Grievance Redressal

Policy Usage Guide

This section explains the structure of the policy document and the purpose of the same is to enable easy navigation and understanding of the contents of the document by various stakeholders. The Policy is organized in the following sections:

Regulatory reference

This section outlines the list of applicable regulations to the current policy document. The name of regulation issued by various regulators along with the date and reference number will be listed under this section. The purpose of the same is to enable various stakeholders in identification of applicable regulations for the policy and act as a ready reference for the regulations.

Key stakeholders and roles

Under this section, a list of all the key stakeholders involved in the design, review, approval and implementation of the policy are identified and the major roles to be performed by them are listed. This section enables various stakeholders in understanding their respective roles with regard to the current policy document.

Policy content

This section contains various aspects of the policy design and implementation as per the applicable regulatory guidelines. This section outlines the action required by various stakeholders of the Bank in ensuring implementation of the policy.

Regulatory Reference

The following key regulation is applicable to the current policy document.

• Regulator - RBI
• Regulation Name - Guidelines on Regulation of Payment Aggregators and Payment Gateways
• Regulation Date - March 17, 2020
• Regulation code - RBI/DPSS/2019-20/174DPSS.CO.PD.No.1810/02.14.008/2019-20

Key Stakeholders and Roles

Matters relating to customer service are deliberated / reviewed / monitored by an Executive Committee and are reported to the Board to ensure that the instructions are implemented meaningfully. Commitment to hassle-free service to the customer at large and the Common Person in particular under the oversight of the Board will is the important purpose of this policy and NDML Payment Aggregator business.

Executive Committee on Customer Service

The Executive Committee on Customer Service would be chaired by NDML MD & CEO. The Committee would have the following functions:

1. Develop and monitor important metrics for evaluation of systemic performance and operational effectiveness which are essential for understanding the Customer Satisfaction;

2. Collect and Evaluate feedback on quality of customer service received from various quarters.

3. Ensure that all regulatory instructions regarding customer service are followed by NDML. To achieve this, the committee would obtain necessary feedback from the respective functional heads and systems.

4. Formulate and review the policies / procedures / systems which are needed to give effect to the intent of this policy, regulatory requirement so as to ensure regulatory / contractual compliances and customer satisfaction.

5. Review unresolved complaints/grievances referred to it by functional heads responsible for redressal and provide their advice.

6. Submit reports on performance to the Audit Committee at quarterly intervals.

7. Review the cases of non-compliance with the provisions of the code, including the complaints which are not redressed within the time-frame stipulated in this policy.

Customer is responsible at all times to ensure the security and safety of its payment credentials such as card details, CVV, OTP, User ID, Passwords and channels of accessing such information i.e. email accounts and mobile. NDML shall rely completely on information submitted electronically and payment status received from the banking system for determining the transaction status.

Audit Committee of the Board

1. The Audit Committee of the Board would be responsible for review / approval of policies in regard to improving customer services. The Committee would also examine issues having a bearing on the quality of customer service rendered by NDML.

2. The Committee would receive and review the reports of executive committee and auditors on various aspects relating to customer service.

3. This Committee would also review the functioning of the Executive Committee on Customer Service.

4. The Committee would advise implementation of procedures / practices / actions where it is of the view that such changes are necessary to improve system transparency and customer responsiveness / satisfaction.

Nodal Officer to handle complaints and Grievances

NDML shall appoint a Nodal Officer who shall be responsible for the implementation of customer service and complaint handling for the Payment Aggregator Business. Nodal Officer would also monitor handling of complaints / grievances. Nodal officer would be responsible for ensuring proper redressal of the complaints by concerned functional / technical teams and reporting to all regulatory interfaces.

Policy Content

4.1Board approved policies on Customer Service

For NDML, customer service & satisfaction is a priority objective. NDML will have Board approved / monitored policies for Merchant Onboarding, Customer Service & Grievance Redressal Policy, Privacy policy, Information Security and IT Policy.

These policies will be aligned to regulatory guidance / contractual terms / network / bank rules from time to time.

Customer Awareness of NDML Policies

NDML will ensure that Merchants / Customers are made aware of the above policies by placing them prominently on the web-site and other customer interface channels. The Merchant / customers would be encouraged to refer to these policies and understand the same. Further, NDML will take necessary steps to keep the Merchants / customers duly informed of the changes in the policies formulated by it from time to time.

As far as feasible, digital / online interfaces will provide information to the customers for direct access to published information relating to:

• Policies;
• Procedures;
• Application Forms & Documents;
• Agreement Formats;
• FAQs on various subjects / areas;
• SLAs for processing of transactions of different types;
• Charges applicable for various transactions;
• Query / Grievance Redressal mechanism deployed;
• Status of transactions / Query / Grievance;
• Working Schedules;
• Contacts and Escalation Matrix;
• Details of Nodal Officer;
• Details of regulatory bodies that can be approached in case of failure of NDML to solve the Grievance;

4.2 Merchant Onboarding

Application and MID issuance

NDML will assist the merchants in queries / complaints that merchant raises relating to NDML processes for:

As far as feasible, digital / online interfaces will provide information to the customers for direct access to published information relating to:

• Filling of Onboarding forms by the merchants for processing
• Validation of the details in the forms and KYC documents attached and shared by Merchants and assist merchants in providing the correction information / KYC documents
• NDML team can assist the merchants is knowing the status of application processing and information about any discrepancies when approaches the customer services section.
• NDML shall assist and resolve queries raised on Legal Agreements by the merchants.
• Following disclosures shall be made available to merchants through its websites / mobile app by NDML
• The terms and conditions governing merchant relationship with NDML in clear and simple language that can be easily understood by the merchant.
• Merchants shall be made aware of key contacts for query / complaint resolution, through information displayed prominently.

4.3 Transaction Processing

NDML shall assist the merchants / customers in the following:

• Address & resolve technical issues faced in integration & Transaction processing;
• Knowing the current status of the transaction as and when contacted at the support desk;
• Knowing the current status of the payout / settlement of amounts as and when contacted at the support desk;
• Guiding on the charges & taxes levied while transaction processing;
• Guiding on exception handling process;
• Any other associated / incidental matters within the operational domain of NDML;

4.4 Disputes / Chargebacks & Refund Processing

N Disputes / Chargeback arises when one or both parties in a transaction disagree with the transaction’s outcome. NDML is committed to ensuring that consumers are treated fairly by merchants. This policy shall protect consumers against invalid transactions and dishonest merchants.

a. Customer Transactions

• Consumers will initiate disputes with its issuing bank, details of this which will be shared by the Acquiring bank / Processor with NDML through proper channels for review and providing necessary documentations proving the genuinity of the transactions;
• These details shall be sent by NDML to Merchant and demand for a copy request / payment / invoice details against which the customer has availed for services;
• Disputes / Chargeback can be grouped into the following four categories:
  1. Technical issues with payment transactions
  2. Processing errors, e.g., duplicate transactions or incorrect billing
  3. Quality issues, e.g., product or service does not meet customer expectations, or customer has not received goods or services
  4. Fraudulent transactions

Accordingly, charge-back requests will be received and processed as per process prescribed by banks / network associations.

b. Merchant Transactions & Other queries

• Queries on Transaction status
• Merchant queries / disputes on the payout / settlement amount credited to their bank account
• Queries on Refunds initiated & processed
• Queries on MDR and taxes levied while transaction or settlements
• Other Queries
• On payment methods activated or requests on addition or deactivation of payment methods
• Procedure to know about the adding / modifying / deleting of Bank account for settlement
• Changing of profile / contact details
• Activation of other products like Invoice based payments, ECS/SI/eNACH
• Errors faced in transaction processing in test and live environment.

c. Refund Processing

• Refunds requests will be received in following 2 cases;
• Dispute / Chargeback documents not provided by Merchant and hence refund processed in customers account
• Customer has raised a request to Merchant to initiate refund due to product / services not delivered, duplicate payments, Etc.
• In such cases Refunds shall be processed as per TAT outlined in the RBI guidelines (RBI/2019-20/67 DPSS.CO.PD No.629/02.01.014/2019-20)

Case Opening, Log, and Categorization

When a query / grievance / dispute/ technical issue is raised by a customer, NDML within its records shall open a new case, log the case category on the basis of the issue type, and define the level of input required for resolution. This categorization and definition will enable NDML to set reasonable SLAs, track towards a timeline for resolution, and delegate initial responsibility for further investigation.

All responses received from involved stakeholders shall be tagged in accordance with the case number and categorization.

Data Requirements for Query / Grievance

Customers / Merchants must provide specific data points to NDML to check the transactions when approached at it service desk.

Customer
1. Full Name
2. Query / Grievance details
3. Transaction type, date, amount, and reference number
4. Merchant details
5. Earlier dispute reference number in case of raising the chargeback
6. Category of dispute/chargeback
7. Related Transaction invoice / bill copy
8. Any specific dispute information
9. Expected Resolution
Merchant
1. Merchant ID
2. Query / Grievance details
3. Transaction type, date, amount, and reference number
4. Earlier query / dispute reference number
5. Any specific query / dispute information
6. Expected Resolution

NDML shall keep a track of all queries / grievances / disputes / chargebacks received along with the details of responses sent and cases resolved. For ongoing / pending cases necessary follow up shall be done by NDML team until closure. Excel / Online records will be maintained along-with details of emails and other communications received.

Customer / Merchant Communications

A case id shall be created and shared with the customer / merchant for future reference. NDML shall determine the resolution time frame based on the type of dispute or chargeback. NDML Operations team shall track responses and timeframes.

Address / Helpline Number of NDML on its websites / emails

NDML will ensure that full address / helpline number of the Payment Aggregator Business is invariably mentioned in the websites and emails sent to customers / merchants. Further details of escalation matrix will also be published appropriately.

TAT for Compliant resolution - Time limit

NDML will make sure that:

• The time limit for resolution / response of customer complaints by NDML is 3 working days from the date of receipt of customer complaint. This timeline is applicable to complaints which are regular in nature / where resolution lies within the scope of NDML system or functioning / where no technical development or changes are needed / no legal consultation – reference is needed / where mentioned transactions are within active transaction database and are not archived / where no external information is needed. For other category of complaints, time-frame will be determined by service team and appropriate response will be provided within 7 working days and resolution will be provided in due course. Accordingly, failure to resolve / respond to the customer’s complaint within 7 working days of receipt of the complaint shall be escalated to the Customer service committee within NDML for further guidance & review.
• If any case needs additional time, NDML will inform the customer/regulator the reasons of delay in resolution and provide expected time lines for resolution of the issue
• Electronic record of all complaints will be maintained and will be monitored by service team and Nodal Officer.
• Customer grievance data will be analysed to improve system functioning, business processes or related matters.

4.5 Service at the contact centers / helpdesk

Working hours / working days of helpdesk

• NDML PA Helpdesk will normally function for public transactions at least for 8 hours on week days for five days a week subject to NDML holidays.
• NDML will provide access to customers / merchants for contacting through digital channels like email, web-forms, calling.

If any of the systems / services which are required by merchants for availing services are under planned maintenance, NDML will give advance intimation of atleast 24 hours to the affected merchants through Emails.

Commencement / Extension of working hours

Commencement of employees’ working hours 15 minutes before commencement of business hours will be made operative by NDML at contact centres / helpdesk. The managers and other supervising officials will, however, ensure that the members of the staff are available at their respective desk right from the commencement of working hours and throughout the prescribed business hours so that there may not be any grounds for customers to make complaints.

4.6 Guidance to customers and Disclosure of Information

Display of time norms

Time norms will be displayed predominantly in the website, mobile site and branches.

Website/Mobile App: The detailed information will also be made available on the NDML’s web-site. NDML will ensure that the customers / merchants are able to easily access the relevant information from the Home Page of the NDML’s web-sites.

NDML would display information on public grievance redressal mechanism service, services offered, product information, time norms for contacting helpdesk.

Other issues: NDML will display promotional and product information while ensuring that the mandatory displays will not be obstructed in anyway. As customer / Merchant Query/Compliant/Feedback is to be achieved by the mandatory display requirements, they will also be given priority over the other display boards. Information relating to Government sponsored schemes as applicable will be displayed according to their applicability.

Display of information relating to PG Charges / MDR / Convenience Charges + GST

NDML would devise a format for display of information relating to PG charges/MDR/Convenience Charges + GST which would enable the customer / Merchant to obtain the desired information at a quick glance. NDML will also ensure that only latest updated information in the above format is placed on their web-sites and mobile app/mobile website and the same is easily accessible from the Home Page of web-sites/mobile app/mobile website.

Disclosure of Information by NDML in the public domain

NDML will disclose the information on products and services on its websites which is found to be an effective channel for reaching out to customers and the public at large. -

I. Policy / Guidelines
• (i) Merchant Onboarding Policy
• (ii) Privacy Policy
• (iii) Terms and Conditions
II. Complaints
• (i) Customer Grievance Policy & Grievance Redressal Mechanism
• (ii) Information relating to Nodal Officer
III. Office Address & Location
• (i) Details of NDML Office along with addresses and Helpline numbers (with search engine for queries relating to Payment Aggregator business)

4.7 Providing facilities to persons with disabilities

Guidelines framed by IBA based on the judgment of Chief Commissioner for Persons with Disabilities

Indian Bank' Association has framed operational guidelines for implementation of its member bank on providing facilities to persons with disabilities. NDML will adopt / follow the operational guidelines to the extent feasible / applicable.

Dealing with Complaints and Improving Customer Relations

• First Point of contact – Call Centre, Email, Digital Complaint form
• If complaint not resolved within time limit informed to the Customer – Customer can contact Nodal Officer
• If Complaint not resolved by Nodal Officer within 15 working days of reference to Nodal Officer – Customer can contact Standing Committee
• If Complaint not resolved within a month at level a,b and c – Customer can contact Banking Ombudsman as per the details mentioned on the NDML website.

Complaints/suggestions box

Complaints/suggestions box or Complaint/Suggestion portal may be provided at each office/branch of NDML.

Analysis and Disclosure of complaints

NDML will place a statement of complaints before its Audit Committee / Board along with an analysis of the complaints received. The complaints will be analyzed

• To identify customer service areas in which the complaints are frequently received;
• To identify frequent sources of complaint;
• To identify systemic deficiencies; and
• For initiating appropriate action to make the grievance redressal mechanism more effective.
• Complaints which could not be resolved in a time-bound manner and reasons thereof;
• Complaints which could not be resolved according to customer satisfaction and reasons thereof;
• Complaints received from regulatory channels and their status;

Further, NDML will ensure to disclose the following brief details along with their financial results:

A. Customer / Merchant Complaints
1. No. of complaints pending at the beginning of the year
2. No. of complaints received during the year
3. No. of complaints redressed during the year
4. No. of complaints pending at the end of the year
B. Awards passed by the Banking Ombudsman
1. No. of unimplemented Awards at the beginning of the year
2. No. of Awards passed by the Banking Ombudsmen during the year
3. No. of Awards implemented during the year
4. No. of unimplemented Awards at the end of the year

Erroneous Debits arising on fraudulent or other transactions

Vigilance by NDML

NDML will ensure to adhere to the guidelines and procedures for ensuring that such merchants are not on-boarded who intend to use the system as conduit for fraud. If regular complaints are received against some merchants, they will be evaluated again even after on-boarding.

Compensating the customer / merchants

NDML will take action on matters after necessary review / investigation to identify its responsibility and liability. Therefore, (i) In case of any fraud, if NDML is convinced that an irregularity / fraud has been committed by its staff towards any constituent, NDML will examine its liability and acknowledge the just claim.

4.9 Various Working Groups / Committees on Customer Service in NDML - Implementation of the Recommendations

In order to measure the progress achieved by NDML in implementation of the recommendations of various working groups/Committees on customer service, NDML will examine the recommendations which have relevance in the present day and continue to implement them. NDML will consider submitting periodically to their Customer Service Committee of the Board a progress report on the steps/ measures taken in this regard.

NDML will also subject the Customer Service function to audit by external professional audit agency.

4.10 Details of Grievance and Nodal Officer

Name of Grievance Officer: Ms. Tejal Baniya
surepaygrievance@nsdl.com

Name of Nodal Officer: Ms. Nehal Thaker
ndml.nodalofficer@nsdl.com

NSDL DATABASE MANAGEMENT LIMITED

Address: NSDL Database Management Limited (NDML), 4th Floor, Tower 3, One International Center, Senapati Bapat Marg, Prabhadevi, Mumbai - 400 013.