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Data Complaints Procedure Policy

Titon Hardware Limited


1. Purpose


Titon Hardware Ltd is committed to handling personal information fairly, lawfully, and transparently. This procedure explains how individuals can raise concerns or complaints regarding how Titon handles personal data and how Titon will investigate and respond to those complaints.

This procedure is intended to ensure compliance with applicable UK data protection legislation, including the UK GDPR, Data Protection Act 2018, and the requirements introduced under the Data (Use and Access) Act.

 

2. Scope

This procedure applies to complaints relating to Titon Hardware Ltd’s handling of personal data, including concerns about:

  • How personal information has been collected, used, stored, shared, retained or deleted;

  • Responses to data subject rights requests (including subject access requests, rectification, erasure, restriction or objection requests);

  • Data accuracy concerns;

  • Information security or confidentiality issues;

  • Personal data breaches involving an individual’s information; or

  • Any other concern regarding Titon Hardware Ltd’s compliance with data protection law.

This procedure applies to complaints made by:

  • Customers;

  • Employees and former employees;

  • Suppliers and contractors;

  • Website users; and

  • Any other individual whose personal data is processed by Titon.

 

3. How to Make a Data Protection Complaint

Individuals may submit a data protection complaint using any of the following methods:

Email: carolyn.isom@titon.co.uk
Post: 894 The Crescent, Colchester CO4 9YQ
Telephone: 01206 713800
Website Contact Form: www.titon.com/contact


Complaints may be submitted verbally or in writing.

To help us investigate efficiently, complainants are encouraged to include:

  • Name and contact details;

  • A description of the concern or issue;

  • Relevant dates or correspondence;

  • Details of the outcome sought; and

  • Any supporting information.


Individuals do not need to use legal language or refer to specific legislation when making a complaint.

 

4. Receipt and Acknowledgement of Complaints

Titon Hardware Ltd will acknowledge receipt of all data protection complaints within 30 calendar days of receipt.

The acknowledgement will normally:

  • Confirm receipt of the complaint;

  • Explain that the matter is under review;

  • Provide a contact point for further communication; and

  • Request any additional information if necessary to understand the complaint.

Where appropriate, Titon Hardware Ltd will communicate using the complainant’s preferred method of contact.

 

5. Investigation Process

Titon Hardware Ltd will investigate complaints without undue delay and take appropriate and proportionate steps to understand and resolve the matter.

The investigation may include:

  • Reviewing relevant systems, records and correspondence;

  • Speaking with relevant employees or departments;

  • Assessing whether Titon Hardware Ltd policies, procedures and legal obligations have been followed;

  • Requesting further clarification from the complainant where necessary; and

  • Considering whether remedial actions are required.


Titon Hardware Ltd’s obligation to investigate begins when the complaint is received and is not dependent on the acknowledgement period.

 

6. Communication During the Investigation

Titon Hardware Ltd will keep complainants informed of progress where appropriate.

Where investigations take longer than anticipated, Titon Hardware Ltd will provide updates explaining:

  • The status of the investigation;

  • Any additional steps being taken; and

  • Expected next steps or timeframes where possible.

 

7. Complaint Outcomes

Titon Hardware Ltd will provide the complainant with the outcome of the complaint without undue delay following completion of the investigation.

The outcome response may include:

  • Findings from the investigation;

  • An explanation of Titon Hardware Ltd’s position;

  • Any corrective actions taken;

  • Changes to systems, processes or practices (where relevant);

  • An apology where appropriate; and/or

  • Information about further rights of escalation.


Where Titon Hardware Ltd concludes it has complied with data protection law, the response will explain the basis for that conclusion.

 

8. Escalation to the Information Commissioner’s Office (ICO)

If a complainant remains dissatisfied with Titon Hardware Ltd’s response, they may raise concerns with the UK Information Commissioner’s Office (ICO).

Further information is available from the ICO website:

Information Commissioner’s Office (ICO) – Complaints Guidance

Titon encourages complainants to allow us the opportunity to investigate and resolve concerns before contacting the ICO.

 

9. Record Keeping

Titon Hardware Ltd will maintain records of data protection complaints, including:Date received;

  • Nature of the complaint;

  • Actions taken;

  • Communications sent;

  • Outcome reached; and

  • Lessons learned or corrective actions implemented.


Complaint records will be retained in accordance with Titon Hardware Ltd’s retention policies and data protection requirements.

 

10. Training and Awareness

Relevant employees will receive appropriate training to recognise, escalate and support the handling of data protection complaints.

Managers and staff responsible for handling complaints must ensure concerns are identified promptly and referred to the appropriate contact.

 

11. Review of this Procedure

This procedure will be reviewed periodically and updated to reflect legal, regulatory, or operational changes.


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