COMPLAINTS POLICY

COMPLAINTS POLICY

COMPLAINTS POLICY

Digital Capital Ltd

Planned-service examples do not mean those services are available.

How to make a complaint

How to make a complaint

Email info@digi-capital.co.uk, use our contact form or write to Digital Capital Ltd, 3rd Floor, 86–90 Paul Street, London, EC2A 4NE, England.

Tell us what happened and how we can contact you. Include relevant dates and any reference you have. Missing documents do not prevent us from logging your complaint. Do not send passwords or one-time codes.

See response times and Financial Ombudsman Service information below.

1. PURPOSE

1. PURPOSE

1.1 This Complaints Policy sets out the framework by which Digital Capital Ltd (“we”, “us”, “our”) receives, investigates, manages and resolves complaints.

1.2 This Policy is designed to ensure:

  • fair and consistent treatment of customers

  • compliance with applicable regulatory requirements, including FCA DISP rules

  • effective identification and remediation of issues

  • continuous improvement of services

2. REGULATORY FRAMEWORK

2. REGULATORY FRAMEWORK

2.1 This Policy is aligned with:

  • FCA Dispute Resolution (DISP) rules

  • Electronic Money Regulations 2011

  • Payment Services Regulations

2.2 Complaints handling is subject to regulatory oversight and audit.

3. SCOPE

3. SCOPE

3.1 This policy covers complaints about Digital Capital's website, enquiries, e-money account, domestic payments, Digital Capital charges and customer service, including the pilot discount, tariff refunds and savings fee cap. You can raise a concern before or after becoming a customer. Digital Capital is currently pre-operational.

3.2 This Policy applies to:

  • individual customers

  • business customers

  • authorised users

3.3 We also accept concerns from prospective customers and people affected by our conduct. Digital Capital is pre-operational; examples of account, payment or savings complaints describe the process for an activated service. Privacy complaints have the separate process in section 45. Initial business-only scope does not exclude an eligible individual representative from raising a concern.

4. DEFINITION OF A COMPLAINT

4. DEFINITION OF A COMPLAINT

4.1 A complaint is any expression of dissatisfaction, whether oral or written, relating to:

  • the provision of a service

  • a failure to provide a service

  • the manner in which a service has been delivered

4.2 You do not need to use the word “complaint”, a particular form or a paid representative. We assess an oral or written expression of dissatisfaction fairly and do not require a request for compensation to recognise it.

5. TYPES OF COMPLAINTS

5. TYPES OF COMPLAINTS

Complaints may include, but are not limited to:

5.1 Payment-related complaints

  • delayed payments

  • failed transactions

  • incorrect execution

5.2 Account-related complaints

  • account access issues

  • restrictions or suspensions

5.3 Pricing and pilot complaints include an incorrect subscription or CHAPS fee, a savings fee above the cap, an omitted pilot discount, a delayed tariff refund or unclear information about the pilot ending.

5.4 Service-related complaints

  • customer support issues

  • communication failures

5.5 Fraud and security complaints

  • suspected fraud

  • unauthorised transactions

6. COMPLAINT VS QUERY CLASSIFICATION

6. COMPLAINT VS QUERY CLASSIFICATION

6.1 A query is a request for clarification or information.

6.2 A complaint involves:

  • dissatisfaction

  • expectation of corrective action

6.3 Where there is doubt, the matter will be treated as a complaint.

7. COMPLAINT IDENTIFICATION

7. COMPLAINT IDENTIFICATION

7.1 Complaints may be received via:

  • email

  • customer support channels

  • Partner platforms

7.2 Staff must:

  • identify complaints accurately

  • escalate appropriately

7.3 Current contact: info@digi-capital.co.uk; by post to Digital Capital Ltd, 3rd Floor, 86–90 Paul Street, London, EC2A 4NE, England; or through the published website contact form. Explain what happened, relevant dates, how to contact you and the outcome sought; provide any available reference or evidence, but missing documents do not prevent logging the complaint. Do not include passwords or one-time codes.

8. COMPLAINT OWNERSHIP

8. COMPLAINT OWNERSHIP

8.1 Each complaint will be assigned an owner responsible for:

  • investigation

  • communication

  • resolution

8.2 Ownership ensures accountability.

9. VULNERABLE CUSTOMERS

9. VULNERABLE CUSTOMERS

9.1 We recognise that some customers may be vulnerable.

9.2 Where vulnerability is identified, we will:

  • adjust communication

  • provide additional support

  • ensure fair treatment

9.3 We offer reasonable adjustments and can work with a verified authorised representative. We aim to record the support needed rather than unnecessary medical information. Vulnerability may arise through health, life events, resilience or capability and can affect a person representing a business.

10. RECORDING OF COMPLAINTS

10. RECORDING OF COMPLAINTS

10.1 All complaints will be recorded.

10.2 Records will include:

  • complaint details

  • date received

  • category

  • actions taken

  • outcome

11. PRIORITISATION

11. PRIORITISATION

11.1 Complaints may be prioritised based on:

  • severity

  • potential financial impact

  • vulnerability of the customer

  • regulatory implications

12. INTERNAL ESCALATION

12. INTERNAL ESCALATION

12.1 Complaints may be escalated internally where:

  • complexity is high

  • risk is significant

  • regulatory concerns arise

12.2 Escalation may involve:

  • compliance function

  • senior management

13. CONFIDENTIALITY

13. CONFIDENTIALITY

13.1 Complaint data will be handled confidentially.

13.2 Access is restricted to authorised personnel.

14. COMPLAINT RECEIPT

14. COMPLAINT RECEIPT

14.1 Complaints may be submitted through:

  • email

  • customer support channels

  • Partner interfaces (where applicable)

14.2 Complaints may be submitted:

  • verbally

  • in writing

14.3 All complaints must be logged upon receipt.

15. ACKNOWLEDGEMENT

15. ACKNOWLEDGEMENT

15.1 We will acknowledge receipt of a complaint promptly.

15.2 Our written acknowledgement confirms receipt and that we are dealing with the complaint, explains the next steps and states the applicable 15/35 Business Day or eight-week timetable. We request only relevant additional information and keep you informed of progress. If different parts follow different timetables, we explain that.

16. INITIAL ASSESSMENT

16. INITIAL ASSESSMENT

16.1 Upon receipt, each complaint will be assessed to determine:

  • category of complaint

  • complexity

  • potential impact

  • urgency

16.2 Complaints may be categorised as:

  • standard

  • complex

  • high-risk

17. INVESTIGATION PROCESS

17. INVESTIGATION PROCESS

17.1 Complaints will be investigated thoroughly and fairly.

17.2 Investigation may include:

  • review of transaction records

  • review of account activity

  • internal system checks

  • communication with relevant teams

  • communication with third parties (where required)

17.3 We may request additional information from the customer.

18. INTERACTION WITH THIRD PARTIES

18. INTERACTION WITH THIRD PARTIES

18.1 Where complaints involve:

  • payment schemes

  • banks

  • merchants

  • Partners we may need to liaise with those parties.

18.2 Third-party involvement does not automatically extend our deadline or transfer our responsibility. We coordinate the investigation and apply only a legally permitted exception to the relevant timetable.

18.3 If your complaint concerns a separate Griffin savings deposit or another provider's service, we will explain which firm is responsible for each part and coordinate or route the relevant information appropriately. We remain responsible for complaints about our own service and charges. Different parts may follow different response timetables; we will explain them and preserve the applicable escalation rights.

19. TIMELINES — FCA REQUIREMENTS

19. TIMELINES — FCA REQUIREMENTS

19.1 We aim to resolve complaints as quickly as possible.

19.2 For an EMD or PSD complaint within the relevant rules, we send a final response by the end of 15 Business Days after the day we receive it. The response is on paper or another agreed durable medium.

19.3 Only in exceptional circumstances, for reasons beyond our control, may we send a holding response by that 15-Business-Day deadline and a final response by the end of 35 Business Days after receipt. Ordinary workload, a complex label or third-party involvement alone does not establish the exception.

19.4 The holding response explains why we cannot yet answer and specifies the final-response deadline. For other complaints governed by the standard DISP timetable, we send by eight weeks either a final response or a written explanation of the delay, when we expect to respond and the applicable right to refer to FOS with its information. The EMD/PSD part of a mixed complaint keeps its shorter timetable.

20. ONGOING COMMUNICATION

20. ONGOING COMMUNICATION

20.1 We will keep you informed where:

  • investigations are ongoing

  • delays occur

20.2 Communication will be clear and transparent.

21. FINAL RESPONSE

21. FINAL RESPONSE

21.1 Our final response will include:

  • a summary of the complaint

  • the outcome of the investigation

  • our decision

  • any corrective action taken

21.2 Where appropriate, we will:

  • provide remediation

  • explain next steps

21.3 A final response accepts the complaint and offers appropriate redress, offers redress without accepting it, or rejects it with reasons. Where the FOS route applies, it includes the required explanatory leaflet or permitted equivalent, website address, referral rights and the applicable time-limit wording, including the normal six-month period from the final response.

22. REMEDIATION

22. REMEDIATION

22.1 Where a complaint is upheld, we may:

  • provide a refund

  • correct an error

  • take operational action

22.2 Remediation will be proportionate to the issue identified.

22.3 We do not delay a statutory unauthorised-payment refund, APP reimbursement or other due remedy while waiting to finish a complaint. Where a problem affects others, we assess wider remediation as well as the individual case.

22.4 We do not require you to make a complaint to receive the automatic savings fee cap or a qualifying pilot tariff refund. Where you request closure of your overall Digital Capital customer account during the pilot project, the qualifying pilot tariff refund, covering base subscriptions, savings account fees and incoming CHAPS charges actually charged, is due within 10 working days of our receipt of that closure request. A complaint does not postpone that deadline or any shorter statutory refund deadline. The full pilot tariff-refund terms are set out in the Fees and Limits Schedule.

23. REJECTION OF COMPLAINTS

23. REJECTION OF COMPLAINTS

23.1 Where a complaint is not upheld, we will:

  • explain the reasons

  • provide supporting information where appropriate

24. FINANCIAL OMBUDSMAN SERVICE (FOS)

24. FINANCIAL OMBUDSMAN SERVICE (FOS)

24.1 Eligible complainants may refer a complaint to the Financial Ombudsman Service if dissatisfied with the final response or if the applicable response deadline has expired. FOS is independent and free to eligible complainants. Website and contact route: https://www.financial-ombudsman.org.uk/consumers/how-to-complain. The FCA supervises firms but does not generally determine individual compensation complaints.

24.2 A referral is normally required within six months of the date of our final response. Other FOS jurisdiction and time-limit rules also apply, including applicable exceptions; our response explains the relevant position and whether any time-limit waiver applies. You may contact FOS directly if uncertain about eligibility or time limits.

25. ELIGIBILITY FOR FOS

25. ELIGIBILITY FOR FOS

25.1 FOS eligibility is determined by its rules and is separate from APP reimbursement eligibility and our product target market. It can include consumers; micro-enterprises with fewer than ten persons and turnover and/or annual balance-sheet total not exceeding €2 million; and qualifying small businesses with annual turnover below £6.5 million and either a balance-sheet total below £5 million or fewer than 50 employees, applying the relevant linked-enterprise and other tests. Other eligible categories can include qualifying charities, trusts and personal guarantors. We will not reject FOS access merely because the customer is a business.

26. COMPLAINTS INVOLVING FRAUD OR PAYMENTS

26. COMPLAINTS INVOLVING FRAUD OR PAYMENTS

26.1 Complaints involving fraud or unauthorised transactions may:

  • require additional investigation

  • involve third parties

26.2 Scheme processes and evidence requests do not override the complaint deadlines. Refund deadlines and any permitted APP stop-clock operate separately and must also be met.

27. RECORD KEEPING

27. RECORD KEEPING

27.1 We maintain detailed records of complaints.

27.2 Records include:

  • complaint details

  • investigation steps

  • communications

  • outcome

27.3 We retain complaint records for at least the applicable DISP period, ordinarily three years from receipt for complaints subject to DISP 1.9, and longer only where another lawful requirement or documented purpose justifies it. The Privacy Notice describes the applicable retention criteria.

28. QUALITY ASSURANCE

28. QUALITY ASSURANCE

28.1 Complaints handling may be subject to:

  • internal review

  • compliance oversight

  • audit

29. REGULATORY REPORTING

29. REGULATORY REPORTING

29.1 We may be required to:

  • report complaint data to regulators

  • provide summaries and statistics

30. TRAINING

30. TRAINING

30.1 Staff handling complaints receive appropriate training.

30.2 Training includes:

  • regulatory requirements

  • customer fairness

  • escalation procedures

30.3 Relevant staff receive induction and at least annual refresher training under the internal policy; new customer-support staff receive the role-specific training required before handling matters without suitable supervision. Training includes recognising complaints, statutory deadlines, vulnerability, redress and escalation.

31. COMPLAINTS GOVERNANCE

31. COMPLAINTS GOVERNANCE

31.1 Complaints handling is subject to governance and oversight.

31.2 Responsibility for complaints management lies with:

  • operational teams (first line)

  • compliance function (second line)

  • senior management oversight

31.3 Complaints handling forms part of the firm’s overall risk management framework.

32. ROLES AND RESPONSIBILITIES

32. ROLES AND RESPONSIBILITIES

32.1 Staff handling complaints are responsible for:

  • accurate classification

  • fair investigation

  • timely communication

32.2 The compliance function is responsible for:

  • oversight of complaints handling

  • regulatory alignment

  • escalation of material issues

32.3 Senior management is responsible for:

  • ensuring adequate resources

  • reviewing complaint trends

  • approving remediation actions

33. ROOT CAUSE ANALYSIS

33. ROOT CAUSE ANALYSIS

33.1 We analyse complaints to identify underlying causes.

33.2 Root cause analysis may include:

  • process failures

  • system issues

  • human error

  • third-party dependencies

33.3 Where root causes are identified, we will:

  • implement corrective actions

  • monitor effectiveness

34. THEMATIC ANALYSIS

34. THEMATIC ANALYSIS

34.1 We review complaints on a thematic basis.

34.2 This includes identifying:

  • recurring issues

  • emerging risks

  • patterns across products or services

35. MANAGEMENT INFORMATION (MI)

35. MANAGEMENT INFORMATION (MI)

35.1 We produce management information on complaints, including:

  • number of complaints

  • categories of complaints

  • resolution times

  • outcomes

35.2 MI is used to:

  • support decision-making

  • identify trends

  • improve services

36. ESCALATION TO SENIOR MANAGEMENT

36. ESCALATION TO SENIOR MANAGEMENT

36.1 Material complaints may be escalated to senior management where:

  • regulatory risk exists

  • financial impact is significant

  • systemic issues are identified

37. CONTINUOUS IMPROVEMENT

37. CONTINUOUS IMPROVEMENT

37.1 We use complaints as a tool to improve:

  • customer experience

  • operational processes

  • product design

37.2 Improvements may include:

  • system enhancements

  • process changes

  • staff training

38. INTERACTION WITH RISK AND COMPLIANCE FUNCTIONS

38. INTERACTION WITH RISK AND COMPLIANCE FUNCTIONS

38.1 Complaints data is integrated into:

  • risk management processes

  • compliance monitoring

38.2 Complaints may trigger:

  • internal reviews

  • audits

  • policy updates

39. THIRD-PARTY AND PARTNER ISSUES

39. THIRD-PARTY AND PARTNER ISSUES

39.1 Where complaints relate to third parties or Partners:

  • we will coordinate investigation

  • responsibility will be assessed

39.2 We remain responsible for regulated services.

40. CUSTOMER FAIRNESS

40. CUSTOMER FAIRNESS

40.1 We aim to treat customers fairly at all times.

40.2 This includes:

  • clear communication

  • fair outcomes

  • proportionate decisions

41. VULNERABLE CUSTOMERS (ENHANCED)

41. VULNERABLE CUSTOMERS (ENHANCED)

41.1 Additional care will be taken where customers are identified as vulnerable.

41.2 Measures may include:

  • adapted communication

  • additional support

  • flexible handling

42. RECORDING AND AUDIT TRAIL

42. RECORDING AND AUDIT TRAIL

42.1 We maintain an audit trail for each complaint.

42.2 This includes:

  • actions taken

  • decisions made

  • communications

43. INTERNAL AUDIT AND REVIEW

43. INTERNAL AUDIT AND REVIEW

43.1 Complaints handling may be subject to:

  • internal audit

  • compliance reviews

43.2 Findings may result in:

  • remediation actions

  • policy updates

44. REGULATORY EXPECTATIONS

44. REGULATORY EXPECTATIONS

44.1 We align our complaints handling with:

  • FCA expectations

  • applicable laws and regulations

44.2 We may update this Policy to reflect changes.

45. POLICY REVIEW

45. POLICY REVIEW

45.1 This Policy is reviewed periodically.

45.2 Updates may reflect:

  • regulatory changes

  • operational developments

  • identified risks

45.3 A data protection complaint can be submitted by email, post or the website contact form. We acknowledge it within 30 days, investigate and keep you informed without undue delay, and communicate the outcome without undue delay. You may complain to the ICO at https://ico.org.uk/make-a-complaint/. This is distinct from a data-subject rights request, normally answered within one month, and from financial complaints subject to the 15/35 Business Day or eight-week rules.