1. 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:
1.1 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.
1.2 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.
1.3 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 NDML Payment Aggregator [NDML PA] in ensuring implementation of the policy.
2. Regulatory Reference
The following RBI regulations are applicable to the current policy.
- Guidelines on Regulation of Payment Aggregators and Payment Gateways (RBI/DPSS/2019-20/174 DPSS.CO.PD.No.1810/02.14.008/2019- 20 dated March 17, 2020.)
- Harmonisation of Turn Around Time (TAT) and customer compensation for failed transactions using authorised Payment Systems (DPSS.CO.PD No.629/02.01.014/2019-20 dated September 20, 2019.)
- RBI Integrated Ombudsman scheme, 2021 (RBI Integrated Ombudsman scheme, 2021.)
3. Key Stakeholders and Roles
Matters relating to customer service and grievances are deliberated / reviewed / monitored by a Grievance Review Committee and are presented to the Board on a quarterly basis 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 is the important purpose of this policy and NDML Payment Aggregator business. This policy is designed towards Customers using NDML Payment Aggregator platform and making payments to merchants.
3.1 Role of Board
1. Board will review and approve the Customer Service, Grievance Redressal and Dispute Resolution Mechanism Policy and appointment of Grievance Review Committee.
2. Board will set in place high standards of customer service and satisfaction as a benchmark for assurance by NDML PA.
3. Board will make available adequate operational and systemic resources for implementation of Grievance and Dispute Resolution Policy and effective functioning of Grievance Resolution Framework.
4. Board will provide for annual review of the Customer Service, Grievance Redressal and Dispute Resolution Mechanism Policy and effective functioning of Grievance Review Committee and Grievance Resolution Framework.
5. Board will ensure implementation of Regulatory Directions.
6. Board will ensure audit of the implementation of Customer Service, Grievance Redressal and Dispute Resolution Mechanism Policy.
3.2 Role of Grievance Review Committee on Customer Service
The Grievance Review Committee on Customer Service would be chaired by NDML MD & CEO and would mandatorily include Head of Operations, Head of IT, Nodal Officer and Grievance Officer as members. 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
a) proactively ensuring customer satisfaction;
b) reducing customer queries & grievances;
2. Collect and evaluate periodic feedback on quality of customer service provided by NDML PA.
3. Ensure that all regulatory instructions regarding customer service are followed by NDML. To achieve this, the committee would obtain necessary feedback / update from the respective functional heads and systems.
4. Formulate and review the SoPs / 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. Ensure that adequate information is made available to the customers regarding grievance handling mechanism, escalation mechanism and policy in this regard;
6. Ensure that convenient and well accessible channels for lodging grievances are made available to customers across variety of channels to support customer needs;
7. Review effectiveness of complaints/grievances review, response and resolution mechanism include resolution TAT and bring improvements to enhance customer satisfaction.
8. Review escalations / delays, if any and take systemic steps to ensure resolution of the same and avoidance of need to escalate in future;
9. Submit reports on performance to the Board at quarterly intervals.
10. Review the cases of non-compliance with the provisions of the policy, including the complaints which are not redressed within the time-frame stipulated in this policy. The Committee shall meet at-least twice a year.
3.3 Executive Team for Grievances Resolution & Dispute Management
NDML shall appoint a Nodal Officer who shall be responsible for regulatory and customer grievance handling functions. Nodal Officer would monitor handling of complaints / grievances. NDML shall appoint a Grievance Officer for ensuring effective implementation of the SoPs created by Grievance Review Committee and meeting customer satisfaction. Grievance officer shall report to Head of Operations and Nodal Officer and work closely under their guidance for effective implementation.
Nodal officer would be responsible for ensuring proper redressal of the complaints by grievance officer in co-ordination with concerned functional / technical teams and reporting to all regulatory interfaces.
The name of Nodal Officer and Grievance Officer is placed as Annexure I.
4. Customer Service
For NDML, customer service & satisfaction is a priority objective and will strive at all times to achieve high customer satisfaction and continuously improve the same. NDML will also put in place metrices to measure its effectiveness towards customer service and grievance resolution.
4.1 Customer Awareness of NDML Policies
NDML will ensure that Customers are made aware of the its policies (Information Security, Privacy, Grievance Handling) by placing them prominently on its web-site and other customer interface channels. The customers would be encouraged to refer to these policies and understand the same. Further, NDML will take necessary steps to keep the 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:
4.2 Transaction Processing
NDML shall assist the customers in the following:
1. Address & resolve technical issues faced in integration & Transaction processing;
2. Knowing the current status of the transaction;
3. Status of product / service delivery by the merchant;
4. Grievance related to product / service delivery by the merchant;
5. Erroneous / multiple payments made;
6. Knowing the current status of the refund request;
7. Guiding on the charges & taxes levied while transaction processing;
8. Guiding on exception handling process;
9. Any other associated / incidental matters within the operational domain of NDML;
4.3 Disputes / Chargebacks
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 support consumers against invalid transactions and dishonest merchants.
1. 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;
2. 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; NDML will follow-up with the merchant for resolution of the same.
Charge-back requests will be received and processed as per process and timelines as prescribed by banks / network associations.
NDML will also monitor the charge back requests against the merchants as per the “excessive charge-back norms” and engage with merchants to reduce such scenarios or take action if such scenario continues.
4.4 Refund Processing
1. Refunds requests will be received in following 2 cases;
a. Customer Transactions
a. Dispute / Chargeback documents not provided by Merchant and hence refund processed in customer’s account.
b. Customer has raised a request to Merchant to initiate refund due to product / services not delivered, duplicate payments, Etc.
2. In such cases Refunds shall be processed as per TAT outlined in the Circular DPSS.CO.PD No.629/02.01.014/2019-20 on “Harmonisation of Turn Around Time (TAT) dated September 20, 2019 and customer compensation for failed transactions using authorised Payment Systems” included as Annexure II or as updated from time to time.
4.5. 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 and details on the basis of the issue type, and define the input required for resolution and identify responsible teams. This categorization and definition will enable NDML to set reasonable SLAs, track the timeline for resolution, and delegate initial responsibility for further investigation. NDML will acknowledge the receipt of the customer communication and the case number assigned by it and if possible, expected timelines for resolution.
All inputs/ responses received from involved stakeholders shall be tagged in accordance with the case number and categorization.
4.6 Data Requirements for Query / Grievance
Customers may be requested to provide specific data points which may be needed to verify the details and resolve the grievance, these may include:
- Full Name & Contact Details
- Query / Grievance details
- Transaction type, date, amount, and reference number
- Merchant details
- Earlier dispute reference number in case of repeat grievance
- Any specific dispute information
- 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 requisite 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.
4.7 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 including that of RBI Ombudsman.
Address for correspondence/Lodging compliant
NSDL DATABASE MANAGEMENT LIMITED
Address: NSDL Database Management Limited (NDML), 4th Floor, Tower 3, One International Center,
Senapati Bapat Marg, Prabhadevi, Mumbai - 400 013.
Escalation Matrix:
Name: Ms. Tejal Baniya
Responsibility: Grievance Officer
Email id: surepaygrievance@nsdl.com
Name: Escalation 1 - Ms. Nehal Thaker
Responsibility: Nodal Officer
Email id: ndml.nodalofficer@nsdl.com
Name: Escalation 2- RBI Ombudsman scheme
https://cms.rbi.org.in
4.8 TAT for Complaint resolution - Time limit
NDML will make sure that:
1. The time limit for 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. Resolution needs to be ensured in 7 working days.
2. For other category of complaints, timeframe 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 Operations Head & Nodal Officer for further guidance & review.
3. If any case needs additional time, NDML will inform the customer the reasons of delay in resolution and provide expected timelines for resolution of the issue.
4. Electronic record of all complaints will be maintained and will be monitored by Nodal Officer. The records will be maintained for a period of minimum five years.
5. Customer grievance data will be analysed to improve system functioning, business processes or related matters
4.9 Service at the contact centers / helpdesk Working hours / working days of helpdesk
1. 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.
2. NDML will provide access to customers / merchants for contacting through digital channels like email, web-forms, calling in addition to writing letters for reporting their grievance.
3. All the participants of PA ecosystem can adopt the Dispute Resolution mechanism after exhausting the Grievance redressal mechanism as per the terms mentioned in the agreement.
4.10 Guidance to customers and Disclosure of Information Display of time norms
Time norms will be displayed predominantly on the website, mobile site and its branches.
4.11 Display of information by NDML
Website: The detailed information will be made available on the NDML’s website. NDML will ensure that the customers / merchants are able to easily access the relevant information from the Home Page of the NDML’s website. 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.
4.12 Display of information relating to PG Charges / MDR / Convenience Charges + GST
NDML would devise a format for display of information relating to charges payable by customer + GST which would enable the customer to obtain the desired information.
4.13 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. -
1. Policy / Guidelines
a. Merchant Onboarding Policy
b. Privacy Policy
c. Terms and Conditions
2. Complaints
a. Customer Service, Grievance Redressal and Dispute Resolution Mechanism Policy
b. Information relating to Nodal Officer
3. Office Address & Location
Details of NDML Office along with addresses and Helpline numbers (with search engine for queries relating to Payment Aggregator business)
4.14 Dealing with Complaints and Improving Customer Relations Levels of Complaint redressal
1. First Point of contact – Call Centre, Email, Digital Complaint form, Letters Grievance Redressal Officer: surepaygrievance@nsdl.com
2. If complaint is not resolved within time limit informed to the Customer – Customer can contact Nodal Officer
Nodal officer: ndml.nodalofficer@nsdl.com
3. If Complaint not resolved by Nodal Officer within 15 working days of reference to Nodal Officer – Nodal Officer can internally escalate same to Grievance Review Committee.
4. If Complaint not resolved within a month at level 1, 2 and c – Customer/any aggrieved party may also make a compliant to the RBI Ombudsman under the RBI Integrated Ombudsman Scheme, 2021 that includes the purpose of the Ombudsman scheme. The complaint may be lodged online through the portal designed for the purpose at https://cms.rbi.org.in
4.15 Complaints/suggestions box
Complaints/suggestions box or Complaint/Suggestion facility may be provided by NDML.
4.16 Analysis and Disclosure of complaints
NDML will place a statement of analysis of complaints received and their resolution effectiveness before the Board to reflect on:
- Customer service areas in which the complaints are frequently received;
- To identify systemic deficiencies;
- 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.
4.17 Vigilance by NDML
NDML will ensure to adhere to the guidelines and procedures for ensuring that such merchant’s 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.
5. Compensating the customer / merchants
NDML will take action on matters after necessary review / investigation to identify its responsibility and liability. Therefore, 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.
6. Customer Grievance Resolution – Audit
NDML will also subject the Customer Service, Grievance Redressal and Dispute Resolution Mechanism Policy function to audit by external professional audit agency.
7. Review of Policy
The Customer Service, Grievance Redressal and Dispute Resolution Mechanism Policy shall be reviewed as and when required and, in any case, on a yearly basis by the Board of Directors.
Annexure I - Executive Team
Name: Ms. Tejal Baniya
Responsibility: Grievance Officer
Email id: surepaygrievance@nsdl.com
Name: Escalation- Ms. Nehal Thaker
Responsibility: Nodal Officer
Email id: ndml.nodalofficer@nsdl.com
Annexure II - Harmonisation of Turn Around Time (TAT) and customer compensation for failed transactions using authorised Payment Systems
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