1. Objectives of complaints management
In compliance with Article 28 of the Legal Framework for Insurance and Reinsurance Distribution, approved by Law no. 7/2019 of 16 January, and with ASF Regulatory Standard no. 13/2020-R of 30 December, VERSPIEREN PORTUGAL has established the autonomous function of Complaints Manager, whose holder is responsible for ensuring compliance with the internal Complaints Management Procedure.
Through this Procedure, VERSPIEREN PORTUGAL aims to ensure the impartial, prompt, efficient and transparent handling of complaints submitted by policyholders, insured persons, beneficiaries or injured third parties.
VERSPIEREN PORTUGAL regards the proper handling of complaints as one of the relevant activities of management, covering measures to correct, where applicable and as promptly as possible, any non-conformities detected in the service provided, and the assessment of whether action is needed to eliminate their causes, with a view to improving the Organisation's performance.
2. Definition of a complaint
a) Insurance distribution activity
Any complaint from policyholders, insured persons, beneficiaries or injured third parties addressed in writing to VERSPIEREN PORTUGAL's services, expressing disagreement or dissatisfaction with the services provided by the Organisation, including any allegation of possible non-compliance.
The concept of a complaint does not include statements forming part of contract negotiations, demands for the performance of legal or contractual duties, communications inherent to the claims settlement process, or requests for information or clarification.
b) Personal data protection
Complaints addressed in writing to the Organisation's Data Protection Officer.
3. Submission and minimum information a complaint must contain
VERSPIEREN PORTUGAL only accepts complaints in writing.
Without prejudice to any further information VERSPIEREN may subsequently need to request from the complainant, a complaint must contain the following:
Full name of the complainant and, where applicable, of their representative;
Capacity of the complainant (policyholder, insured person, beneficiary, injured third party);
Contact details and identification document number of the complainant;
Description of the facts supporting the complaint and, where possible, the identification of those involved and the date on which the facts occurred;
Where possible, the policy and/or claim number associated with the complaint;
Any other information the complainant considers relevant to handling the complaint; and
Date and place of the complaint.
4. Where to submit a complaint
a) Complaint relating to an insurance contract
The e-mail address of the policy or claims manager; or, preferably, [email protected]
b) Complaint relating to the processing of personal data
The Organisation's Data Protection Officer: [email protected]
5. Response times
VERSPIEREN PORTUGAL undertakes to observe the following response times:
Acknowledgement of receipt: 3 working days;
Decision: 15 days after receipt of all the information requested.
Whenever the steps required to analyse the complaint prevent the decision deadline above from being met, the complainant will be duly informed as promptly as possible, with an indication of the estimated date for concluding the analysis of the case.
In that case, the complainant will be kept informed of the steps in progress and to be taken in order to respond to the complaint.