GDPR-CARPA Complaints and Appeals

Procedure on the filing of formal appeals and complaints with regards to the certification evaluation process

Grant Thornton Audit and Assurance S.A., Luxembourg (“GTAA”) is responsible for and will retain authority for its decisions relating to the handling of complaints and appeals.

To avoid any possible conflict of interest, GTAA shall ensure that those persons engaged in the handling of the complaints and appeals process are different to those who made the original certification decision and were engaged in the preceding certification evaluation procedure.

Should you wish to register such an appeal or lodge a complaint, thereby expressing formal dissatisfaction with GTAA’s certification decision or the certification evaluation process informing the aforementioned decision, please contact your Managing Partner (for internal complaints) or our Legal department (for external complaints or appeals) at the following address:

GTAA - Complaint

13, rue de Bitbourg

L-1273 Luxembourg

Tel: +352 45 35 78

Email: gdpr.carpa@lu.gt.com  

General

Complaints and appeals may originate from within or outside GTAA. They may be made by personnel, clients or third parties.

Policy to resolve complaints and appeals

GTAA requires its partners and staff to deal appropriately with:

• Complaints and appeals that the work performed by GTAA fails to comply with professional standards and applicable legal and regulatory requirements; and
• Complaints or appeals of non-compliance with GTAA’s system of quality control.

Communication channels to resolve complaints and appeals

If the complaint or appeal involves a member of the engagement team, GTAA requires it to be raised with a partner outside that team who will take responsibility for investigating the complaint or appeal. GTAA requires this partner to be the head of the respective service line, unless the complaint concerned that individual, in which case GTAA requires the complaint to be raised with the managing partner.

If a complaint/appeal is received, GTAA requires the individual receiving the complaint or appeal to contact GTAA's managing partner.

Policy to investigate and resolve complaints and appeals

GTAA requires the head of the respective service line, or if the complaint/appeal concerned that individual, the managing partner, to supervise an investigation into each complaint and appeal received, to identify whether the complaint or appeal indicates deficiencies in the design or operation of GTAA’s quality control policies and procedures, or non-compliance with GTAA’s system of quality control by an individual or individuals.

GTAA considers that the head of the respective service line, or if the complaint/appeal concerned that individual, the managing partner has sufficient and appropriate experience and the necessary authority within GTAA in order to supervise these investigations.

In circumstances where it is not practicable for the partner supervising the investigation not to be involved in the engagement, GTAA may use the services of a suitably qualified external person or another firm to carry out the investigation into complaints and appeals.

In those situations, in which the results of the investigations indicate deficiencies in the design or operation of GTAA’s quality control policies and procedures, or non-compliance with GTAA’s system of quality control by an individual or individuals, GTAA requires appropriate remedial actions.

If the complaint or appeal is serious or cannot be resolved by the process above, it will need to be referred to GTAA's legal counsel. External advice can also be sought, as needed.

All complaints received should be recorded in a complaints register together with the resolution thereof.

Procedure about handling complaints

Complaints must be submitted in writing to GTAA, whether by postal mail or e-mail. The complainant shall include in his/her complaint:

• His/her identification (first name, name, address and other contact details).
• A detailed description of the circumstances underlying the complaint.

There may be exceptional circumstances where an individual may want to make an anonymous report. In which case GTAA will need enough information to investigate the matter.

GTAA will, upon receipt of a complaint, register this in the complaint register. GTAA will, within 10 business days, acknowledge receipt and due consideration of the complaint by sending a confirmation letter or e-mail.

The findings of this investigation will be reported to the managing partner within a four-week timeframe.

The findings in the report will be used to inform the development of any potential recovery or remedial corrective actions.

GTAA will propose a solution to the complainant no later than four weeks after having sent confirmation of receipt. GTAA reserves the right to extent the time for solving the complaint, if the issue at stake is complex. GTAA will duly inform the complainant for the extension and provide an approximate time estimate for the expected resolution.

In those cases where the proposed solution above does not lead to an acceptable resolution or if the presented procedure is unacceptable for the complainant or other parties involved, the complainant will be given the option to initiate an appeal.

GTAA will maintain files and records of all complaints relating to the certification process, as well as any corrective actions taken. This will be used, amongst other things, for analysis purposes during management reviews.

Procedure about handling appeals

Upon receiving an unsatisfactory resolution of a complaint, a complainant may submit an appeal.

Handling of an appeal follows the same formalities in terms of submission, registration and acknowledgement as with respect to complaints, safe for appeals cannot be made anonymously.

GTAA will consider appeals with an internal panel composed of at least two partners and the ethics leader of GTAA.

GTAA will propose a solution to the appellant no later than four weeks after having sent confirmation of receipt. GTAA will duly inform the appellant for the extension and provide an approximate time estimate for the expected resolution.

Where the appeal handling does not result in a satisfactory answer within a reasonable timeframe, the appellant may notify the Commission Nationale pour la Protection des Données (CNPD) in Luxembourg within one year of filing the initial complaint.

GTAA will maintain files and records of all appeals relating to the certification process, as well as any corrective actions taken. This will be used, amongst other things, for analysis purposes during management reviews.

Any questions with respect to this procedure should be addressed to: gdpr.carpa@lu.gt.com