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ITU-T Focus Group Digital Financial Services
                                               Consumer Experience and Protection



               2.4    Complaints handling


               2.4.1   In-house dispute resolution

               Recourse mechanisms can build consumer trust in the system if they operate efficiently and respond to
               consumer concerns and problems (Chapman & Mazer 2013). From the contract review, provider contracts
               described an in-house dispute resolution mechanism in only 39 per cent of the agreements. This means that
               for the most part, customers will not know how to go about resolving disputes. As a result, customers may
               unnecessarily accept loses or burden government agencies with complaints that could have been resolved
               more efficiently and promptly directly with the provider.

               See Box 5 for an example of contract clauses related to complaints handling which may not adhere to the legal
               and regulatory requirements in Uganda and Nigeria.

               Figure 8: In-house dispute resolution
































               Box 5: Complaints handling



                   Uganda Mobile Money Regulations

                   Under Section 12(d) Complaints handling and consumer recourse, mobile money service providers
                   shall ensure that appropriate and effective procedures for receiving, considering and responding to
                   complaints are put in place. The complaints handling procedure shall ensure that:
                   (iii) A dedicated toll free telephone line for complaint resolution is provided;

                   Nigeria, Consumer Protection Framework:

                   2.7.1 Complaints Channels - Financial institutions shall have multiple channels (including electronic and
                   non-electronic channels) for consumers to lodge complaints. Examples of complaints channels may
                   include provision of dedicated email addresses, telephone numbers, help desk, web chat etc. Such
                   channels shall be toll-free, easily accessible and available to consumers or their agents at all times.








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