What is a Complaint?
A complaint is any oral or written expression of dissatisfaction by a person, or their representative, who has had dealings with us alleging that the action, or inaction, of our staff, agents, or contractors, has fallen short of their expectations. Types of complaint can include:
- Poor interaction with our office staff, agents or contractors
- Damage to property
- Incorrect tracing
- Fees which have been applied
Regardless of how a complaint is received we will need to receive the below for a full review to be conducted:
- The full details of the complaint including any specifics relating to interactions with our staff or contractors (including names, dates and times if known) whilst also providing any relevant evidence.
- The impact of the event being complained about, what effect did it have?
- What is your preferred remedy, what steps do you feel we could we take to resolve this? Examples of remedies can be an apology, a refund or a request for a change in process
It’s important to note that making a complaint won’t change how we treat you going forward and that they are often used as a tool to improve our service.
Complaints and their outcomes are regularly reviewed internally at CDER and also independently by our Independent Advisory Group (IAG), as part of our complaint processes, and adjustments are implemented where applicable to progress satisfaction in our service and prevent further complaints where possible.
What isn’t a Complaint?
While we welcome all complaints, there are some situations which can be dealt with as a general enquiry/request which can include the below:
- Service issues that can be dealt with during a conversation such as setting or amending a payment plan or locating a missed payment to reset an arrangement. These may be instances where something has gone wrong but can be fixed without the need for further escalation and to prevent dissatisfaction.
- Disputes surrounding the liability or amount of the original debt or order. CDER can only offer limited assistance in these instances but can offer basic guidance as applicable.
- Your opinion or feedback, whilst we are happy to hear this, we will not treat it, or respond to it, as a complaint
Complaints or issues pending a decision from the Court – if the matter becomes subject to formal legal proceedings, it must follow the relevant legal process and the complaint will not be responded to.
How to Make a Complaint
We welcome complaints by any method but specifically you can contact us:
By email to:
HMCTS complaints – Magistrates Court Fines
If your complaint relates to a Magistrates Court Fine, please submit your complaint using the below email:
email: hmcts-complaints@contactcder.co.uk
By post to:
CDER Group Ltd, Floor 9 Peninsular House, 30-36 Monument Street, London, EC3R 8LJ
As mentioned above, when making a complaint please tell us as much information as possible to help us to understand your concerns.
Please make sure you provide:
- your full name, or business name, and address
- your reference number
- details of your complaint
- any evidence you would like considered e.g. documents, photos
- how you would like the complaint to be resolved
You don’t have to make a complaint yourself if you don’t feel able to, you can give your authority to someone else (either an individual or from an agency) in writing and they can bring the complaint on your behalf. We will still need all the details of what happened and the impact on you but someone else can communicate this to us on your behalf.
Where can you get Support
Support can be obtained via various sources, such as:
- National Debtline
- Business Debtline
- Citizens Advice
- StepChange Debt Charity
- Christians Against Poverty
- Community Money Advice
- Debt Advice Locator Tool via https://www.moneyhelper.org.uk/en
You can also contact the Enforcement Conduct Board (ECB) using the link below and they may be able to help. https://enforcementconductboard.org/
3rd party authority – if you are complaining on behalf of somebody else, please ensure you provide written authority on behalf of the complainant.
What Happens Next
Acknowledgement – We will acknowledge a complaint within 2 working days of its receipt. This acknowledgement will be in writing and via email wherever possible.
Informal Resolution – We will always try to resolve a complaint fully and informally within 5 working days from when we acknowledged receipt. During this period the complaint will be considered by one of our Complaints Administrators, they will review documentation (including your submission), listen to phone calls or watch body worn video footage to allow them to reach a fair outcome.
Formal Resolution – we will move to this stage if we have been unable to resolve your complaint by informal resolution. This may be because we did not complete our review within the timeframe, due to its complexity or the unavailability of necessary information, or because we provided our informal resolution, but you didn’t accept it.
We have 20 working days from when we acknowledge the case has moved to Formal Resolution to issue our final written response although we will always respond sooner where possible.
If we aren’t able to provide our Formal Resolution within 20 working days we will let you know as soon as possible and outline your options.
To support the continuous improvement of our people and processes, the details of all complaints are captured, regardless of the resolution type, analysed by an appropriate person / department and reported within our organisation and industry sector.
What if you aren’t Satisfied with our Response
If our complaints process has been exhausted and you remain dissatisfied with the outcome reached, for events from January 1st 2025, you can refer your case to:
Enforcement Conduct Board (ECB)
10 Queen Street Place,
London,
EC4R 1BE
https://enforcementconductboard.org/making-a-complaint/
Please note you have the longer of 3 months from when you reasonably could have been aware you had a complaint or 1 month from our final response to your complaint. If you refer your complaint after this period, the ECB may not consider your complaint.
If you are complaining about an event which took place prior to the 01st January 2025 and you remain dissatisfied with the outcome reached by CDERs complaint team, details of further escalation can be found below:
| Local Authorities (Councils) (including Transport for London) |
Central Government (including Highways England and His Majesty’s Courts and Tribunals Service) (HMCTS) |
| If your complaint relates to a local authority debt (e.g., Council Tax, NNDR, Road Traffic Penalty Charge Notice (PCN) you can escalate your complaint direct to the local authority.
They will ask you what steps you have taken to resolve the matter with us, and the reasons why you feel our response has not been sufficient. If you remain dissatisfied with their response, you can refer your complaint to the Local Government & Social Care Ombudsman. Use the link below to find out more about their complaints process. |
If your complaint relates to a Highways England Penalty Charge Notice (PCN), or a HMCTS Magistrates Court Fine, you have the option to escalate your complaint to our governing trade body – Civil Enforcement Association.
Complaints to CIVEA can be sent by post to the following address: CIVEA Please note that CIVEA will only investigate a complaint that has been formally investigated by CDER Group. For more information regarding CIVEA’s complaint process, please go to: |
Protecting our Staff
Unreasonable Behaviour
We will take a case-by-case approach to deciding whether a behaviour is unacceptable, and examples provided are not exhaustive.
However generally, examples of behaviour that we won’t tolerate are grouped under two broad headings:
- behaviour that is unacceptable because it is aggressive or abusive, including the use of offensive language
- behaviour that is unacceptable because of the unreasonable nature of the engagement with us
There may be times when the tone, frequency or both of communications become excessive, disproportionate, and unreasonable.
Examples of this behaviour include, but are not limited to:
- asking for a response within an unreasonable timescale
- repeatedly contacting or asking to speak to a particular member of staff who is not the right person to talk to
- making repeated contact via phone, email, post or social media at a volume that we consider excessive
- sending duplicate correspondence requiring a response to more than one member of staff
- acting in a way that presents barriers to our progressing a complaint including not providing information and / or evidence without a reason
- not accepting our decision and continuing to contact us about it after our process is exhausted
What we will do if behaviour is unreasonable
Where someone continues to communicate in an unacceptable manner, or where the conduct is of a particularly serious nature, we will restrict contact or alter our approach to protect our people.
It should be noted that we will continue with enforcement activity albeit in a way to protect our staff from unacceptable behaviours or potential violence. The precise nature and action will be appropriate and proportionate to the nature of the unacceptable behaviour and the circumstances of our staff and the customer.
Among other things we may:
- in the case of a complaint that has been through all stages of our process cease correspondence
- for other, non-complaint, correspondence we will consider ending all contact for a specified period of time or about a specified topic – we will accept correspondence from a 3rd party in these circumstances as long as it is reasonable
- in the case of threats of violence, we will consider referral to the police or we will restrict / alter our approach
- in the case of actual violence, we will always report to the police and will fully support in any prosecution
When deciding to restrict contact, we will consider any special requirements of those affected by our decision and will continue to communicate with 3rd party advocates.
Aggressive, abusive, or offensive language or behaviour
All of our staff, whether they work in one of our offices or externally, have the right to a safe work environment and not to be subjected to aggressive, abusive or offensive language or behaviour, regardless of the circumstances.
This includes behaviour relating to any protected characteristic they may have, as defined by the Equality Act 2010 (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation).
Examples of this behaviour include, but are not limited to:
- threats of physical violence
- swearing
- inappropriate cultural, sexist, racial or religious references; and
- rudeness, including derogatory remarks
- persistently and repeatedly raising unsubstantiated accusations against staff members
Violence is not restricted to acts of aggression that may result in physical harm. It also includes behaviour or language (written or spoken) that may cause (or may have the potential to cause) staff to feel distressed, threatened or abused.
Telephone Calls
If a customer’s language or behaviour on the phone is unacceptable as set out in this policy, our people have the right to put them on hold or to end the call. However, before taking such action, we will usually try to warn the caller that their conduct is unacceptable and allow them the opportunity to moderate their behaviour.
We may decide to arrange for a single, named member of staff to deal with all future calls or correspondence from the customer. If a customer consistently behaves in an unacceptable way on the phone, a more permanent restriction may be considered, for example ‘call barring’ their phone number for inbound calls.
Support for employees
Additional support will be offered to the employee who experienced the unreasonable behaviour e.g. mental health first aider, employee support network
