being issued to the customer requesting contact. Procedure ends here
• Level 2 complaints – respond to the employee responsible for the management of the complaint and advise further information is required from the customer to conduct Centrepay a complaint investigation. If the employee responsible for the complaint obtains and provides the required information, go to Step 6

If a customer has provided their express consent to contact the business on their behalf, Centrepay Complaints team must attempt to call the business within 2 business days to discuss the complaint.

Go to the Organisation Contact Summary (OSCS) screen to obtain contact details for the business’s Authorised Officer (AO).

Successful contact

Request the business to provide more information within a specified time frame, for example:

• proof of consent
• proof that the business is not passing on (or attempting to recover) the Centrepay transaction fee
• any other information or action as directed

Email a Centrepay Complaints Request for Information (RFI) letter asking the business to provide the relevant information discussed.

Upload this RFI letter to the business record on Document Tools and annotate the Centrepay Complaint DOC on the business Document List (DL). See Attaching electronic documents to a Centrelink customer's record using Document Tools in Customer First.

Unsuccessful contact

Send a Centrepay Complaints Request for Information (RFI) letter to all the business’s recorded AO by email asking the business to provide the relevant information to manage the complaint, for example:

• proof of consent
• proof that the business is not passing on (or attempting to recover) the Centrepay transaction fee or reimburse the customer
• any other information or action as directed
• upload this RFI letter to the business record on Document Tools and annotate the Centrepay Complaint DOC on the business DL. See Attaching electronic documents to a Centrelink customer's record using Document Tools in Customer First

Note: a business must make documents or records available to the Agency within the timeframes directed by the Agency, as per Centrepay Policy, terms and guides. See References.

A satisfactory response would include where the business has provided all requested information and taken all appropriate actions as directed by the agency.

Has the business provided a satisfactory response?

• Yes,
• If an overpayment has been identified, go to Step 11
• If there is no identified overpayment, go to Step 9
• No,
• Issue the business a Centrepay RFI Fail to respond letter by email to all AOs recorded on the business record
• Upload the letter to the business record on Document Tools and annotate the Centrepay Complaint DOC on the business DL. See Attaching electronic documents to a Centrelink customer's record using Document Tools in Customer First
• When the business responds or specified timeframe advised in the letter ends, go to Step 8

Has the business responded to the Centrepay RFI Fail to respond letter within the specified time frame?

• Yes, and the business has provided a satisfactory response
• If an overpayment has been identified, go to Step 11
• If there is no identified overpayment, go to Step 9
• Yes, and the business has not provided a satisfactory response, go to Step 10
• No, go to Step 10

If the complaint can be resolved and there are no compliance concerns, go to Step 12

If the complaint cannot be resolved and/or there are compliance concerns, does the matter meet an escalation reason and warrant escalation to Level 2?

• Yes, follow - Level 1 - Manage complaints and feedback. Make sure the CFT includes reason for escalation and detailed information about the investigation. Procedure ends here
• No, go to Step 10

Have compliance concerns been identified or did the complaint raise regulatory concerns?

• Yes, action a General Activity Review (GND) on the business record noting any issues found. See Actioning a review for Third Party Organisations (TPO). Send an additional referral email to Centrepay Compliance team. Include:
• Complaint Feedback ID
• Details of the complaint and compliance concerns identified
• Identify if customer consent has been provided
• Actions required
• Resolution required
• Go to Step 12
• No, go to Step 12

If an overpayment has been identified, contact the business AO to discuss the overpayment and the requirement for the funds to be returned to the customer.

Issue a Centrepay overpayment recovery letter to the business by email. Upload this letter to the business record on Document Tools and annotate the Centrepay Complaint DOC on the business Document List (DL). See Attaching electronic documents to a Centrelink customer's record using Document Tools in Customer First.

Has the business returned the overpaid funds to the customer, and the customer has confirmed receipt of these funds?

• Yes, go to Step 9
• No, if the business is refusing to return the funds to the customer or contact between the customer and business is not available, the agency may assist with returning the funds to the customer. See Centrepay overpayment recovery
• Send the internal referral template to Centrepay Recoveries advising of action required
• Once advised by Centrepay Recoveries the funds have been returned contact the customer to confirm receipt. Code a GND on the M3RV screen on the business record for all instances where an overpayment has been identified or funds were taken without the customer’s consent. See Actioning a review for Third Party Organisations (TPO)
• Go to Step 12

Customer complaints are considered closed when the customer’s issue has been resolved. The complaint does not need to remain open while compliance issues are resolved with the business.

Do not record business compliance outcomes in the CFT. Record this information on the business record.

The employee responsible for the complaint will finalise the complaint with the customer and within the CFT.

Centrepay Complaints staff:

• Record details of the outcome in the Customer Feedback Register, which is stored locally
• Update notes to the complaint record in the CFT. Notes must be clear. The outcome that has been provided to the customer must be recorded. See Managing complaints and feedback for documenting customer feedback standards
• Annotate Centrepay complaint DOC on the business Document List (DL) screen, confirming finalisation of complaint. Do not disclose any personal information of the customer
• If relevant, email a Centrepay complaint outcome notice to the business AO. Upload this letter to the business record on document tools and annotate the Centrepay Complaint DOC on the business Document List (DL). See Attaching electronic documents to a Centrelink customer's record using Document Tools in Customer First
• Level 1 complaints - finalise the CFT entry, see Level 1 – Manage complaints and feedback
• Level 2 complaints – respond to the employee responsible for the management of the complaint and provide outcome details of the investigation undertaken by Centrepay complaints

Note: If the customer asks for a written response, see Level 1 - Manage complaints and feedback.

Centrepay complaints can be received directly from:

• stakeholders
• advocacy groups
• peak bodies

External stakeholders use email to lodge Centrepay complaints on behalf of customers. Each complaint must be recorded in the Customer Feedback Tool (CFT).

The complaint must include at least one of the following documents:

• The letter of complaint to the agency, including what outcome the customer wants
• The letter of complaint to the business, and any other correspondence or evidence to remedy the complaint (if the complaint relates to a Centrepay business)
• A statement confirming the customer’s consent to act on their behalf and disclose personal information to the business, signed by the customer
• Any further documents referenced in the complaint, such as, ledgers, lease agreements or fee schedules
• An Authorising a person or organisation to enquire or act on your behalf (SS313) form signed by the customer

See Nominees ,Disclosing information to third parties and Implied consent regarding third parties.

Is the external stakeholder authorised to represent the customer?

• Yes, record the complaint in the CFT on the customer’s record. If authority is obtained through implied consent, include details, see Table 1, Step 5 in Implied consent regarding third parties. Go to Step 2
• No, Do not access the customer’s record
• contact the external stakeholder by phone or email to explain the agency is unable to provide any details about the customer's situation
• encourage the third party to help the customer contact the agency to discuss their issues
• inform the third party of the process to gain authority to enquire on the customer's behalf

When the CFT entry is linked to:

• a customer record, documents can be uploaded using the Document Attachment tab
• an organisation record, documents cannot be attached to the CFT entry. Documents can only be uploaded via the Document Tools function in Workspace

Note: if the feedback is anonymous, documents cannot be linked to the CFT entry.

The Centrepay Complaints team must respond to the complainant, acknowledging the receipt of the complaint within 2 business days and request more information if needed.

If the complaint indicates a referral to a social worker or Financial Information Service (FIS) may be required, offer to refer the customer.

See Table 2.