Objective
Ensure each complaint is investigated impartially, proportionately and on a complete, preserved evidential record, in accordance with section 8 (Investigation Process) of the approved Client Complaints Handling Manual.
Control Activity
The assigned investigator defines the issues, gathers relevant records and statements, considers both supporting and contradictory evidence, documents findings against applicable obligations and protects confidentiality. The complaint owner reviews the file for completeness, impartiality and preservation before a final response is authorized. Complaint records are retained for at least ten years after resolution.
Specifically, the control verifies that:
- The Complaints Officer conducts an impartial and thorough investigation.
- All relevant evidence, documentation, and witness statements are collected and reviewed.
- Relevant internal teams (Compliance, Finance, IT) or external experts are engaged where necessary.
- Confidentiality is ensured at all times, protecting personal data and sensitive information.
- All steps taken are documented to create a clear audit trail.
- Complaint records are retained for at least 10 years after resolution.
Evidence
- Expected evidence: Investigation plan and issue statement
- Expected evidence: Collected evidence, documentation, and witness statements
- Expected evidence: Engagement records for relevant internal teams (Compliance, Finance, IT) and external experts
- Expected evidence: Interview notes and analysis
- Expected evidence: Complete audit trail documenting all investigation steps taken
- Expected evidence: Findings and independent completeness review
- Expected evidence: Confidentiality and personal-data protection confirmation
- Expected evidence: Ten-year retention record
- Evidence location: source evidence in SYS-ECM-002 Compliance Reporting and Evidence Repository; target Hermes assessment record in Odoo under ISS-HERMES-001.
- Retention: according to the applicable approved policy and Bitkaya record-retention requirements.
- Testing method: sample closed complaint files and verify evidence lineage, balanced analysis, engagement of internal teams/external experts, confidentiality safeguards, complete audit trail, and 10-year retention
- Testing frequency: per complaint with periodic quality review
Relationships
- Policy: POL-COMP-001 Client Complaints Handling Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Procedure: PROC-COMP-004 Investigate Complaints and Preserve Evidence
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Design status: implemented
History
- 2026-07-28: Enriched verification requirements with full details from PDF section 8 (impartial investigation, evidence/witness collection, internal team engagement, confidentiality, audit trail, 10-year retention).
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.
- 2026-07-26: Created from the approved COMP Manual.