Complaints Policy and Procedures
Introduction
Check Technologies, Inc. (Check) is committed to maintaining its responsiveness to the needs and concerns of its customers. This policy sets forth the standards and procedures in which Check receives and resolves complaints made against the company, its partners and employees. This policy applies to Check and its subsidiary, Check Payments LLC.
Policy Statement
Check views customer complaints as an expression of legitimate concern regarding the way it provides its processing of payroll for third party software providers. The objective of this policy is to assist the company and its employees in resolving complaints in an efficient, expeditious and professional manner. If handled constructively, complaints are an opportunity to improve products and services, enhance customer satisfaction and minimize potential regulatory impact.
Complaints Officer
The Chief Compliance Officer may appoint a Complaints Officer to serve as the primary contact for receiving written complaints and managing the resolution process. Should there not be a Complaints Officer appointed, any action items identified in this policy will revert back to the Chief Compliance Officer.
Complaint Resolution Procedure
Definition of a complaint
For the purpose of this policy, a complaint is defined as a written communication by a customer or end user expressing a concern related to Check products or services where a response is explicitly or implicitly expected, and that meets one or more of the following categories:
- Expression of dissatisfaction with the service received as compared to what was promised, rising to the level of a potential violation of service terms or equivalent.
- Assertion that complainant has suffered a financial loss due to a failure on the part of the company in provision of its services.
- Assertion that complainant is a victim of possible fraud, identity theft, financial loss and/or criminal activity due to an action taken or not taken by Check.
- Allegation of breach of customer’s or end user’s privacy or personal information. Negative feedback and statements of general dissatisfaction with Check services or agreed upon terms and conditions that do not require a resolution or formal follow up are not covered under this policy. Items that fall outside of the above criteria will be considered a grievance and should be handled using Check’s standard procedures for partner and end user communications.
Receiving complaints
Complaints may be received via email such as support@checkhq.com, messaging platform such as Slack, or through a dedicated customer support platform such as Zendesk. Written complaints must be addressed by the appropriate team in accordance with any applicable service level agreements (“SLAs”). The Complaints Officer should be notified of complaints that cannot be addressed within the applicable SLA - or, if there is no SLA, within five (5) business days from first review.
The following are examples of complaints that may be received from a customer or its employee:
- “I never received my earnings as agreed to by using Check.”
- “My earnings received from Check are different than the agreed amount.”
- “I am supposed to get paid twice a month, but only receive pay once a month.”
- “Tax funds that were taken by Check are different from the agreed amount.”
- “I suspect Check shared my confidential data.”
Handling complaints
Upon receipt of an unresolved complaint, the Complaints Officer shall assess the severity of the complaint and either investigate the complaint or assign the complaint to a manager for investigation. If a complaint is unrelated to Check services, and is instead traceable to partner activities, the Complaints Officer shall refer the complaint to that other entity as quickly as possible.
If the matter is reasonably likely to give rise to legal action against the company, including instances in which the aggrieved party has retained or has threatened to retain an attorney in connection with the complaint, the matter should immediately be referred to the Legal team. Reports of unauthorized data sharing or cybersecurity breaches should be immediately reported to the Security team.
Investigating complaints
Check staff must provide the Complaints Officer with all assistance requested in order to allow for a full investigation to be conducted in a timely manner. When investigating a complaint, the Complaints Officer or their designee shall gather all facts and evaluate the circumstances giving rise to the assertions made by the aggrieved party. During the investigation process, the Complaints Officer or their designee must keep the complainant informed of the progress and likelihood of any delays. Communications to an end user may be facilitated via the appropriate Check partner.
Based on the findings of the investigation, the Complaints Officer or their designee shall propose a remedy. Possible considerations for remedies include:
- Correction of errors
- If correction not possible or not within the power of Check to remedy, suggest alternative solutions or refer complainant to the appropriate third party (for example, in the case of a tax notice, the relevant tax agency).
- Full or partial payment of aggrieved amount.
- Financial assistance or compensation.
Recording complaints
All complaints must be recorded in Check’s system of customer communications. Each complaint should be documented with its status clearly noted as either open or resolved, along with the corresponding dates of when it was received and resolved.
In addition, each complaint must be logged in Check’s Complaint Tracker. During the review and resolution process, complaints should be evaluated to determine whether they pertain to First Internet Bank (FIB). If a complaint is identified as relating to FIB, it must be escalated to the Bank via the Increase dashboard promptly upon resolution.
Responding to complaints
All complaints must be addressed within appropriate time limits. The maximum time limit for resolving a complaint is 45 days, excluding any time spent waiting for action by a government agency.
Once a resolution has been authorized, a written determination of resolution must be sent to the complainant. The written response must include the following information:
- Advise the complainant of the resolution.
- Give reasons for the determination.
- If the resolution is not what the complainant requested, advise of the existence of
further avenues of appeal or outreach, including contacting the relevant regulator or
state agency, if applicable. - If the resolution of the complaint is contingent upon the acceptance and release of
claims, inform the complainant of such and attach the document to be signed.
Retention of records
The Complaints Officer will be responsible for ensuring that written records of complaints and related investigations are maintained as required by Check’s data retention obligations.
Staff training
All Support team members are trained annually on the Check Complaints Policy and Procedures.
Management reporting
On a periodic basis, a report of customer complaint trends and systematic issues should be prepared by the Complaints Officer and submitted to Check leadership. The report will be used as a tool to assess the need for additional training, possible document revisions and the need to amend procedures. Any issues or concerns with respect to procedures and system functionality that are uncovered during the investigation of a complaint should be addressed as soon as practicable. Check may share this report with partners, critical vendors, and Check’s bank partners, upon request.
Responsible Officer
The Chief Compliance Officer is responsible for carrying out the overall aims and objectives of
this policy.
Updates
This policy was last updated December 17, 2024.