NetRent Complaints Procedure

NetRent aims to provide a professional, fair and reliable service.

We recognise that things may occasionally go wrong. Complaints give us an opportunity to:

• investigate concerns;
• correct mistakes;
• provide an explanation;
• improve our services;
• identify misleading, unlawful or inappropriate website content;
• protect users of the NetRent website; and
• meet our legal and regulatory obligations.

We will handle complaints:

• free of charge;
• fairly and impartially;
• as promptly as reasonably possible;
• without discriminating against the person making the complaint;
• with appropriate respect for confidentiality and data protection; and
• in a way that is clear and proportionate to the nature of the complaint.

You do not need to use legal terminology, quote legislation or complete a particular form in order to complain.

Making a complaint will not affect your legal rights.

This Complaints Procedure applies to services provided by:

NetRent Limited
Registered in England and Wales
Company number: 04852898
Registered office:

5 Rectory Close
Ysceifiog
Flintshire
CH8 8TA

Telephone: 01352 721300
Email:support@netrent.co.uk

References in this Procedure to “NetRent”, “we”, “us” and “our” mean NetRent Limited.

Financial-services status

NetRent Insurance Services is a trading name of NetRent Limited.

NetRent Limited is an Appointed Representative of Clear Insurance Management Limited, which is authorised and regulated by the Financial Conduct Authority.

• NetRent Limited Financial Services Register reference: 472341
• Clear Insurance Management Limited Financial Services Register reference: 307982

Complaints concerning regulated insurance activity may be handled by NetRent, Clear Insurance Management Limited, or both, in accordance with the applicable regulatory arrangements.

NetRent may also introduce mortgage and finance enquiries to separately authorised mortgage or finance advisers. The authorised adviser is responsible for any advice, recommendation, application or regulated service it provides.

For the purposes of this Procedure, a complaint is any oral or written expression of dissatisfaction about:

• NetRent;
• a NetRent employee or representative;
• the NetRent website;
• information or material published by NetRent;
• a NetRent product or service;
• the Property for Sale service;
• a property listing published through NetRent;
• the handling of a property enquiry;
• an insurance introduction or insurance-related service;
• a mortgage or finance introduction;
• the use of personal information;
• direct marketing;
• cookies or similar website technologies;
• the handling of an earlier complaint; or
• an act or omission for which the complainant believes NetRent may be responsible.

We may treat a communication as a complaint even if the word “complaint” is not used.

A request for information, routine service query or request for technical assistance is not necessarily a complaint. However, if the communication also expresses dissatisfaction, we will consider whether it should be recorded and handled as a complaint.

A complaint may be made by:

• a website visitor;
• a landlord;
• a property owner;
• a property advertiser;
• an estate or letting agent;
• a Property for Sale enquirer;
• an insurance or mortgage customer;
• a tenant or occupier whose information or interests may be affected;
• a business contact;
• a person whose personal information is processed by NetRent; or
• another person or organisation affected by a NetRent service.

You may ask another person to complain on your behalf.

Where someone acts for you, we may require evidence that they have your authority before disclosing confidential or personal information. This may not be necessary where their legal authority is already clear, for example where they act under a valid power of attorney.

We may consider an anonymous complaint, but anonymity may restrict our ability to investigate, seek clarification or communicate an outcome.

You may complain by email, telephone, post or through an appropriate contact facility on the NetRent website.

By email

Send your complaint to:

support@netrent.co.uk

Please use the subject line:

Complaint

For a data-protection complaint, use:

Data Protection Complaint

By telephone

Call:

01352 721300

If you complain by telephone, we will make a written record of the main points. We may send you a copy or summary so that you can confirm that we have understood your complaint correctly.

By post

Write to:

The Complaints Manager
NetRent Limited
5 Rectory Close
Ysceifiog
Flintshire
CH8 8TA

Complaints made through social media

You may alert us to a concern through social media, but social-media messages are not normally a secure method of sending personal, financial or confidential information.

We may therefore ask you to continue the complaint by email, telephone or post.

The date on which NetRent first receives a clear expression of dissatisfaction will normally be treated as the date of the complaint, even if we subsequently ask you to use a more secure communication method.

Please provide, where available:

• your name;
• your business or organisation, where relevant;
• your preferred contact details;
• any account, policy, enquiry, property or listing reference;
• the relevant property address, where applicable;
• a clear description of what happened;
• relevant dates;
• the names of people or organisations involved;
• copies of important correspondence or documents;
• how the matter has affected you; and
• what you believe would be a fair outcome.

Please send copies rather than original documents.

Do not send unnecessary bank details, passwords, identity documents, medical information or other sensitive information by ordinary email.

A complaint will not be rejected merely because some of the information listed above is unavailable. We will ask for clarification where reasonably necessary.

Please tell us if:

• you require information in an alternative format;
• you have a disability or communication need;
• you would prefer us to communicate by email, telephone or post;
• you are experiencing severe illness, financial difficulty or another urgent vulnerability;
• someone is helping you with the complaint; or
• the matter presents an immediate risk of harm or financial loss.

We will consider reasonable adjustments and will try to adapt our communication where reasonably practicable.

We will not charge for making or investigating a complaint.

We will:

1. record the complaint;
2. identify the service, property, communication or issue involved;
3. decide whether it is a general, Property for Sale, data-protection or regulated financial-services complaint;
4. identify whether NetRent, an advertiser, an insurer, Clear Insurance Management Limited, a mortgage adviser or another provider is responsible;
5. acknowledge the complaint;
6. appoint an appropriate person to investigate;
7. gather relevant information;
8. keep you informed where the investigation cannot be completed promptly; and
9. communicate the outcome.

Where practicable, a person who was not materially responsible for the subject of the complaint will investigate or review it.

We aim to acknowledge general complaints within three working days.

The acknowledgement will normally:

• confirm that we have received the complaint;
• provide a complaint reference;
• summarise our understanding of the main concern;
• identify who will handle it;
• explain any further information required;
• explain the applicable response period; and
• tell you how we will communicate with you.

A working day is Monday to Friday, excluding public holidays in England and Wales.

Different legal requirements apply to data-protection and regulated financial-services complaints, as explained below.

We will investigate a complaint competently, diligently and impartially.

Depending on the issue, our investigation may include:

• reviewing correspondence, forms and account records;
• reviewing website and property listing information;
• checking the applicable terms, policies and privacy notices;
• speaking to the employees or contractors involved;
• asking the property advertiser or service provider for information;
• reviewing technical, email-delivery or security records;
• checking the information against applicable legal or regulatory requirements;
• considering similar complaints;
• identifying whether another organisation may be responsible; and
• considering what corrective or remedial action may be appropriate.

We may ask you for additional information. We will not delay beginning appropriate enquiries merely because further information may later be required.

We will consider all relevant evidence fairly. We will not assume that a complaint is invalid merely because NetRent, an advertiser or another provider initially disagrees with it.

We aim to provide a substantive response to a general complaint within 15 working days.

Where the matter is complex, involves another organisation or requires further evidence, we may need more time. In that case, we will:

• explain why the investigation has not been completed;
• tell you what further work is required;
• keep you reasonably informed; and
• provide an estimated date for our response.

We will normally provide the final outcome of a general complaint no later than eight weeks after receipt.

The eight-week period applying to general complaints is a NetRent service standard. It does not mean that every general NetRent complaint is eligible for consideration by the Financial Ombudsman Service.

Our response will normally:

• identify the complaint and the matters investigated;
• summarise the relevant evidence;
• respond to the substantive points raised;
• state whether the complaint is upheld, partly upheld or not upheld;
• explain the reasons for the decision;
• describe any corrective, remedial or redress action;
• explain any remaining limitations on what NetRent can do; and
• identify any applicable review or external escalation route.

Depending on the circumstances, an appropriate outcome may include:

• an explanation;
• an apology;
• correction or clarification of information;
• correction of an account or communication record;
• removal, amendment or suspension of website content;
• contacting a property advertiser;
• improving a process or staff guidance;
• repeating a service;
• a refund, where a payment was made to NetRent and a refund is appropriate;
• financial redress where NetRent or the relevant regulated firm determines that this is appropriate; or
• referral to the organisation responsible for the matter.

Where we reject all or part of a complaint, we will explain why.

13.1 Complaints about NetRent’s service

NetRent will investigate complaints about:

• the operation of the Property for Sale website facility;
• the forwarding of a property enquiry;
• a technical or email-delivery problem;
• a failure by NetRent to administer an enquiry appropriately;
• NetRent’s service follow-up email or telephone call;
• the publication, moderation, suspension or removal of a listing;
• NetRent’s use of personal information; or
• a failure by NetRent to follow its published terms or procedures.

13.2 Complaints about a property listing

All property descriptions, photographs, prices, rental figures, tenancy information and other listing material are supplied by the relevant property advertiser.

If you believe that a listing is:

• inaccurate;
• misleading;
• incomplete;
• unlawful;
• fraudulent;
• unauthorised;
• out of date;
• an infringement of copyright or privacy;
• discriminatory; or
• otherwise inappropriate,

please provide the property address or listing reference and explain the concern.

NetRent may:

• ask the advertiser to respond;
• request evidence of ownership or authority;
• ask for information to be corrected;
• temporarily suspend the listing;
• remove some or all of the listing;
• preserve relevant records;
• restrict the advertiser’s account; or
• refer suspected unlawful conduct to an appropriate authority.

A moderation or removal decision does not amount to NetRent accepting liability for the advertiser’s content.

13.3 Complaints about advertisers and property transactions

The property advertiser is responsible for:

• the listing information;
• responding to enquiries;
• arranging viewings;
• property negotiations;
• offers;
• deposits or reservation arrangements;
• title and ownership information;
• tenancy information; and
• any resulting property transaction.

NetRent provides a free advertising and enquiry-forwarding facility. NetRent does not act as the estate agent for either party and is not a party to a property sale.

NetRent cannot:

• compel an advertiser to respond;
• require an owner to sell;
• determine ownership or title;
• decide whether a tenancy is valid;
• resolve a contractual dispute between advertiser and purchaser;
• determine whether a property is suitable for letting;
• recover money paid to an advertiser or third party;
• award compensation on behalf of an advertiser; or
• provide legal or conveyancing advice.

We may nevertheless investigate whether the advertiser has breached the Property Advertiser Terms and decide whether the listing or advertiser should remain on the NetRent website.

If the advertiser is an estate or letting agent, it may have its own complaints procedure and property redress scheme. Complaints about the agent’s own professional service should also be made directly to that agent.

13.4 Suspected fraud or immediate financial loss

If you suspect fraud, identity theft, false payment instructions or another criminal offence, do not wait for NetRent’s complaints process before:

• contacting your bank or payment provider;
• reporting the matter to the police or the appropriate fraud-reporting service; or
• obtaining independent legal advice.

NetRent will preserve and disclose relevant information where reasonably necessary and legally permitted.

14.1 Who is responsible?

NetRent Limited is an Appointed Representative of Clear Insurance Management Limited.

Where a complaint concerns regulated insurance activity, Clear Insurance Management Limited, as the authorised principal firm, may be responsible for the investigation and final response.

You may complain to NetRent or directly to Clear Insurance Management Limited.

If NetRent receives an insurance complaint, we will record it and promptly notify or forward it to Clear where required. We will tell you who is handling the complaint.

A complaint may concern:

• an insurance introduction;
• information provided about insurance;
• the arranging or administration of a policy;
• a renewal;
• a premium or fee;
• policy documents;
• disclosure or communication;
• an insurance claim;
• an insurer’s decision;
• NetRent’s conduct; or
• the conduct of Clear or another insurance provider.

Where an insurer or another regulated organisation may be wholly or partly responsible, the complaint or the relevant part may be forwarded to that organisation. You will be informed where this occurs.

14.2 Contacting Clear Insurance Management Limited

You may contact:

Complaints Department
Clear Insurance Management Limited
1 Great Tower Street
London
EC3R 5AA

Telephone: 020 7280 3450
Email:complaints@thecleargroup.com

14.3 Insurance complaint response process

Regulated insurance complaints will be handled in accordance with the applicable Financial Conduct Authority rules.

If the complaint is resolved by the close of the third business day following the day on which it was received, and you indicate that you accept the response, the responsible firm will promptly send a written summary resolution communication.

That communication will:

• confirm that the complaint has been made;
• confirm that the firm considers it resolved;
• explain that you may still be able to refer it to the Financial Ombudsman Service if you later remain dissatisfied; and
• provide the required Financial Ombudsman Service information.

If the complaint is not resolved within that period, the responsible firm will:

• send a prompt written acknowledgement;
• confirm that the complaint is being investigated;
• explain that a written response will be sent within eight weeks;
• keep you informed of progress; and
• issue a final response as soon as the investigation is complete.

The final response will:

• accept the complaint and, where appropriate, offer redress or remedial action;
• offer redress or remedial action without accepting the complaint; or
• reject the complaint and explain the reasons.

If a final response cannot be provided within eight weeks, the responsible firm will explain:

• why the investigation has not been completed;
• when a final response is expected; and
• your possible right to refer the complaint to the Financial Ombudsman Service.

NetRent may introduce customers to a separately authorised mortgage or finance adviser.

At the effective date of this Procedure, NetRent’s principal mortgage partner is:

DNA Financial Solutions Limited
Financial Services Register reference: 926435

NetRent does not itself provide the regulated mortgage advice supplied by DNA Financial Solutions Limited.

Complaints about NetRent

NetRent will investigate a complaint about:

• the way NetRent handled the initial enquiry;
• information supplied by NetRent;
• a failure to make an agreed introduction;
• NetRent’s use of personal information; or
• conduct for which NetRent is responsible.

Complaints about mortgage or finance advice

A complaint concerning:

• mortgage advice;
• a personal recommendation;
• lender or product selection;
• affordability;
• an application;
• an illustration;
• fees charged by the adviser;
• protection advice;
• communication by the adviser; or
• the conduct of a lender or provider

should normally be investigated by DNA Financial Solutions Limited or the other authorised firm that supplied the service.

NetRent will identify the responsible organisation and may forward the complaint or help you contact it.

DNA Financial Solutions Limited may currently be contacted at:

DNA Financial Solutions Limited
Holroyds Mill
Old Lane
Halifax
HX3 5WQ

Telephone: 01422 557240
Email:hello@dnafs.co.uk

The authorised firm will apply its own FCA-compliant complaints procedure and provide information about the Financial Ombudsman Service where applicable.

The Financial Ombudsman Service is an independent service that can consider certain complaints about regulated financial products and services.

It does not normally deal with complaints solely about:

• general NetRent website content;
• editorial articles;
• the free Property for Sale advertising facility;
• the accuracy of an advertiser’s property listing;
• an ordinary property transaction; or
• another matter that is not a regulated financial service.

Whether a complainant or complaint is eligible is determined by the Financial Ombudsman Service.

Where applicable, you may be able to refer a regulated complaint to the Financial Ombudsman Service if:

• you are dissatisfied with the final response; or
• the responsible firm has not issued a final response within eight weeks.

A referral must normally be made within six months of the date of the final response. The final response will contain the prescribed wording and explain the applicable time limit.

The service is free to eligible complainants.

Financial Ombudsman Service
Exchange Tower
London
E14 9SR

Telephone: 0800 023 4567

Further information and the online complaint form are available from the official Financial Ombudsman Service website.

Requesting an additional internal review from NetRent does not extend the six-month Financial Ombudsman Service time limit.

17.1 What is a data-protection complaint?

A data-protection complaint includes a concern that NetRent has:

• collected personal information unfairly or unlawfully;
• used information for an unexpected purpose;
• disclosed information to the wrong person;
• failed to keep information secure;
• retained information for too long;
• failed to correct inaccurate information;
• failed to respond appropriately to a data-protection rights request;
• sent unlawful electronic marketing;
• failed to respect an objection or unsubscribe request;
• used cookies or similar technology inappropriately; or
• otherwise failed to comply with applicable data-protection or privacy law.

A subject access request, erasure request or other exercise of a data-protection right is not automatically a complaint. However, dissatisfaction about how NetRent handled such a request may be treated as a complaint.

17.2 How to complain

Email:

support@netrent.co.uk

Use the subject line:

Data Protection Complaint

Alternatively, write to:

Data Protection Contact
NetRent Limited
5 Rectory Close
Ysceifiog
Flintshire
CH8 8TA

You may also telephone 01352 721300.

17.3 How we handle data-protection complaints

NetRent will:

• provide an accessible means of making the complaint;
• acknowledge receipt within 30 calendar days;
• begin appropriate enquiries without undue delay;
• investigate the subject matter to the extent appropriate;
• keep you informed where the investigation continues;
• provide the outcome without unjustifiable or excessive delay; and
• explain any corrective action or reasons why NetRent considers that it has complied with the law.

Although the legal acknowledgement period is 30 days, NetRent will normally aim to acknowledge a data-protection complaint within three working days.

We aim to provide the outcome within 30 days where the matter is straightforward. More complex complaints may take longer, but we will explain the reason and keep you informed.

You do not have to complete an internal review before contacting the Information Commissioner’s Office.

17.4 Information Commissioner’s Office

If you remain dissatisfied, or wish to raise the matter directly with the UK data-protection regulator, you may contact:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Data-protection complaints may also be submitted through the official Information Commissioner’s Office website.

The Information Commissioner’s Office will commonly ask whether you have first raised the matter with NetRent, but you may complain to the regulator at any point.

NetRent works with advertisers, insurers, brokers, mortgage advisers, contractors and other service providers.

Where another organisation may be wholly or partly responsible, NetRent may:

• investigate the part for which NetRent is responsible;
• promptly forward the whole complaint or the relevant part;
• give you the other organisation’s contact details;
• explain why the complaint has been forwarded;
• cooperate with the organisation where appropriate; and
• continue dealing with any part that remains NetRent’s responsibility.

Forwarding a complaint does not mean that NetRent accepts or rejects the merits of the complaint.

Personal information will be shared only where reasonably necessary, legally permitted and consistent with the NetRent Privacy Policy.

If you remain dissatisfied with NetRent’s response to a general, website, editorial or Property for Sale complaint, you may ask the Complaints Manager to review the decision.

Please explain:

• which part of the outcome you disagree with;
• why you believe it is incorrect or incomplete; and
• whether there is new evidence that should be considered.

Where the Complaints Manager made the original decision, a director or another person not materially involved will conduct the review where reasonably practicable.

An internal review will normally consider:

• whether the correct procedure was followed;
• whether relevant evidence was considered;
• whether the conclusions were reasonable;
• whether the explanation was adequate; and
• whether further action is appropriate.

We will normally aim to complete an internal review within 15 working days.

An internal review is not a requirement before exercising any legal right or contacting an applicable external body.

An internal review does not suspend or extend:

• the Financial Ombudsman Service referral period;
• a legal limitation period;
• a court or tribunal deadline; or
• the right to complain to the Information Commissioner’s Office.

We will handle complaint information in accordance with the NetRent Privacy Policy.

Complaint information may be accessed or shared with:

• NetRent employees and contractors who need it to investigate;
• Clear Insurance Management Limited;
• an insurer;
• a mortgage or finance adviser;
• a property advertiser;
• a relevant service provider;
• professional advisers;
• regulators;
• the Financial Ombudsman Service;
• the Information Commissioner’s Office;
• law enforcement; or
• another person where disclosure is necessary and lawful.

We cannot promise complete confidentiality where information must be disclosed to investigate the complaint fairly, respond to an allegation or comply with law.

Tell us if there is information you believe should not be disclosed. We will consider the request, but withholding information may limit what we can investigate.

Complaint records will normally be retained for six years after the complaint is closed, unless:

• a shorter period is appropriate;
• a longer period is required by law or regulation;
• the complaint concerns an active legal claim;
• a regulator or court requires retention; or
• another justified retention period applies.

We will handle complaint information in accordance with the NetRent Privacy Policy.

Complaint information may be accessed or shared with:

• NetRent employees and contractors who need it to investigate;
• Clear Insurance Management Limited;
• an insurer;
• a mortgage or finance adviser;
• a property advertiser;
• a relevant service provider;
• professional advisers;
• regulators;
• the Financial Ombudsman Service;
• the Information Commissioner’s Office;
• law enforcement; or
• another person where disclosure is necessary and lawful.

We cannot promise complete confidentiality where information must be disclosed to investigate the complaint fairly, respond to an allegation or comply with law.

Tell us if there is information you believe should not be disclosed. We will consider the request, but withholding information may limit what we can investigate.

Complaint records will normally be retained for six years after the complaint is closed, unless:

• a shorter period is appropriate;
• a longer period is required by law or regulation;
• the complaint concerns an active legal claim;
• a regulator or court requires retention; or
• another justified retention period applies.

NetRent may review complaints to identify:

• repeated problems;
• inaccurate or unclear website information;
• service failures;
• staff training needs;
• problems with a property advertiser or service provider;
• data-protection risks;
• security concerns;
• unfair outcomes;
• regulatory issues; and
• opportunities to improve our procedures.

Where appropriate, we will take corrective action to reduce the risk of the problem recurring.

Complaint information used for internal analysis will be limited to what is reasonably necessary and anonymised or aggregated where appropriate.

NetRent may update this Complaints Procedure to reflect:

• changes to the website or services;
• changes to the Property for Sale facility;
• changes to NetRent’s regulated arrangements;
• changes to service partners;
• legal or regulatory developments; or
• improvements to our complaint handling.

The latest version will be published on the NetRent website with its effective date and version number.

NetRent complaints

Email:support@netrent.co.uk
Telephone: 01352 721300

Post:

The Complaints Manager
NetRent Limited
5 Rectory Close
Ysceifiog
Flintshire
CH8 8TA

Insurance complaints

Email:complaints@thecleargroup.com
Telephone: 020 7280 3450

Post:

Complaints Department
Clear Insurance Management Limited
1 Great Tower Street
London
EC3R 5AA

Mortgage and finance complaints

Email:hello@dnafs.co.uk
Telephone: 01422 557240

Post:

DNA Financial Solutions Limited
Holroyds Mill
Old Lane
Halifax
HX3 5WQ

Financial Ombudsman Service

Telephone: 0800 023 4567

Post:

Financial Ombudsman Service
Exchange Tower
London
E14 9SR

Information Commissioner’s Office

Telephone: 0303 123 1113

Post:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF