Purpose
Use complaint information to identify systemic risk, report performance, improve controls and maintain proportionate capability, as mandated by sections 10 (Internal Follow-Up and Reporting), 13 (Continuous Improvement) and 14 (Proportionality and Scalability) of the approved Client Complaints Handling Manual.
Reporting and Continuous Improvement Requirements
Complaints data is regularly analyzed to identify root causes, trends, and systemic issues. Senior management reviews findings at least every 6 months, with minutes recorded. Reports include complaint volumes, categories, resolution timelines, and root-cause analysis. Escalated complaints and recurring issues are reviewed at management level. Corrective actions are implemented promptly and tracked for completion. Insights from complaints are integrated into risk management processes, staff training programs, and service and product development. Bitkaya applies the principle of proportionality, ensuring procedures are effective, efficient, and aligned with the company’s size, complexity, and risk profile.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Analyze complaint data regularly | Identify root causes, trends, and systemic issues. | Trend analysis output |
| 2 | Prepare management reports | Include complaint volumes, categories, resolution timelines, and root-cause analysis. | Management report |
| 3 | Hold senior management reviews | At least every 6 months, with minutes recorded. | Management review minutes |
| 4 | Provide complaints data to the CBCS upon request | Ensure full regulatory transparency. | CBCS data response record |
| 5 | Review escalated and recurring complaints | Review escalated complaints and recurring issues at management level. | Management review minutes |
| 6 | Implement and track corrective actions | Implement corrective actions promptly and track them for completion. | Corrective-action tracker |
| 7 | Integrate insights from complaints | Into risk management processes, staff training programs, and service and product development. | Integration record |
| 8 | Assign corrective actions and verify closure | Assign corrective actions, owners, and deadlines and verify closure and effectiveness. | Corrective-action tracker |
| 9 | Review proportionality and scalability | Structure: single designated Complaints Officer (may be combined with other compliance duties, provided independence and impartiality are maintained). Documentation: centralized digital register suited to current scale (e.g., secure Excel-based or cloud database); automation and reporting expand as volumes increase. Reporting and Review: semi-annual internal reviews with ad-hoc reviews if trends or high-risk complaints are identified; frequency scales with client base. Resources: periodic staff awareness and training without excessive administrative burden. Scalability: policy framework, systems, and templates designed for gradual expansion to higher volumes, new jurisdictions, or additional regulatory requirements. | Proportionality review record |
| 10 | Update policy and procedures after material findings or change | Ensure regulatory compliance, operational efficiency, and continuous improvement while maintaining the flexibility expected of a small but growing VASP. | Updated policy / procedure record |
Records
- Complaint metrics and trend analysis (volumes, categories, resolution timelines, root-cause analysis)
- Semi-annual management review minutes and decisions
- Root-cause and systemic-issue records
- Corrective actions implemented, tracked for completion, with closure evidence
- Training, corrective action, and effectiveness evidence
- Integration of insights into risk management, staff training, and service/product development
- Proportionality and scalability review (structure, documentation, reporting, resources, scalability)
- CBCS data requests and responses
- Policy and procedure updates after material findings or change
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-COMP-007 Ensure Complaint Trends Reporting Training and Improvement Are Maintained
History
- 2026-07-28: Enriched with full operational details from PDF sections 10, 13, 14 (root-cause analysis, 6-month review, corrective actions, integration into risk/training/products, proportionality aspects).
- 2026-07-26: Created from sections 10, 13 and 14 of the approved COMP Manual.