PRIVACY, T&Cs, & COOKIE POLICY
CMutual - IRL
Privacy Statement
General Data Protection Regulation (GDPR) Notice
At CMutual we are committed to keeping your privacy and information safe. We respect the trust you’ve placed in us, and this Notice is a copy of our policy around how we do this.
Our privacy notice tells you what we do with information we collect about you. It’s relevant to anyone who uses our services, including policyholders, prospective policyholders, our partners and visitors, our website users and beneficiaries under our policies.
It is the intention of this privacy statement to explain to you the information practices of CMutual in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
CMutual Services (Ireland) Limited
Located at 511, The Capel Building, Mary’s Abbey, Dublin 7, D07 FK22 Ireland
When we refer to ‘we’ it is CMutual.
Who are we?
CMutual is the pre-eminent insurance specialist for Credit Unions. We have unique expertise in tailoring protection solutions to fit the needs of the credit union and its members. We are an Insurance broker regulated by the Central Bank of Ireland. CMutual staff are experts in Commercial Insurance products, and Credit Union insurance needs. CMutual group offer quotations, and policies for clients to fit their needs.
The controller (as defined in the GDPR) of your personal data for all purposes outlined in the policy is CMutual. We can be contacted by post at 511 The Capel Building, Mary’s Abbey, Dublin 7, D07 FK22, Ireland, by telephone at 01 55 33 500 or by email at [email protected]
Purpose for processing your data:
-
To provide insurance quotations to potential clients.
-
To offer clients and potential client’s insurance for their needs and requirements.
-
To provide ongoing insurance support.
-
As part of our ongoing Anti-Money Laundering (AML) requirements, we have an obligation to carry out customer due diligence on each of our customers.
Why are we processing your data? Our legal basis.
We will only process your data where we have a legal basis in accordance with data protection Law.
In order for us to provide you with our services, CMutual needs to collect personal data for the purpose of providing you with insurance quotations and incept policy cover on your instruction.
CMutual needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.
CMutual provides quotations, and policies on a range of Commercial Credit Union insurance products, for both Life and General insurance.
CMutual is committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
How will CMutual use the personal data it collects about me?
CMutual will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
Special Categories of personal data
If we collect any special categories of personal data (e.g. health). We will ensure that we will obtain your explicit consent prior to collecting such data.
Please note in order for us to provide some insurance quotations we must ask questions in relation to convictions and prosecutions pending.
Who are we sharing your data with?
CMutual is a regulated insurance intermediary, holding agency agreements with insurance companies to provide clients with quotations and policies of insurance. We collect data required for the provision of contract terms and this information is shared with relevant insurance companies and underwriting partners who provide the insurance premium for the risk being proposed to them.
We may pass your personal data on to third-party service providers contracted to CMutual in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with CMutual procedures. In certain cases where you the client appoint a third party to act on your behalf (loss assessors for example) we will share data with them on your written request to do so.
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent unless we are legally required to do otherwise.
If we transfer personal data to a third party or outside the EU, we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.
Data Subjects Rights:
CMutual behaves in line with our data protection policy and the subject access request procedure. This is available on request. For any GDPR related queries please email [email protected]
Your rights as a data subject:
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
-
Right of access – you have the right to request a copy of the information that we hold about you.
-
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
-
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
-
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
-
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
-
Right to object – you have the right to object to certain types of processing such as direct marketing.
-
Right to object to automated processing, including profiling.
-
Right to judicial review – in the event that CMutual refuses your request under rights of access, we will provide you with a reason as to why.
All the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. CMutual will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body and our internal governance.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by CMutual or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and CMutual.
​
You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:
​
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Phone: + 353 765 0100/ + 353 1800 437 737
Email: [email protected]
Failure to provide further information.
If we are asking for your data for an insurance contract/quotation and you cannot provide this data the consequences of this could mean the contract cannot be completed, quotation cannot be provided, or details are incorrect.
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact our data protection officer on 01 55 33 500, email: [email protected]
Privacy policy statement changes:
CMutual may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services, you agree to this privacy policy.
This privacy policy was last reviewed in January 2025
CMutual is regulated by the Central Bank of Ireland with Registration No.371942 and its registered offices are at 511 The Capel Building, Mary’s Abbey, Dublin 7.
Tel: 01 55 33 500 E: [email protected]
​
Terms and Conditions
​
Who are we?
CMutual Services (Ireland) Limited is regulated by the Central Bank of Ireland with the Central Bank reference number of C33182.
CMutual Services (Ireland) Limited is registered in Ireland with a registered address at 511, The Capel Building, Mary’s Abbey, Dublin 7, and a registered company number of 371942.
You can find out more about us at www.cmutual.ie
Accepting our Terms of Business
This agreement, together with any separate written agreement between you and CMutual Services (Ireland) Limited (“Cmutual”), sets out the terms on which we agree to act for you when we are instructed to provide services by you. By asking us to arrange or handle your insurances you are providing your informed agreement to these terms of business.
Whose products do we offer?
CMutual Services (Ireland) Limited is authorised and regulated by the Central Bank of Ireland as an insurance, reinsurance or ancillary insurance intermediary under the European Union (Insurance Distribution) Regulations, 2018.
We only provide products on a limited analysis of the market basis. This means that we only provide products that are created and underwritten by insurance companies with whom we have a written commercial agreement to do so.
Therefore, the products that we provide are not based on an analysis of all products available in the insurance market.
Currently we only offer products created and underwritten by the following insurance companies:
Credit Union Package of Protection (CUPOP)
General Insurance underwritten by Allianz Ireland plc
Registered in Ireland, No. 143108
Registered Office at Burlington House, Burlington Road, Dublin 4
Fidelity Bond & Directors & Officers cover underwritten by AIG Europe S.A.
Registered in Ireland No. 908876
Registered Office at 30 North Wall Quay, IFSC, Dublin 1
Cyber Insurance
Underwritten by AIG Europe S.A.
Registered in Ireland No. 908876
Registered Office at 30 North Wall Quay, IFSC, Dublin 1
Underwritten by CFC Europe S.A.
Registered in Belgium, No. 0711818068
Registered Office at Levels 20&21 Bastion Tower, 5 Place du Champs de Mars,1050 Brussels
Group Life & Critical Illness Insurance Products
Underwritten by Utmost PanEurope DAC
Registered in Ireland No. 311420
Registered Office at Navan Business Park, Athlumney, Navan, Co Meath.
Underwrtten by Aviva Life and Pensions Ireland DAC
Registered in Ireland with registration number 165970
Registered office is at Building 12,Cherrywood Business Park Loughlinstown, Co. Dublin D18
W2P5.
Non-Life Insurance Products
Accident & Sickness Insurance cover underwritten by Maiden Life Försäkrings AB
Registered in Sweden No. 516406-0468
Registered Office at Klarabergsviadukten 70, Box 70396, 107 24 Stockholm, Sweden.
Involuntary Unemployment Insurance cover underwritten by Maiden General Försäkrings AB
Registered in Sweden No. 516406-1003
Registered Office at Klarabergsviadukten 70, Box 70396, 107 24 Stockholm, Sweden.
In some cases we may be granted authority from an insurance undertaking to conduct tasks on their
behalf, for which we will be remunerated. Where we place your business with this insurance
undertaking under this authority you will be notified in advance of the placement.
We will also offer assistance to you in relation to processing claims on policies taken out with us and in
seeking renewal terms on your cover.
We will not in any circumstance, guarantee the solvency of any insurer.
We can act both as agent of insurer, and on behalf of you. We have in place management controls to
deal with any conflicts of interest that might arise.
Remuneration
Remuneration is the payment earned by us for work undertaken on behalf of you and our product
providers. The amount is generally directly related to the value of the products sold and is otherwise
known as commission. Our income is generated from a combination of commissions and administration
fees for our professional services, premium management and claims management services. The level of
fee charged will be dependent on the complexity of service, seniority of staff involved, compliance
factors, and other operational considerations. Any fees charged will be inclusive within your quotation
documentation and where business is transacted. Specific policy set-up fees may be non-refundable in
the event of policy cancellation. A summary of the details of all arrangements for any fee, commission
other reward or remuneration paid or provided to us which have agreed with product providers is
available on request.
Regular Reviews
It is in your best interests that you review, on a regular basis, the products which we have arranged for
you. As your circumstances change, your needs will change which may result in you having insufficient
insurance cover.
Default for Non-Payment
Non-payment of premium and/or failure to disclose any relevant information may result in the
cancellation of your policy. You should refer to your Policy Document for further details.
Codes of Conduct
CMutual Services (Ireland) Limited is subject to compliance with all regulatory requirements relevant to
an Insurance Intermediary.
In particular, we must comply with the Consumer Protection Code, the Minimum Competency Code and
the Fitness and Probity Standards. These particular Codes/Standards offer protection to consumers and
further details with respect to these Codes/Standards are available from the Central Bank of Ireland
directly at www.centralbank.ie.
Disclosure of Information
It is essential that you should bring to our attention any material alteration in risk such as changes of
address or use of premises. Any failure to disclose material information may invalidate your claim and
render your policy void.
Data Protection
CMutual Services (Ireland) fully respects your right to privacy. Any personal information which you
provide to us will be treated with the highest standards of security and confidentiality, strictly in
accordance with the Data Protection Acts 1988-2018.
We are committed to protecting and respecting your privacy. We wish to be transparent on how we
process your data and show you that we are accountable with the GDPR in relation to not only
processing your data but ensuring you understand your rights as a client.
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation on data protection and
privacy for all individuals within the European Union. It came into force across the European Union on
25 May 2018. It replaces the previous data protection directive which has been in force since 1995 and
forms the basis of our new Data Protection Irish laws (Data Protection Acts 1988-2018).
The data you supply may be used for administration purposes by CMutual Services (Ireland) Limited,
our associated companies, the insurer, our agents and the insurers’ agents. We may pass the
information to regulatory authorities, which monitors whether we are adhering to regulatory
requirements. Your data may be transferred to another country within the EEA in order to fulfil
statutory actuarial monitoring responsibilities required under Solvency II.
You have a right to request a copy of your personal information which is held by us. For more details
write to:
The Data Protection Officer
CMutual Services (Ireland) Limited
511 The Capel Building, Mary’s Abbey,
Dublin 7
Tel: 01-553 3500 Email: [email protected]
Period of Insurance
The period of insurance in respect of any Policy you hold is defined in your Policy Schedule.
Cancellation
Both you and the underwriter can cancel the Policy by providing written notice to the other in
accordance with the terms and conditions as set out in your Policy Document.
Governing Law
The laws of the Republic of Ireland will apply to your policy and the Irish Courts will have jurisdiction to
hear any dispute regarding your Policy unless otherwise stated on your Proposal Form or in your Policy
Document.
Language
Your policy and all communications with you or by you to us will be in English.
Conflicts of Interest
CMutual Services (Ireland) Limited seeks to avoid any conflict of interest when providing services to
our customers. Should an unavoidable conflict of interest arise then we will advise you of the details in
writing. Where pertinent, we will request your confirmation in writing to proceed where a conflict has
been identified. A full copy of our conflicts of interest policy is available on request.
Investor Compensation Scheme
CMutual Services (Ireland) Limited is a member of the Investor Compensation Company Ltd (ICCL)
Scheme established under the Investor Compensation Act 1998.
This Act provides for the establishment of a compensation scheme and to the payment in certain
circumstances, of compensation to certain clients of firms (known as eligible investors) covered by the
Act. However, you should be aware that a right to compensation will only arise where money or
investment instruments held by the firm on your behalf cannot be returned, either for the time being or
for the foreseeable future, and where the client falls within the definition of eligible investor as
contained in the Act. In the event that a right to compensation is established, the amount payable is
the lesser of 90% of the client’s loss (if recognised as being eligible for compensation) or €20,000.
CMutual Services (Ireland) Limited also holds Professional Indemnity Insurance in accordance with the
Central Bank of Ireland’s requirements.
Complaints
A full copy of our complaints procedure is available on request.
Should you not be satisfied at any time with the service you receive from CMutual Services (Ireland)
Limited, please do not hesitate to make the fact known to us. We have an internal complaints
procedure and will deal with your complaint promptly, thoroughly and in line with regulatory standards.
Complaints should be addressed to:
Compliance Manager
CMutual Services (Ireland) Ltd
511 The Capel Building, Mary’s Abbey, Dublin 7
Dublin 7
Tel: 01-553 3500 Email: [email protected]
We will acknowledge your complaint in writing within 5 business days of receipt and will provide an
update on the progress at regular intervals of not greater than 20 business days. We endeavour to
resolve all complaints within 40 business days however if we have not resolved your complaint within
40 business days, we will inform you of the anticipated timeframe within which we hope to have your
complaint resolved. If you dissatisfied with the handling/outcome of your complaint, you may refer
same to the Financial Services and Pension Ombudsman:
The Financial Services and Pension Ombudsman
3rd Floor, Lincoln House
Lincoln Place
Dublin 2
Tel: 01 567 7000
E-mail: [email protected]
Webpage: www.fspo.ie
General
If any provision of these Terms is found to be invalid or unenforceable in whole or in part, the validity
of the other provisions of these Terms and the remainder of the provision in question will not be
affected.
These Terms shall be governed by the law of the Republic of Ireland and the parties agree herewith
that any dispute arising out of it shall be subject to the exclusive jurisdiction of the relevant court.
These Terms supersede all proposals, prior discussions and representations (whether oral or written)
between us relating to our appointment as your agent in connection with the arranging and
administration of your insurance. These Terms constitute an offer by us to act on your behalf in the
arranging and administration of your insurance.
Effective Date
This document is effective from October 2024 until further notice. This version supersedes all
previous versions.
​
​
Cookie Policy
​
We use Cookies to give you the best online experience. We don’t do any funny stuff. If you’re happy to continue, we’ll assume that you’re happy with our policy, what we’re using and tracking and how we use this information to better inform you.
This Cookies Policy (together with our Terms of Business and Privacy Statement) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.
You can find out a lot more about how CMutual ensures that your information is kept safe and secure and used to try make your time with us a better use of your time.
We are committed to safeguarding your privacy and information you share with us. Our commitment is to treat it securely, fairly and lawfully.
We’ll be clear and open about what we’re collecting and why we collect it. We’ll be upfront about how we’ll use this information and will do our best to explain what we intend to do with it.
Our website will use cookies and other similar technologies to collect anonymous information to greatly improve your experience with us, making it faster, easier and more helpful. It also allows us to do other things, such as
-
To remember your preferences
-
Let you move between pages smoothly and efficiently
-
Make our website better
-
Improve the speed, efficiency and accuracy of our website and quote journey
-
Help us to arrange questions, content and other information to match your preferred interests
-
To Collect statistical information for analysis by us, and some of our partners so that we can better serve you
With your permission we will also collect information about you and your quotation journey including information on the products you enquire about or buy from us to:
-
Help us address your questions and queries and to carry out your instructions when you need us to
-
Verify you as a user, or a loyal visitor, and carry out other essential security checks, when appropriate
-
Remember how far you’ve progressed with our quotation and contact you if you need our help in completing and getting a quotation with us
-
To contact/inform you regarding our offers, products and services
-
Supply you with appropriate messaging, information and sometimes advertising that is tailored to you when you are visiting our Credit Union partners website, our website or other websites that promote our products (retargeting cookies)
-
Track the effectiveness of our online marketing activity
What are cookies and what other technologies will we use?
A cookie is a small file which is placed on your computer, just like an image or a web page file. The difference with a cookie is that it contains information which allows a website to identify you as you click from one page to the next, or when you return to the website. It can also be used to allow personalisation of a website. The cookies used, and the information held within them have no personal information and cannot be used to identify you as a person. For this reason, we consider our cookies to be completely non-intrusive. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website and could prevent you from completing some purchases through our site.
We may partner with or receive services from third parties which you can visit from our website. We may also embed external content and features from such third parties within our website (e.g. social media networks such as LinkedIn, Facebook and Twitter). We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
​
Cookie Policy
The cookies we use do not contain any sensitive information such as your name, address or any payment details. Sensitive information which you choose to provide to us as part of the quotation process is stored securely and is not collected in the form of a cookie. Only information which is relevant to your visit to our website is stored in the form of a cookie, for example if you have visited our site previously. We use Google Analytics cookie (__utma, __utmb, __utmc, __utmz) to help us understand how our customers interact with our website and we use this information to continue to improve the user friendliness of our website.
Types of Cookies
Necessary cookies: These are used to manage your website visit, they provide features such as encryption for data and user login plus e-commerce shopping cart choices.
​
Analytical cookies: These cookies track user statistical visit data such as country, browser type and pages visited. We currently use Facebook Pixels and Google Tags to analyze the users interactions on our website and web journeys.
​
Targeting cookies: These cookies remember which features or advertisementss you were presented with and can display the same or related content to provide you with a content that may be of more interest to you. Facebook Pixels are used to target users who have been on our site and credit union websites to target users who have previously shown interest in cmutual.ie.
​
Functionality cookies: These cookies allow your browser to operate more effectively i.e. your language choice or menu preferences. They can also be used to provide services you request, such as viewing videos or social media integration.
​
Disabling cookies: If you wish to, all browsers have the ability to restrict or completely disallow cookies. You may find your internet experience is disrupted if you do this, but it is entirely within your control. If you wish to change your cookie settings, the following website provides useful information: www.aboutcookies.org
​
​
CONTACT US
​
If you have any questions concerning your privacy, please contact us at:
Dublin Office
​
511 The Capel Building,
Mary's Abbey,
Dublin 7,
Ireland D07FK22
Phone: +353 1 5533500
e-mail: [email protected]
​
Complaints Procedure
1. Purpose
In Ireland, this procedure is operated by CMutual Services Ireland Limited in relation to its financial services provided under the Consumer Protection Code 2025. In the UK, this procedure is operated by CMutual Group Limited (authorised and regulated in the UK under FRN 304814) in relation to its financial services covered by the Financial Services and Markets Act 2000, in accordance with the FCA’s DISP rules and Consumer Duty requirements.
2. Our Objectives
-
To respond to complaints in a courteous, timely and fair manner.
-
Take all reasonable steps to resolve any complaint with the consumer making the complaint.
-
To endeavour to address the specific issues raised by our customers and, where appropriate, update our procedures to avoid re-occurrence of problems.
-
To endeavour to achieve a situation where our customer feels we have addressed the complaint, but if he/she remains dissatisfied with the outcome of our efforts, to ensure that he/she is notified of the right to refer the matter to the Financial Services and Pensions Ombudsman (FSPO). In the UK, the equivalent right of referral is to the Financial Ombudsman Service (FOS).
-
To ensure fair outcomes for all customers, including those in vulnerable circumstances, in line with the FCA’s Consumer Duty (UK).
3. Who does this procedure apply to
This procedure applies to all directors and employees of CMutual who receive a complaint in relation to a regulated activity
4. Procedure
-
CMutual will establish and maintain a complaints file and all complaint records will be kept for six years in Ireland, and for three years from the date of receipt in the UK. Complaints will be recorded and categorised in line with applicable regulatory reporting requirements (FCA in the UK; CPC in Ireland), including identification of vulnerable customer complaints, to support regulatory reporting obligations.
-
Where we receive an oral complaint, we will offer the consumer the opportunity to have the complaint handled in accordance with the firms’ complaints process. We will investigate the complaint based on our understanding of the issue.
-
We shall permit and facilitate submission of complaints in writing by post and by electronic means.
-
We will implement and maintain systems and controls to effectively track and manage the progress and resolution of complaints.
-
We will acknowledge all complaints in writing within 5 business days of receipt and will advise you who is dealing with the complaint until it is resolved or cannot be processed any further. Details of all verbal complaints are recorded in writing. Our aim is to resolve any complaint as quickly as possible.
-
We shall provide the consumer making the complaint, or the person making the complaint on the consumer’s behalf, with a point or points of contact in relation to the complaint until the complaint is resolved or all steps of the firm’s complaints procedures have been exhausted.
-
In the UK, for straightforward complaints the FCA allows a 3-day response option – if a complaint can be resolved by us by close of business on the third business day following the day on which it is received, we will send a ‘summary resolution communication’ which will state that we now believe the complaint to be resolved, but that it can still be referred to the FOS, and details of how to do this will be included in the letter.
-
We shall investigate the complaint as swiftly as possible and shall provide the consumer making the complaint or the person making the complaint on the consumer’s behalf, with a regular update, on paper or on another durable medium, on the progress of the investigation of the complaint at intervals no greater than 20 working days, starting from the date on which the complaint was received.
-
Special consideration will be given to customers in vulnerable circumstances, ensuring appropriate support and communication throughout the process. Vulnerability will be assessed at the point of first contact and kept under review throughout the complaint lifecycle. Where vulnerability is identified, the complaint handler will: adapt their communication method and language to meet the customer’s needs; allow additional time for the customer to respond; offer alternative formats for correspondence (e.g. larger print, simplified language); and flag the case for senior manager awareness. Vulnerable customer complaints will be separately identified on the complaint log to enable reporting and trend analysis.
-
We will attempt to investigate and resolve the complaint within 40 business days of having received the complaint; where the 40 business days has elapsed and the complaint is not resolved, the complainant will be informed of the anticipated timeframe within which we intend to resolve the complaint and that the complainant can refer the matter to the relevant Ombudsman and the contact details of such Ombudsman will be provided. In the UK, we will attempt to investigate and resolve the complaint within 8 weeks of receipt. Where the 8 weeks has elapsed and the complaint is not resolved, the complainant will be notified in writing of the reasons their complaint remains unresolved and of the anticipated timeframe within which we hope to resolve it, informed that they can refer the complaint to the FOS, and provided with a copy of the FOS standard explanatory leaflet, its website address and the six-month referral timeframe.
-
Within 5 working days of the conclusion of our investigation of the complaint, we shall advise the consumer making the complaint on paper or on another durable medium of:
-
The decision at the conclusion of the investigation, including the reasons for that decision,
-
Where applicable, the terms of any offer or settlement being made to the consumer making the complaint,
-
Where the consumer has a right to refer the matter to a relevant ombudsman, the fact that the consumer may refer the matter to the Financial Services and Pensions Ombudsman (FSPO), and
-
The contact details of the Financial Services and Pensions Ombudsman FSPO).
-
-
Where it appears to CMutual that the complainant is not satisfied with the outcome of our investigation, and where we feel that we cannot progress the issue further, we will immediately write to the complainant advising them of their right to refer the dispute to Financial Services and Pensions Ombudsman.
-
In the UK, if the complaint is rejected and reasons are given for not accepting it, we will also enclose a copy of the FOS explanatory leaflet along with the contact details of the FOS, state whether the firm consents to waive the relevant time limits and confirm that the complaint must be referred to the FOS within six months of the date on the firm’s final response letter.
-
A senior manager will review the file before its conclusion and attempt to identify any procedures that can be implemented to avoid a repeat of the type of complaint received. Any new procedures will be immediately communicated to all staff and placed in the Written Procedures file.
-
With regard to Quality Assurance, all complaint investigations are conducted by the by the Head of Operations and reviewed by the Head of Product where necessary prior to the issuance of responses. The full quality assurance framework is set out in the Quality Assurance section below.
​
​
5. Quality Assurance
CMutual will operate an ongoing quality assurance (QA) process to verify that complaints are being handled in accordance with this policy and, in the UK, the FCA’s DISP requirements. The QA process is a key control to ensure that errors in complaint handling are identified and corrected promptly, and that the firm can evidence consistent standards to its regulators.
QA sampling: The Head of Operations will conduct a monthly sample review of closed complaint files. A minimum of 10% of all complaints closed in the period will be reviewed, or a minimum of two files where volumes are low. Each reviewed file will be assessed against the following criteria: whether the complaint was correctly identified and categorised (regulated complaint vs non-regulated dissatisfaction); whether acknowledgement was issued within 5 working days; whether updates were provided at intervals of no greater than 20 days; whether the final response was issued within the applicable timeframe (8 weeks in the UK; 40 business days in Ireland) and addressed the complaint fully; whether the complaint was correctly logged on the complaint register and CRM system (Insly); whether senior manager sign-off was obtained prior to closure; and whether any vulnerable customer flags were identified and appropriate adjustments made.
Reporting and escalation: QA findings will be summarised in a monthly report to the ELT, including the number of files reviewed, the number and nature of any failures identified, remediation actions taken, and any trends or patterns emerging. Where a systemic issue is identified, this will be escalated to SMF 16 (UK) or the equivalent responsible senior manager (Ireland) and, where material, to the Board. QA findings will also feed into the root cause corrective action process and into
staff training and coaching.
Supervisory sign-off: All outbound complaint responses (acknowledgements, interim updates, and final response letters) must be reviewed and approved by the Head of Operations or SMF 16 before issue. This supervisory check must be recorded on the complaint log. Where a response is sent without supervisory approval, this will be treated as a QA failure and escalated accordingly.
Annual QA review: The QA process itself will be reviewed annually by SMF 16 to assess its effectiveness and whether the scope or sampling methodology requires updating. The review outcome will be reported to the ELT.
6. Definition and Categorisation of Customer Dissatisfaction
Complaint Definition:
Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination, which alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience.
We record all customer dissatisfaction to ensure we identify underlying customer issues.
Non-Regulated Dissatisfaction is customer dissatisfaction that does not meet the regulated complaint definition. Whilst these cases would not be regulated by CPC regulations, they are recorded and managed to ensure we resolve customer dissatisfaction effectively. If a non-regulatory complaint is not resolved to the customer's satisfaction within a reasonable period, or if the customer indicates they wish to make a formal complaint, it should be immediately escalated to a formal regulatory complaint.
Complaints are reviewed by company management regularly and are reported to the Board. Should there be any emerging theme, the company would address potential product changes with the relevant underwriter in accordance with the prevailing Terms of Business Agreement.
A Regulated Complaint is customer dissatisfaction that meets the FCA (UK) or CPC (Ireland) complaint definition and is made by or on behalf of an eligible complainant. We treat all of our Customers as eligible complainants. In the UK, a Non-FCA reportable complaint is dissatisfaction that meets the FCA definition but is from an ineligible complainant.
Guidelines for applying the complaint definition
To assess whether customer dissatisfaction meets the complaint definition (and should therefore be
managed as a regulated complaint), each case must be assessed on an individual basis taking into
account the customer’s circumstances and the impact the issue has had on them. Consider:
-
Has the customer expressed dissatisfaction? If no dissatisfaction is expressed, there is no requirement to record the interaction and it should be managed as business-as-usual customer contact, with notes maintained on the relevant core system.
-
Does the customer feel they have suffered material distress and inconvenience because of the issue – for example, is the customer becoming upset, using emotive language, or sharing additional context that increases the level of inconvenience or distress (e.g. a sick relative, worrying about finances)?
-
Has the customer been, or may they be, financially impacted because of the issue? If, having identified dissatisfaction, the answer to 2) or 3) is ‘yes’, the case must be managed as a regulated complaint. If the individual remains unsure of the categorisation, it should be recorded as meeting the complaint definition and managed as a regulated complaint.
7. Root cause corrective action
This section describes how CMutual assesses the root cause of complaints and feeds back any learnings relating to company processes, product design, or other matter.
1 – Complaint received
A complaint may be registered by phone, email, via company website form, or in person. The complaint will be acknowledged by the complaint handler, logged on the complaint log, and noted in the CRM system – Insly. At the time of recording the complaint, the narrative may point to an underlying issue (policy coverage, claim part-payment, claim denial, service delay). Each complaint will attract a prioritisation, depending on the issue severity, and at all times within the
context of regulatory compliance requirements.
2 – Resolve complaint
This phase involves the gathering of relevant information (Policy document, policy coverage, claim limits, claim files). In the case of claims related issues, the complaint handler may conduct an interview with the claims assessor.The complaint handler will update the complainant in a timely way with either a full, or interim update. The complaint handler will ensure responses are issued well within the compliance guidelines set by the FSPO (Ireland) and the FOS (UK)
3 – Root cause analysis – RCA
The company is keen to understand why complaints arise, and to learn from the issue so as to either improve company processes, or product as appropriate. Various Six-Sigma approaches may be employed, (Fishbone diagram, Pareto, the 5 Whys). The company is data driven and will ensure cross-functional team involvement (product, Finance, Operations, Compliance). This approach helps drive organisational learning and accountability.The output expected here is a succinct description of what has gone wrong, whether this is people, systems, or process related.
4 – Corrective action
The corrective action will typically include one of insurance product, or process change. Any such change will be supported by focused staff training and coaching. The implementation of changes will be completed to an agreed plan, with clear responsibility, timelines and metrics reported. Where a recommended action has a compliance related impact, such
impact will be assessed prior to implementation.Changes to process will be advised to staff via team meetings with supporting documentation.
5 – Evaluate effectiveness
Complaint metrics will be reviewed to check for recurrence of the identified issue, completion of actions will be reported to the company executive at ExCo meetings.The relevant department manager will feed results of the actions taken into staff training, company systems and processes. Should this evaluation identify any additional process or product weakness,
these will be fed back to the top of the process creating a closed-loop-corrective action flow.In the UK, complaints data will be reported to the FCA in line with updated reporting requirements, including standardised complaint categories, firm-level reporting, and identification of complaints involving vulnerable customers.
8. Policy review
This policy is reviewed at least annually and approved by the ELT.
An earlier review may be triggered by:
• changes to FCA or CBI rules or guidance affecting this policy, or changes to the legislation that this policy refers to.
• findings from internal monitoring, audits, or complaints that indicate the policy or its processes are no longer adequate;
9. Contact
For further information in relation to this Policy, please refer to the Head of Operations
​
​
​
​
​