Terms and Conditions
Affordable Cars Group Treating Customers Fairly Policy Statement
TREATING CUSTOMERS FAIRLY POLICY STATEMENT 2018 -- 2019
The Board of Affordable Cars Group (\"the Company\") has adopted this policy, reflecting how, in the context of its motor retail business it intends, to operate to the \"Treating Customers Fairly\" (TCF) principle in the mediation of sales of general insurance products, together with acting as a credit broker/intermediary.
The Company believes that the fair treatment of customers is essential to the success of its business. Customers are a key stakeholder in the Company\'s motor retail businesses, both directly and because of the influence, the quality of the customer experience has on the businesses\' relationships with other crucial stakeholders, principally providers of consumer credit and suppliers of general insurance products.
This policy is adopted for the purposes of general insurance mediation and credit broker/intermediary activities, and all references to \"products\" are to general insurance and consumer credit products, and to \"customers\" are to customers for general insurance and consumer credit products.
The Company recognises that the customer\'s demand for or need of a general insurance or consumer credit product is ancillary to their requirement for a motor vehicle. Each customer for a vehicle is potentially a customer for a general insurance or consumer credit product.
Accordingly, the process for the selection, marketing, sales and advice, aftersales service and complaint handling for general insurance and consumer credit products is inextricably linked with the sale or supply of a high-value item (a motor vehicle) which represents a considerable investment for most customers.
The fair treatment of the customers is therefore required to be embedded in the whole process and reflected in all the behaviours of the Company\'s team members.
VALUES AND TCF POLICY STATEMENT
To ensure they are memorable and easily understood by our team members and stakeholders, our core values and TCF policy are encapsulated in brief statements.
The Company has adopted core values reflecting its relationship with each of its five key stakeholders. Its core value for customers is:
\"We provide a good value, personalised service to existing and potential customers.\"
Treating customers fairly is an inherent requirement for the fulfilment of this core value.
The Company\'s processes, policies and behaviours will ensure that customers are treated fairly at each stage of our relationship with them.
The Company selects and retains only those independent suppliers of general insurance and consumer credit products and associated services who are able to demonstrate their respect and fulfilment of TCF principles for those aspects of the customer relationship for which they are responsible. Similar standards are expected of the suppliers of general insurance and consumer credit associated with the new vehicle franchises the Company\'s businesses hold.
The Company\'s core value for suppliers is: \"We provide long term, profitable partnerships in return for quality service and competitive pricing\".
Our core values and TCF policy is included in the induction and training of all team members.
Our TCF policy is available on our internal intranet and external website and made available in hard copy upon request.
PRODUCT DESIGN, GOVERNANCE AND MARKETING
We do not supply general insurance or consumer credit independently from the supply of a motor vehicle.
We require our product suppliers to provide us with information about the outcome of our sales to inform our decisions on our product portfolio and our assessment of the fair treatment of our customers.
As mediators and brokers of products designed by third-party suppliers, our concern is to ensure that our product portfolio meets the following requirements:
- The supplier is of adequate financial standing and will enable us to fulfil our core values
- The products are suitable for our potential customers, as purchasers of new and used motor vehicles
We regularly review product features, their terms and conditions and all customer feedback and engage with product suppliers to redress imbalances against customer expectations.
SALES AND ADVICE PROCESSES AND AFTERSALES CARE
We mediate insurance and consumer credit products from multiple retail locations to customers for motor vehicles who potentially will have contact with a variety of our team members. Our concern is to ensure that our customers\' experience meets the following requirements:
- Whether for general insurance, consumer credit or other products or services, only appropriately trained competent team members to deal with the customer;
- team members receive the appropriate knowledge and skills training and support to provide a service which treats customers fairly, protects against risks of mis-selling and poor customer outcomes, and ensures the suitability of advice given;
- where practicable, our information systems incorporate means of assurance of the fair treatment of customers and the control of the risks of mis-selling and of poor outcomes for customers;
- we regularly review the effectiveness of our sales and advice systems and processes in achieving the fair treatment of customers;
- we use our management information to identify behaviours which put customers at risk of poor outcomes or mis-selling or otherwise fall short of our expectations and to inform corrective training;
- we design our remuneration system for team members involved in mediating insurance and consumer credit so as to minimise the potential for customer\'s transactions being influenced by bias or other mis-selling risks.
We identify potential conflicts of interest within our sales process and ensure that individual and business objectives are linked not only to sales performance but also to sales process quality, TCF and regulatory compliance.
We acknowledge that conflicts of interest may arise either: (a) between our interests as a business and those of customers; or (b) between the personal interests of our team member and those of the customer; either because of a relationship, or a financial incentive or inducement we offer or which is offered by any third party. Such conflicts may have the potential to influence our interaction with a customer or our advice to a customer on the most appropriate general insurance or consumer credit product or service for them, according to their circumstances as they have explained them to us. Where such a potential or actual conflict arises, we will operate processes which are designed to eliminate the risk of detriment to the customer. Any team member found not to be operating to those processes will be subject to disciplinary procedures, which could lead to a variety of outcomes, including the dismissal of the team member. The decision whether or not to commence such procedures and the conduct of disciplinary procedures shall in each case be by leaders who do not have a direct financial or other interest in the outcome of any such procedures. Whilst aftersales care is delivered by our selected providers, we satisfy ourselves of their financial standing, ability to meet the obligations inherent in their products and to provide aftersales care, and other relevant capabilities, in our provider selection process and require them to provide us management information concerning their performance to a prescribed standard. We utilise such management information and our own management information to identify and respond to aftersales performance matters.
We provide customers with easy access to team members, both those who made the sale and ones unconnected with the sale, to receive, record, investigate and respond to complaints.
We allocate clear responsibilities to team members for:
- investigation of a complaint; and
- resolution of a complaint; and
- communication with the customer at appropriate stages.
We give clear explanations of our complaints handling process and of conclusions reached at the end of our process.
We keep the customer informed in a timely manner of the progress and status of their complaint.
We advocate on behalf of customers with any supplier which responds unreasonably to a legitimate claim or complaint.
We use identified trends in complaints received to inform our product and supplier selection.
MANAGEMENT SUPPORT FOR TCF
- Prescribes and oversees a risk management process and methodology for the identification of risks and the design and documenting of effective mitigating controls;
- Prescribes management information disciplines which allow regular score-keeping against our TCF and sales process quality objectives;
- Regularly reviews the management information needs of the Company so as to ensure that MI produced is relevant to the risks and controls in the Company\'s sales environment and permits effective review of sales practices and their associated audit test results;
- Ensures business leader\'s and team member\'s role responsibilities clearly set out their TCF and regulatory compliance objectives;
- Ensures there is available to all relevant team members training and coaching which equips them to understand their responsibilities;
- Regularly reviews and moderates remuneration schemes and attendant performance objectives to ensure consistency with the business\'s TCF approach;
- Ensures that the Company rigorously promotes our customer core value, among our five core values, in all available training interfaces with our team members, to embed a culture of Treating Customers Fairly;
- Ensures that our incentive schemes reward and recognise excellence in providing a quality sales experience to the customer, embracing the fair treatment of customers.
- To exchange information for warranty/ aftersales to the relevant manufacturer of your vehicle.
- The purchase of a vehicle
- Where it is in your Vital Interest;
- If we provide you with one of our life shine paint protection products your details of application will be sent to a third party to register the guarantee against the vehicle.
- To ensure that the data we hold remains up to date our databases we regularly cleanse our database via Experian. If we are notified that you are no longer the registered owner of the vehicle we once attributed to you, the vehicle will be detached from your records.
- Registering for offers via our website; or
- Visiting one of our dealerships / contacting us via telephone
- Where you believe it is unlawful for us to do so.
- You have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
Affordable Cars Group Privacy Notice
Maintaining the security of your data and ensuring that you are in control of how your data is handled is a priority at Affordable Cars Group. We are dedicated to ensuring that we are transparent about the data that we collect about you, how we use it and the conditions whereby we may disclose your data to others. We will ensure that your data is kept secure and that you are aware of the steps we have taken to ensure the security of your private information.
Affordable Cars Group takes the security of your data very seriously and strictly adheres to guidelines published in the United Kingdom Data Protection Act 2018 and the General Data Protection Regulation 2016/679 which is applicable from 25th May 2018. Any questions relating to this notice and our privacy practices should be sent to A19sales@affordable-cars.co.uk
Personal data we collect
We will only collect relevant data to enable us to carry out the service you have requested or accessed, below we have set out in more detail about the personal data we collect and why we collect it. We review our retention periods regularly and will only hold data as it is necessary for the original purpose it was collected for, as required by law or as set out in any relevant contract we have with you.
To make an online vehicle service or MOT booking we require your name, contact information and vehicle details. This information is required so that we can arrange your booking.
If you have purchased a vehicle from Affordable Cars or you have previously had a service with us our aftersales system will have stored your information, along with your service and MOT due date. These details will be removed after 24 months if no further contact is made or if you request it.
When you search for a used vehicle on our website we may store information on the vehicles you searched for and viewed in a cookie so that we can provide personalised content, and suggest other vehicles you may also be interested in.
If you enquire about one of our vehicles we require your name, email address and contact telephone number to able us to respond to your enquiry. We will continue to discuss your enquiry with you for up to 6 months after your initial enquiry or if applicable, the new vehicle you enquired about becomes available (whichever is greater).
Test Drive or Courtesy Car
If you book a test drive or take a courtesy car from our service department we require a copy of your driving licence, we will store a copy of this in case of any speeding, parking or other motoring offences that may occur.
Sell your car
If you request a valuation for your current vehicle we require your vehicle details including registration number, mileage, plus your name, email address and telephone number so that we can send you your indicative valuation. If you decided not to proceed with your valuation we will delete your details after 6 months of your valuation.
If you decide to purchase a vehicle from Affordable Cars Group, at the point of sale under a Contractual Obligation we will collect your full name, address, contact number, date of birth, driving licence details, payment details, details of the vehicle you are buying and, if applicable, details of the vehicle you will be using as a part exchange. Your details will not be used for marketing purposes unless you provide consent for us to do so.
If you require finance for your vehicle purchase, we will require additional information including marital and housing status, number of dependents, previous address, occupation, employer, business address and bank details, in addition, we may also require proof of address (i.e. utility bill) and any other relevant information. With your permission, this information will be passed to our selected finance partners. Your personal information will be stored within your deal file which will be stored for 7 years. At the end of your finance agreement, we will contact you to discuss your end of finance arrangements and where applicable arrange the required arrangements to fulfil the contract -- for example, end of finance term vehicle return and appraisal.
We operate CCTV in all of our dealerships to monitor our premises, therefore your image and vehicle registration may be captured and stored for up to 30 days.
If you enter one of our competitions, we require your name, email address and telephone number so that we can contact the winner. Competitions are subject to terms and conditions.
Contact by phone
Should you call our dealerships or should we contact you in response to an enquiry, your phone call may be recorded and will be retained for a maximum of 3 months. The recording will be used for quality and training purposes only.
How we may use your personal data
Where you have provided consent;
Affordable Cars Group uses your personal data for electronic marketing purposes and we may contact you to update you in accordance with your selected marketing preferences.
You have the right to opt out of receiving promotional communication at any time by contacting the dealership.
We may need to process your data to manage your queries, complaints, or claims and may result in us contacting you by the contact details you have previously provided.
Where required to perform a Contract with you;
We may use and process your personal data where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes;
We may use your personal information to contact you if there are urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information may prevent or reduce any potential harm to you.
Where required to comply with our Legal Obligation;
We will use your personal data to comply with our Legal Obligation including: (i) to assist HMRC, the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data that we hold about you.
Sharing Data with third parties
In order to make certain services available to you, we may disclose your personal information to third parties. We will only disclose the minimum amount of personal data in order to provide the service. We have data sharing agreements in place with each of our third-party suppliers and have completed the necessary security checks to ensure that your data is kept safe once it is passed to them. Our third-party suppliers only have the rights to use your data for the purpose of fulfilling the service required of them, they do not have marketing rights over your data unless you have specifically expressed third-party consent. Your data will be shared with third parties under the following circumstances;
When you provide us with your personal data we may ask you to set your marketing preferences with us so that you can choose (if any) the information you\'d like to hear more about as set out in the \'When Consent is required\' section. This may be done by;
From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for your information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request.
Accessing your personal information
You have the right to ask for a copy of the information we hold about you by emailing or writing to us at the end of this notice. This will be provided in a readable format (CSV) free of charge. We may not provide you with a copy of your information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold about you is inaccurate or out of date, please let us know by contacting us via the details at the end of this notice.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under \'How we use your personal data\' section, you may withdraw your consent at any time by contacting us using the details at the end of this notice. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do this by selecting the \'amend my preferences\' link located at the bottom of our emails. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal data to be removed from our systems by emailing or writing to us at the address at the end of this notice. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal data in the following situations;
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company in connection with legal proceedings.
Transferring your personal information;
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under section \'How we use your personal data\' you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a CSV file.
We may not provide you / transfer you a copy of your data if this concerns other individuals or we have another lawful reason to withhold that information.
Complaining to the UK data protection regulator;
You have the right to complain to the Information Commissioners Officer (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO website for further details.
How to contact us
Please contact us if you have any questions about our privacy notice or information we hold about you:
By email: email@example.com
Or write to us at:
CUSTOMER COMPLAINTS POLICY 2018 -- 2019
Affordable Cars Group believes that having a well-managed mechanism for handling external complaints can improve the quality of its work, enhance the trust and confidence, identify areas of work that need to be improved, Adhere to a quick resolution to any complaint received no matter how small and ensure that Affordable Cars Group learns from the feedback provided through this process. Affordable Cars Group, therefore, welcomes feedback and will react constructively to complaints from the people it works with: Staff, Customers, the general public.
This policy applies to the following people:
- Affordable Cars Group staff members, customers, and management
- Partner organizations: Finance companies, Paint protection, smart repairer\'s
- Affordable Cars Group Board of Directors
For the purpose of this Policy, Affordable Cars Group defines a complaint as: \"an external grievance made against Affordable Cars Group or against one or more of its employees, consultants, suppliers, partners or anyone else acting on its behalf, where the organization has allegedly failed to meet a requirement.
WHAT COMPLAINTS ARE CONSIDERED
Affordable Cars Group will receive and respond to all complaints irrespective of who makes them or the nature or subject of the complaint. Some complaints are of a more minor nature, can be more easily and promptly resolved and pose minimal risk to Affordable Cars Group. Minor complaints that are readily resolved will not follow all the procedures outlined in the Complaints Handling Procedures of this Policy as to do so would be unnecessarily cumbersome, bureaucratic and compromise their timely resolution. More minor complaints might include a telephone complaint that can be responded to in an initial call, a written complaint that proceeds on the basis of a misconception that can readily be corrected.
Complaints of a more complex and significant nature that require acknowledgement, initial assessment and investigation and may require remedial action (e.g. a change to the way in which we operate, train, counsel or discipline staff or even the involvement of regulatory/enforcement authorities) will be undertaken in line with the Complaints Handling Procedures of this Policy.
Serious complaints -- those that pose significant operational, safety, financial or reputational risk to Affordable Cars Group -- will be immediately escalated to the General Manager, depending on the seriousness of the complaint, to the Executive Director, If it is established that a complaint has been made maliciously, in bad faith or without serious intent then a response will be made to the complainant explaining why their complaint is not being taken further.
All complaints no matter how minor will be recorded on a complaints log that will be kept in a secure format.
The following principles will guide Affordable Cars Group in the handling of complaints and ensure that we comply with the standards relating to complaints handling as follows:
- We recognise the importance and value of listening and responding to concerns and complaints.
- The feedback and complaints handling process is as effective, safe, confidential and accessible to all parties, irrespective of their gender, status or background and without prejudice to their future participation
- Visibility: Information about the process for making a complaint will be clear and well documented
- Accessibility: The complaints handling process is easily accessible to all parties involved. There is readily accessible information about the process of making and resolving complaints in a range of formats so that no complainants are disadvantaged. Affordable Cars Group will ensure that flexibility is provided to complainants to ring, write and e-mail complaints and/or to raise concerns in person.
- Objectivity: All complaints are addressed in a fair and equitable, objective and unbiased manner throughout the complaints handling process. Issues of conflict of interest will be identified to ensure objectivity.
- Confidentiality: Confidentiality relating to the complaint will be safeguarded so far as reasonably practicable including the person(s) to whom the complaint is addressed.
- People-centred approach: Affordable Cars Group has a people-centred approach and actively welcomes feedback including complaints and has a commitment to acting to resolve all complaints
- Responsiveness: All complaints and constructive feedback will be taken seriously and handled as swiftly as practicable. All complainants will be treated courteously and kept updated on the progress of their complaint through the complaints-handling process.
- Accountability: Accountability for handling complaints and reporting on the actions and decisions of Affordable Cars Group with respect to complaints handling will be clearly established. All complaints will be recorded through one central point before action is taken. Complaints will be addressed as locally as possible using the agreed complaints procedure and only escalated to management if they are of a serious nature.
- Continuous improvement: Affordable Cars Group is committed to the continual improvement of the complaints handling process and the quality of Affordable Cars Group\'s work. This commitment is practically supported by: the collection and classification of complaints trends; analysis and reporting of complaints trends; monitoring of complaints handling processes; and auditing/management reviews of the complaints handling process and refining of complaints handling in light of those reviews.
- All complaints will be acknowledged as soon as possible, and ideally within five working days by the recipient.
- All complainants will receive a response giving the outcome of their complaint as soon as possible and ideally within thirty working days of receipt. If the matter is more complex a further acknowledgement will be sent explaining what further investigation is required to resolve the complaint and the likely timeframe
- All complaints should be recorded on a Complaints Record Form
- All complainants will be treated respectfully, whether it is felt the complaint is justified or not
- Any complaints about any aspect of Affordable Cars Group and its work should be sent to the e-mail address: firstname.lastname@example.org
- Complaints about a warranty product aspects can be registered by calling Crystal Clear Warranty team on 01522 513833
- Postal complaints can also be sent to Affordable Cars Group, A19 Crockey Hill, York, YO194SH
- corrective action which has been taken;
- timeline for implementation; and investigation
- the person/role addressing the issue. Wherever possible Affordable Cars Group will invite the complainant to outline suggestions for actions the organisation can take to ensure similar complaints do not arise in future.
- if the complaint is about a matter at management level then the complainant may appeal to the company director;
- if the complaint is about a finance agreement, then the complainant may appeal to the finance company directly or contact the financial ombudsman;
- if the complaint is about the quality or fit for purpose of a vehicle the customer has the right to contact citizens advice for more information or have an independent inspection carried out;
- if the complainant continues to be dissatisfied with the outcome, after all avenues have been explored to resolve the complaint, a letter will be sent to the complainant explaining the steps/actions that have been taken, outlining any changes that have been put in place as a result of the complaint and bringing the matter to a close.
Affordable Cars Groups handling of complaints will meet the following minimum standards:
All Affordable Cars Group Staff are aware that Affordable Cars Group welcomes complaints and constructive feedback and need to know how to raise a complaint with the organisation.
Affordable Cars Groups Complaints Handling Policy, specifically highlighting the following central points for all complaints.
Recieving Written and verbal complaints
The complainant must be treated with respect at all times. It is important that the person receiving a complaint face to-face clarifies the issues underlying the complaint, listens to what the complainant has to say and makes a brief and accurate written summary of the complaint. Where necessary, language interpreters may be required to help establish the nature of the complaint. If the complaint is in writing it might be appropriate to write or speak to the complainant to clarify the facts of the case.
Complainants, who are not anonymous, will receive an acknowledgement of their complaint to confirm that it has been received and an outline of the next steps.
All complaints, whether verbal or written, are recorded on the company Complaints Record Form. Each complaint will also be recorded on the complaints log which will form the basis for review at the end of each year. All complaints will be recorded and logged. These records will be used to ensure complaints are dealt with efficiently and effectively and to monitor any trends. It will provide information on the number and types of complaints Affordable Cars Grup is recieving.
RESPONDING TO THE COMPLAINANT
Complainants, who are not anonymous, will receive a response outlining the outcome of the complaint or, if it is a complex matter, when it will be investigated further and how long it is likely to take. Affordable Cars Group will let the complainant know the outcome which may include:
If a complainant is unhappy about the response received from Affordable Cars Group or if they believe the corrective action has not been adequately implemented they may appeal to the next level. For example:
RIGHT TO RETURN GOODS
Refunds within the first 30 days of ownership are subject to you, the customer, demonstrating the serious fault existed on the car when you purchased it.
Once the refund is agreed you agree to return the car to Affordable Cars Group. Refunds will be paid within 14 days of the vehicles. If there was a part exchange, and this car is still available, Affordable Cars Group, reserve the right to return the car as part of the refund, at the part exchange value, less any costs incurred on the car (paintwork, service work etc).
Where a customer had negative equity, it will be their responsibility to repay the amount to Affordable Cars Group, once the car has been returned. Any finance agreement will be cleared once the car is returned. Affordable Cars Group, once the car has been returned. Any finance agreement will be cleared once the car is returned.
Where a customer chooses a replacement car, they may swap \"like for like\" on price, or adjust any difference on screen price. Finance can be rearranged on the exchange car, on the same terms.
A customer can only have one exchange
Where a viable repair is preferred, we will be happy to do this. If a repair is uneconomical we reserve the right to offer an exchange or full refund.
Service items required are not considered reasons for returning a vehicle. It is the customers\' responsibility to maintain the car once purchased.
This does not apply to vehicles bought for high performance, commercial use, for taxi, for hire or for reward purposes.
Status Disclosure Document
Please read the following document in addition to your pre-contract information and SECCI. You should consider the following given in all 3 documents before signing your finance agreement.
Financing your purchase -- Frequently Asked Questions
Who are we?
Affordable Cars (Yorkshire) Ltd company registration number. 08716545 trading as Affordable Cars Group our registered address is Affordable Cars, A19 Crockey Hill, York, YO19 4SH.
What can we do to help finance your purchase?
We are authorised and regulated by the Financial Conduct Authority for credit brokerage. Our FCA number is 646667
We work with a number of carefully selected credit providers who may be able to offer you finance for your purchase. We are only able to offer finance products from these providers who may offer us an incentive to do so. We will not charge you any fee for our services.
Can we give you independent financial advice?
No, we are not independent financial advisors and are unable to give you independent financial advice.
What can you do if you wish to complain about our services?
If you wish to make a complaint, please contact us in the first instance by writing to us at Customer Services Department, Affordable Cars Group, A19 Crockey Hill, York YO19 4SH, or by telephoning us on 01904 644440
You have the right to refer any unresolved complaint to the Financial Ombudsman Service , South Quay Plaza ,183 Marsh Wall, London, E14 9SR.
Telephone: 020 7964 1000
Fax: 020 7964 1001