Complaints / Insurance Intermediaries
In order to improve practices related to complaint handling, the ACPR issued a recommendation on May 9, 2022. A complaint is a statement in which an individual expresses dissatisfaction and requires an appropriate response. Conversely, certain requests do not constitute a complaint (e.g., a request for information).
The ACPR’s recommendation aims to:
- To organize the handling of complaints,
- To inform clients about how to access the complaint handling system, the available avenues of appeal, and the processing timeframes,
- To ensure monitoring of the system to enable corrective actions.
- This recommendation is available on the ACPR website.
Below, you will find some guidelines for properly handling your complaints. Please note that these guidelines are not a substitute for legal advice from a professional.
What should I do within my organization?
First and foremost:
- Set up an organization, adapted to your structure, for handling complaints (entry point and direction, identification, processing, principles of responsibility and delegation, etc.).
- Formalize your complaint handling procedure.
- Communicate your procedure to employees in contact with clients and train them so they can clearly identify a complaint and use the complaint handling process.
Subsequently :
- Establish a follow-up process for complaints (recording and reporting).
- Identify shortcomings and poor practices in terms of marketing and customer protection, and implement corrective measures.
- Provide feedback on complaints to those involved in the marketing process.
- If you are required to have an internal control system, consider the identified risks related to complaints and implement the necessary means and procedures.
When Receiving a Complaint, What Should I Do?
Identify the Complaint and Acknowledge Receipt
• For complaints made orally, if they cannot be fully resolved immediately, the complainant should be invited to formalize their dissatisfaction in writing so that you can have a dated copy.
• In all cases, regardless of the channel used by the complainant to submit their complaint, if it cannot be resolved quickly, the complainant must be informed and receive a written acknowledgment of receipt within 10 working days from the date of submission.
Identify the Nature of the Complaint
Two scenarios should be distinguished:
- The Complaint Falls Under Your Responsibility (e.g., information and advice provided).
- It is your responsibility to handle the complaint and respond directly to the client in writing within two months of receiving the complaint. You can seek technical assistance from Signature Assurances in this process.
- The Complaint Concerns Another Matter (e.g., contract interpretation).
- It is your responsibility to forward the complaint to SIGNATURE ASSURANCES within 48 hours to the following address:
- Email: contact@signature-assurances.fr
- Postal Address:
SIGNATURE ASSURANCES
Service Réclamation
25 cours Albert Thomas 69003 LYON – FRANCE
Note: If Signature Assurances or the insurer receives a complaint that falls under your responsibility, the complaint will be forwarded to you as quickly as possible for handling.
What Should I Inform My Clients About?
Before Any Complaint
Provide clear and understandable information on:
• The existing procedures for submitting a complaint, including the contact details (address, phone number, email) of the person or service responsible for handling complaints in your organization;
• Your processing timeframes;
• The existence of a mediator and a mediation charter.
These details should be easily accessible to your clients, particularly in your offices (if you receive clients there) and on your website (if you have one).
In the Event of a Complaint
• Information about the progress of the complaint handling process, especially if there are particular circumstances that may prevent adherence to the standard processing timeframes;
• The existence of a mediator and how to access their services.
If your complaint is not resolved within two months from the date of submission, you may refer the matter to the competent mediator by contacting La Médiation de l’Assurance TSA 50110 75441 Paris Cedex 09 – le.mediateur@mediation-assurance.org.”
The mediator carries out their role free of charge and with complete independence. Any request for mediation must be preceded by a written complaint to our services. If the response provided does not satisfy you or if you have not received a response for more than two months, you may refer the matter to the Mediator at the contact details provided. No legal action should have been initiated. If you wish, you may pursue other appeal procedures afterward.