Section 11(1)(e) of the Recall Notice requires Suppliers to track and keep records of complaints from consumers relating to vehicles they supplied fitted with an Affected Takata Airbag Inflator (ATAI), or in relation to the Supplier’s recall campaign, identified by issue and by location (State or Territory), and with information on how each complaint has been managed.
Consumer complaints may come from a range of different sources including dealers, call centres, formal dispute resolution mechanisms, webforms, emails, letters, staff members, media and online forums, referrals from industry associations and government agencies.
Suppliers are required to provide consumer complaint data in Part 2 of the Quarterly Report.
All complaints in relation to an ATAI or your Takata recall campaign must be included.
General enquiries in relation to an ATAI or your Takata recall campaign are not required and should not be included as a complaint. For example, you do not need to include general enquiries about whether a vehicle is affected, the timing of replacement or arranging a replacement airbag where the consumer has been appropriately advised.
It would assist if you are able to categorise complaints you receive by type of issue (select all that apply) in the ’briefly summarise the content of the complaint’ section of the consumer complaints table:
- alpha inflators
- transport (hire/loan car, transport costs, other transport)
- special circumstances (for example, any towing, hire/loan car, transport costs, technician)
- communications or information (including communication or information that is incorrect, incomplete or inconsistent with the requirements of the Recall Notice)
- costs of replacement
- damage associated with the replacement
- replacement airbag inflators (for example, for grey importers/RAWS participants, private importers, orphan vehicles)
- purchased vehicles (consumer not provided with information in according with Recall Notice when purchasing vehicle subject to recall)
- consumer guarantee complaints
- injury or death
- other aspects of recall or replacement process
The Recall Notice (at section 10) requires Suppliers to use best endeavours to have a consumer dispute resolution system consistent with AS/NZS 10002:2014 Guidelines for complaint management in organisations. Your management and collection of consumer complaints data is a part of this.
Proper consumer complaints management is critical and, in addition to categorising the complaint type, it is good record keeping practice and due diligence for Suppliers to collect and record the following information regarding each consumer complaint:
- confirm consumer consent to have their personal details shared with the ACCC and other relevant regulators/agencies as appropriate.
- steps the consumer has taken to resolve their concerns in addition to contacting the Supplier
- other agencies the consumer has reported their concerns to
- details of the dealer that the consumer has been talking to, including the name of the dealer and wherever possible the name of the dealer’s representative
- whether the Supplier has contacted the dealer as part of their steps to resolve the issue and concerns raised by the consumer
- status of the complaint, for example, whether it is resolved or outstanding, pending further information, or escalated to a formal dispute resolution process.
The following document provides an illustrative example of how the consumer complaint data may be presented to assist in consistent reporting: