KAP Motor Group Acceptable Use Policy

This acceptable use policy sets out the terms between you and us under which you may access our website.

This acceptable use policy applies to all users of, and visitors to, our site. Your use of our site means that you accept, and agree to abide by, all the policies in this acceptable use policy.

KAP Motor Group is the trading name of Kent Auto Panels Ltd, a wholly owned subsidiary of Tudor Holdings (UK) Ltd a company registered in England and Wales. The company number of Kent Auto Panels is 00662809 with its registered office at: Shorncliffe Motor Park, Ross Way, Folkestone, Kent CT20 3UJ (“Registered Office”). VAT number is [336047511] (“VAT Number”).

Prohibited Uses

You may use our site only for lawful purposes.

You may not use our site:

In any way that breaches any applicable local, national or international law or regulation.

In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.

For the purpose of harming or attempting to harm minors in any way.

To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards detailed below.

To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

Not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our terms of website use.

Not to access without authority, interfere with, damage or disrupt:

  • any part of our site;
  • any equipment or network on which our site is stored;
  • any software used in the provision of our site;
  • or any equipment or network or software owned or used by any third party.

Interactive Services

We may from time to time provide interactive services on our site, including, without limitation:

Chat rooms.

Bulletin boards.

Finance eligibility checks.

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not foolproof. Minors who are using any interactive service should be made aware of the potential risks to them.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Content Standards

These content standards apply to any and all material which you contribute to our site (contributions), and to any interactive services associated with it.

You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any contribution as well as to its whole.

Contributions must:

Be accurate (where they state facts).

Be genuinely held (where they state opinions).

Comply with applicable law in the UK and in any country from which they are posted.

Contributions must not:

Contain any material which is defamatory of any person.

Contain any material which is obscene, offensive, hateful or inflammatory.

Promote sexually explicit material.

Promote violence.

Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.

Infringe any copyright, database right or trade mark of any other person.

Be likely to deceive any person.

Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence.

Promote any illegal activity.

Be threatening, abuse or invade another's privacy, or cause annoyance, inconvenience or needless anxiety.

Be likely to harass, upset, embarrass, alarm or annoy any other person.

Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.

Give the impression that they emanate from us, if this is not the case.

Advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

Suspension And Termination

We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our site.

When a breach of this policy has occurred, we may take such action as we deem appropriate.

Failure to comply with this acceptable use policy constitutes a material breach of the terms of use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:

Immediate, temporary or permanent withdrawal of your right to use our site.

Immediate, temporary or permanent removal of any posting or material uploaded by you to our site.

Issue of a warning to you.

Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach

Further legal action against you.

Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

We exclude liability for actions taken in response to breaches of this acceptable use policy.

The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

KAP Motor Group Remuneration Policy

1. Introduction

KAP Motor Group is committed to remunerating and incentivizing staff in a way that aligns with our business objectives and promotes fair customer outcomes. This policy provides clear direction and guidance on how we remunerate and incentivize staff, incorporating effective risk management to identify and discourage behaviours that could lead to poor customer outcomes.

2. Remuneration Structure

Variable Pay and/or Commission:

  • Staff remuneration may include a combination of base salary, variable pay, and commission based on performance.
  • Commission structures are designed to reward sales achievements while ensuring responsible selling practices.

3. Incentive Schemes

Accelerators and Stepped Payments:

  • Accelerators and stepped payments may be included in the incentive schemes to motivate higher performance.
  • These are structured to ensure they do not encourage behaviours that could lead to poor customer outcomes.

Sales Targets and Minimum Triggers:

  • Specific sales targets and minimum triggers for bonuses are set at the beginning of each year.
  • Targets are communicated clearly to all participating staff members.

Payment Frequency:

  • Commissions and bonuses may be paid monthly, weekly, or quarterly depending on the specific scheme.
  • There may be caps on commission payments to prevent excessive risk-taking.

4. Key Performance Indicators (KPls)

Identification and Monitoring:

  • KPis are established to ensure that sales targets are met responsibly.
  • Key KPis include sales volume, customer satisfaction scores, compliance with company policies, and quality monitoring scores.
  • Risk Mitigation:
  • Regular reporting and analysis of KPis are conducted to mitigate the risk of miss selling products or finance.
  • Quality assurance measures such as complaints data, customer feedback, and mystery shopping exercises are used to monitor performance.

5. Quality Assurance Measures

Complaints Data:

  • Regular reviews of complaints data to identify trends and areas for improvement.
  • Complaints are analysed to ensure they are resolved effectively and to prevent recurrence.

Mystery Shopping:

  • Periodic mystery shopping exercises to assess the quality of customer interactions and adherence to company policies.
  • Results are used to refine training and support for staff.

6. Commission Clawbacks

Non-Compliance and Poor Performance:

  • Commission clawbacks may be implemented in cases of non-compliance, such as upheld complaints or poor-quality monitoring scores.
  • This ensures accountability and encourages adherence to company policies and procedures.

7. General Provisions

Discretion and Amendments:

  • Bonus, incentive, and commission schemes are set at the beginning of the year and are subject to the sole discretion of the company.
  • The company reserves the right to withdraw or amend any schemes from time to time without notice.

Tax Liabilities:

  • Employees will normally be liable for tax on such rewards, which will be included on annual P 11 D tax returns, if appropriate.
  • In the case of monetary awards, tax will normally be deducted through PAYE.

8. Communication

Scheme Details:

  • Details of any scheme applicable to an employee will be notified to them as appropriate.
  • Staff will receive clear communication regarding targets, incentives, and any changes to the schemes.

9. Effective Date and Review

Implementation:

  • This policy is effective from [insert date].
  • The policy will be reviewed annually to ensure it remains aligned with business objectives and regulatory requirements.

Vulnerable Customers Policy and Procedures

1. Vulnerable Customers

In order to address the needs of vulnerable customers correctly, it is important to be able to identify them. Risk factors can include bereavement, illiteracy, illness or other impairment. In many cases, more than one risk factor is present which increases the consumer's

vulnerability.

Our sales team needs to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make an informed decision about the implications of the agreements that they are being asked to make. This is not a diagnosis of a condition, it is just an extension of staff's existing skill of listening, identifying needs and adjusting their approach accordingly.

The Mental Capacity Act states that a person is unable to make a specific decision if they cannot understand information about the decision to be made, cannot retain that information in their mind, cannot use or weigh that information as part of the decision­ making process, or cannot communicate their decision.

2) Indicators of Vulnerability

1. Being asked to speak up or speak more slowly

Can they hear the complete conversation or are they missing important information?

Do they understand what you are saying? 2) They appear confused.

Do they know what is being discussed?

Do they ask unrelated questions?

Do they keep wandering off the point in the discussion and talking about irrelevancies or things that don't make sense?

Do they keep repeating themselves?

Do they say "Yes" in answer to a question when it is clear they haven't listened or understood?

They take a long time to get to the phone and sound flustered or out of breath, indicating they may have a lack of mobility due to age or illness.

They take a long time to answer questions They say "My son/daughter/wife/husband deals with these things for me".

A language barrier exists since they may not fully understand what is being said to them.

They say that they don't understand information given, a previous phone conversation or recent correspondence.

3) Mental Health Issues

Mental capacity is a person's ability to make a decision. It is reasonable to assume a customer has mental capacity at the time the decision is made. Having limited mental capacity does not necessarily mean that the customer lacks capacity to make a decision. The most common causes of mental capacity are: a mental health condition, dementia, a learning difficulty or development disorder, a neurological disability, a brain injury, alcohol or drug abuse. Some customers who fall into financial difficulties may have mental health issues as a result of being in financial difficulties or it may cause their financial difficulties as their ability to function may be disrupted for either a short period or permanently.

Possible Indications of Mental Capacity Limitations

1. We have an existing relationship with the customer and the customer's decision appears to be out of character.

2. A relative, close friend, carer or similar brings it to our attention.

3. Where we know or have reason to believe the customer has been diagnosed with a particular condition.

4. Where we know or have reason to believe the customer does not understand what he/she is applying for.

5. The customer seems unable to understand the information and explanations we are giving.

6. The customer seems to have difficulty in retaining the information and explanations.

7. The customer is unable to communicate a decision to borrow by any reasonable means.

8. The customer appears confused about personal information that we require, such as date of birth or address.

KAP Motor Group Policy

It is our policy to ensure that we treat customers who have mental capacity limitation with respect and consideration. Therefore, in our dealings with such customers, we will endeavour to adherer to the following practices:

1. Not to discriminate against the individual

2. Not to inappropriately deny a service or credit

3. Assist the customer to make an informed decision

4. Ensure the lending decision or debt solution is responsible and is based on a reasonable assessment of affordability and in the best interests of the customer

5. Ensure communications are clear and jargon free

6. Make a reasonable assessment of the customer's ability to understand and retain the information

7. Allow the customer sufficient time to make a decision

8. Speak clearly and enunciate

9. Set expectations for the communication -outline all the information that will be required and how long the discussion is likely to last

10. Be patient and empathise

11. Don't rush the conversation

12. Keep the conversation "on topic" but also put the customer at ease

13. Don't assume that you know what the consumer needs -it's easy to rush through if the customer is slow or not able to explain what they need.

14. Suspend the pursuit of recovery of a debt where it is known or we are aware, that the customer may lack the mental capacity to make decisions about the management of their debt.

Our staff are trained to recognise and encourage a customer to disclose any issue, including mental health, and whether this is affecting their ability to repay the debt. In all instances where a disclosure is made, the customer's consent to record this information on our systems is obtained and the customer will be advised of how this information will be used.

In the event that a customer does make a disclosure, staff must

Acknowledge

Inform and request to record the information

Provide a Data Protection Statement

Ask appropriate questions:

1. Does your mental health affect your financial situation?

2. Does it affect your ability to deal or communicate with us or other third parties?

3. How would you prefer us to contact you -in writing, by phone or email?

4. Does anyone help you manage your finances such as a family member-if yes, do you want us to deal with this person on your behalf? Consent must be noted on the system.

Financial Difficulties

Although there are a wide range of risk factors that lead to vulnerability KAP Motor Group recognises that financial difficulty itself commonly leads to customers becoming vulnerable.

Financial hardship can often be caused by experiencing other vulnerability risk factors as bereavement, income shock due to illness, redundancy and so on.

Financial vulnerability covers a wide spectrum, from severe financial hardship to those who understand the product and how to use it in a responsible and appropriate manner, therefore, our processes and systems aim to distinguish between these customers. For example:

Ensuring that the customer understand the product, all associated costs and their responsibilities

Conducting brief assessment of affordability

Ensuring that the customer has sufficient time to consider their options and review any documentation

Highlighting the importance of, and proactively encouraging customers, to disclose any financial difficulties or any issues that they are experiencing

Discussing whether the customer envisages any future difficulties through recent or planed future events (Coronavirus related restrictions, redundancy, retirement etc.)

Customers who are experiencing financial difficulties will always be treated fairly and in line with our policies.

Lending Decision and Communication with a Lender

Where it is highlighted that a customer is classed as a vulnerable person, a prospective Lender will be made aware of this fact so they an also instigate their Vulnerable Persons Procedures. We and the Lender will, where appropriate:

Apply a high level of security to the customer's application for credit, in order to mitigate he risk of the customer entering into unsustainable borrowing.

Balance the risk of a customer taking on unsustainable borrowing against inappropriately or unnecessarily denying credit to the customer

Undertake an appropriate and effective creditworthiness assessment which does not place over-reliance on information provided by the customer for the assessment.

Take particular care that the customer is not provided with credit which the firms knows, or reasonably believes, to be unsuitable to the customer's needs, even where the credit would be affordable.

Consumer Credit Directive

Consumer Credit Directive (CCD) is a significant package of regulations introduced by the European Commission to harmonise the protection offered to consumer credit customers and to increase the transparency of the consumer industry. The CCD applies to all providers of credit to consumers (such as banks and building societies) and all credit intermediaries (such as motor dealers) and came into effect fully on February l't 2011. In order for us to comply with the CCD requirements and for this business to demonstrate a high level of professionalism and assure our customers that customer satisfaction is paramount to us; we are required to give explanations to borrowers of the credit products we offer. These explanations should be clear enough for you (the borrower) to assess whether the agreement suits your needs and financial situation. The explanation should also allow borrowers to make a reasonable assessment as to whether they can afford the credit for the length of the contracted arrangement and to understand the key associated risks. We have taken all practical steps to ensure that we have fulfilled this requirement, in addition, we have processes and procedures in place that will be applied if we are uncertain or have concerns regarding a decision to proceed with the arrangement, we should stress that there are limits to the assessments we make in this respect. We have endeavoured to make the explanations clear, however please ask for more information if you feel it necessary to do so. If financing the vehicle purchase through the dealership, borrowers will be handed documentation referred to as Pre - Contract Credit Information (PCCI) or Standard European Consumer Credit Information (SECCI). This documentation will be generated by the finance provider's system once a credit has been accepted by them. Credit reference searches will be conducted by lenders in order to assess the credit application. Additional information may be required, and lenders may on occasions contact employers as part of their checks. Alternative terms may be offered. Non-payment of credit agreements and defaults will severely affect your credit rating and may result in the vehicle connected to the finance agreement being repossessed by the lender and/ or action being taken via the County Courts. The way the agreement is conducted will be registered with all Credit Reference Agencies {CRA'S) and therefore any default could severely affect the chances of being accepted for future credit. In respect of a Hire Purchase, Conditional Sale, Lease Purchase or Personal Loan agreement with a "balloon payment" at the end borrowers should be aware that the "balloon" or residual value is not guaranteed by the lender and is the responsibility of the borrower to pay. This is shown as a final payment figure on the finance documentation and may also include a purchase fee. If the protection of a Minimum Guaranteed Value (GMFV or GFV) is required, then the finance arrangement should be in the form of a Personal Contract Purchase (PCP) arrangement. It is important that the borrower carefully reviews the details provided in the PCCI / SECCI, which will include information regarding the amount of credit, APR, loan duration, monthly cost, consequence of missed payments, elements of the agreement which may be disadvantageous to the borrower, right of withdrawal, early repayment etc. At this stage the borrower may take sufficient time to review the content and consider how the payments fit into their budget and how they would manage monthly cost should circumstances change adversely, the borrower has the right of withdrawal within 14 days of confirmation from the provider that the agreement has been executed, with 30 days being allowed to repay the loan amount including any interest. Terms and conditions will provide full details.

1. The Financial Conduct Authority (FCA)

The FCA is the independent watchdog that regulates the financial services. We are required to give you this document, use this information to decide if our services are right for you.

2. Whose products do we offer?

We offer selected products from Gardx assure whose insurance products listed below are underwritten by Lloyds Syndicate 5820 and are managed by ANV Syndicates Ltd.

We may from time to time use other insurers; we can provide you with more details if required.

We also offer selected products from a range of finance providers (Dependant on Franchise) including:

  • Mobilize Financial Services • Evolution Funding Ltd • Blue Motor Finance Ltd • Motonovo Finance

3. What service will we provide you with?

We will advise and make a recommendation for you after we have assessed your needs for:

  • Retail Price Protection / Guaranteed Asset Protection (Gap)
  • LCV Retail Price Protection
  • Taxi Return to Invoice Gap
  • Taxi Finance Gap
  • Lease Asset Protection Alloy Wheel &/or Tyre Protection
  • Cosmetic Accident Repairs Solution (SMART Insurance)

We will also advise and make a recommendation for you in respect of the following finance products:

Hire Purchase

Conditional Sale

Personal Contract Purchase

Personal Loan

Leasing

Contract Hire

Credit reference searches will be conducted by lenders in order to establish any credit application. Additional information may be required and lenders may on occasions contact employers as part of their checks. Alternative terms may be offered. We Will NOT advise on or recommend to you any Payment Protection Insurance (PPI) products. If you feel you may have a need for this type of insurance, you should contact and Independent Financial Advisor (IFA).

4. What will you have to pay us for this service?

There is no fee for advising or recommending our insurance products including Guaranteed Asset Protection or any credit arrangement. You will receive a quotation which will tell you about any other fees relating to any particular insurance policy. We may receive a payment or other benefit from the finance provider if you decide to enter into an agreement with them.

5. Who regulates us?

Kent Auto Panels limited is authorised and regulated by the FCA. Our FCA Register number is: 300296. Our permitted business is arranging non -investment insurance contracts and consumer hire and credit brokerage for debtor-creditor-supplier agreements or consumer hire agreements. You can check this on the Financial Services' Register by visiting FCA's website. www.fca.org.uk/register/ or by contacting the FCA by phone on: 0800 111 6768.

6. What do you do if you have a complaint?

If you wish to make a complaint, please contact us:

In writing: Managing Director, KAP Motor Group, Shorncliffe Motor Park, Ross Way, Folkestone, Kent, CT20 3UJ or telephone 01303 228200. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (FOS).

7. Are we covered by the Financial Services Compensation Scheme (FSCS)?

We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. Non-compulsory general insurance products are covered for 90% of the claim, without any upper limit. Further information about compensation scheme arrangements is available from the FSCS. You can telephone the FSCS on: 020 7741 4100 or write to them at: Financial Services Compensation Scheme, l0'h Floor, Beaufort House, 15 St Botolph Street, London EC3A 7QU

Disclosure of Commission on Finance Agreements

As an FCA regulated business it is important that you are aware of the fact that in placing business with a finance provider, we will receive a commission.

Any agreement with a third-party finance provider is totally separate to your agreement. For your peace of mind, any commission received by KAP

1. Will not affect the rate of finance you get, as this is solely down to your individual credit score, and the resulting Tier your Finance Company accepts you on.

2. Will not affect the amount of money the finance company advances, as this is determined by the value of the vehicle.

3. Will not affect the term of the loan as this is determined by the age of the vehicle.

We make this information as clear as possible, so that any concerns you have about the effect finance commissions may have on your deal, are satisfied.

It is also worth making clear that there are various other funders available in the marketplace to obtain quotes from.

Should you wish to enquire as to the level of commission on your deal, please speak to your Sales Executive.

Complaint Policy and Procedure

Purpose

A) This document represents our policy towards complaints, how a consumer can make them and how as a company we handle them.

B) This policy and procedure has been created to meet general standards and requirements and complies with standard complaint handling procedures, including the Financial Ombudsman Service (FOS) and FCA regulations.

C) We are committed to ensuring the fair treatment of our customers and ensuring they face no post sale barriers with our service and we have effective and transparent procedures in place.

D) As a business we ensure that complaints can be made using any reasonable means and recognise complaints require a resolution.

Definition

As per FCA material, they define a complaint as the following:

"Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a service or a redress determination, which alleges that the complainant has suffered (or may suffer} financial loss, material distress or material inconvenience.

Customer Complaints Procedure

Our aim is always to provide an exceptionally high level of service to all our customers. Where customers are unsatisfied, it's important to us that this is dealt with objectively, fairly and as quickly as we are able to.

The following procedure explains how we deal with complaints, our commitments to you and what action to take if you think your complaint has not been resolved to your satisfaction.

If you have a complaint about any aspect of our service, then we would like to hear from you.

Please use the below details to let us know:

info@kapmotorgroup.co.uk

We kindly ask, so we can look into your complaint as quickly as possible you include as much detail as possible, however if we are missing anything we will be in touch. We will aim to come back to you within 48 working hours of receiving your complaint.

If we are able to investigate and resolve your complaint within 3 days, you will receive a summary resolution response from ourselves, which will detail our outcome and findings.

In the event our investigations take longer than 3 days, we will issue you a final response within the 8 week timescale. Whilst we try to close any complaint before this 8 week time frame we do need to make you aware we do have this time. Our final response will include detailed information of your complaint, our investigation and the resolution we have come to. If you are not satisfied with our final response or the handling of your complaint within the 8 week time frame, you can contact the Financial Ombudsman service using the details below. You must do this within six months of our final response.

www.financial-ombudsman.org.uk

0800 023 4567

Exchange Tower, Harbour Exchange, London, E14 9SR

Process and Responsibilities

1 Record Keeping

a) As per DISP 1.9 and to ensure that we handle our complaints efficiently and effectively, any correspondence or note from phone communications will be documented on our system.

b) This will allow the complaint handler to review the whole complaint and refer back to any point in the investigation if they are required to do so.

c) Any Documentation received regarding the complaint will also be attached to the application.

d) All records of complaints will be kept as per our retention periods, only employees that require access to customer complaint notes will be granted this information.

e) We aim to resolve all complaints as soon as possible to minimise the number of complaints (DISP1.4.3).

2 Training

a) Staff will receive complaints training within their initial induction and at lease once a year.

b) Training will ensure our team understands the processes that we have in place and the regulatory importance of following these processes.

c) At any time, staff have the opportunity to request further training on any aspect of our business.

3 Treating Customers Fairly

a) As a company, we ensure that we follow all regulatory guidelines, including treating customers fairly.

b) When it comes to complaints, we guarantee that our customers will not face any post sale barriers.

c) Our staff are aware that they need to assist customers as much as possible when they wish to make a complaint, and they should not receive a different service to any other customer.

d) As per DISP 1.3.2 customers are made aware they can make a complaint verbally or in writing and these contact details are provided in our complaint's procedure for ease for the customer.

e) We will ensure that our complaints procedure is in clear location so our consumers can access it with ease. To ensure we are in compliance with DISP 1.2 our complaints procedure is clearly listed on our website.

f) Specifically, to meet DISP 1.2, our complaint procedure will also detail contact details for the FOS.

g) Customers will have their expectations managed, and staff will explain the complaints process so a customer can understand the next steps.

h) As per DISP 1.4.1, we will thoroughly investigate any complaint competently, diligently and impartially, ensuring that any evidence is saved to the customers application for record.

i) In line with 1.4.2 all factors of the customers complaint journey and outcome will be considered in our investigations.

j) We will keep in constant communication with all parties.

k) We will assess fairly, consistently , and promptly:

The subject matter of the complaint

Whether the complaint should be upheld

What remedial action or redress (or both) may be appropriate.

If appropriate, whether it has reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in the complaint.

l) All communication received will be acknowledged within 48 hours, as per DISP 1.6.1.

m) If a customer makes a complaint about a specific member of the team, that employee will not have any involvement in handling the customer's complaint .

n) Customers will never be charged for making a complaint, no matter what method of communication they use (DISP 1.3.1 ).

o) Where a customer has referred a complaint to the FOS, we will filly comply with any further investigations and comply promptly with any settlements or rewards in line with DISP 1.4.4.

p) At any point in our trading future, we are required to publish our complaints data due to the number of complaints received, we will ensure this is easily available to our customers and contains all the required information and in the time limits required. We will inform the FCA in writing as and when this has been actioned.

q) As per DISP 1.8, should we receive a complaint which is outside of the time limit (as detailed in DISP 2.8) for referral to the FOS an d we reject the complaint, we will provide a full explanation of this to the complainant.

r) For reference these time limits are as follows:

More than six months after the date on which we sent our final response, redress determination or summary resolution communication.

More than six years after the event complained of.

Three years from the date on which the complainant became aware (or sought reasonably to have become aware) that they had cause for complaint.

4 Summary Resolution

a) In line with DISP 1.5 we have put in the following process should we resolve the complaint within 3 working business days.

b) Once resolved, we will send the customer a Summary Resolution.

c) This will include details of how the customer can refer their complaint to FOS should they wish to if they are not satisfied with our response, the time limits able to do this and that we consider the complaint closed.

d) Depending on the customer's circumstances, and if it is deemed easier or preferred for the customer, we may communicate this resolution via other methods such as telephone.

5 Redress

a) redress will be decided on an individual basis and detailed to the customer in our final communication.

b) Management will take into account all aspects of the complaint and any suffering caused to the customer.

c) Where redress is considered or decided, we will ensure all factors have been taken into account including all evidence obtained and regulation set out buy the FCA and FOC.

d) Redress may also involve agreements with lenders or brokers, to determine an overall decision, and where application all communications and decisions will be documented.

e) As with all complaint records, redress will be recorded so we are able to report to the regulator.

6 Point of Contact

a) We have appointed Angus Furneaux to currently handle all complaints.

b) We will ensure this information remains clear and up to date on our FCA register.

c) As KAP Motor Group grows and moves forward, we will consistently review this responsibility and regularly review knowledge and training.

d) We will request an email or detailed description over the phone to handle the complaint further.

e) We will then liaise with the customer and any third parties as required (and in line with DISP 1. 7 .1) and issue a final response letter or summary resolution.

f) If in the event or circumstance we are required to forward the complaint, we will do so promptly and inform the customer that we have done so.

g) We are committed to ensuring that we are in control of all complaints and complete them as soon as possible.

h) We will ensure all complaints are updated on the complaints log, system and compliance monitoring plan.

i) Templates will be used when liaising with customers for acknowledgement (including initial and holding letters), Summary Resolution and Final Response letters to ensure that the customer received information required in DISP.

j) This will include:

Acceptance or rejection of the complaint

Information on any redress offered and agreed on

Information on how the customer can contact FOC and the time limits applicable

FOS explanatory leaflet

k) If we cannot provide the customer with a final response in 8 weeks, we will ensure a holding letter is provided that will include:

Why we are unable to provide this

A time frame of when we believe we will be able to

Informing they are able to contact FOS and the contact details to do so

FOS explanatory leaflet

l) If we are able to resolve the complaint before the 8 week period, the final response will be sent as soon as possible.

m) All correspondence with customers will be clear, fair and not misleading. Where information such as FOS details is required to be prominent, this will be done so.

Kent Auto Panels Ltd – Data Retention and Deletion Policy

1. Introduction

At Kent Auto Panels Ltd, we are committed to protecting the privacy and rights of our customers, employees, and partners. This Data Retention and Deletion Policy sets out how we manage personal data throughout its lifecycle, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Purpose

This policy ensures that:

Personal data is not kept for longer than necessary.

Data is securely deleted or anonymised when no longer required.

We meet legal, regulatory, and operational obligations.

Individuals’ rights under data protection laws are respected.

3. Scope

This policy applies to:

All personal data processed by Kent Auto Panels Ltd.

All employees, contractors, and third parties with access to such data.

All systems, whether digital or physical, that store or manage personal data.

4. Retention Periods

The table below outlines typical retention periods for the types of data we collect:

Data Category

Retention Period

Legal/Business Basis

Customer data (sales and service records)

7 years

HMRC, legal claims, warranty tracking

Vehicle service history

Lifetime of vehicle

Technical support and warranty records

Finance/credit applications

7 years

Financial Conduct Authority (FCA) recordkeeping

HR and payroll records

6 years after termination

Employment law

Job applications (unsuccessful)

12 months

Recruitment practices

Email correspondence

2 years

Operational and legal needs

CCTV footage

30 days

Security and investigations

Invoicing and accounting records

7 years

HMRC requirements

Warranty claims

7 years

Product liability and aftersales support

Where legal obligations differ from operational needs, the longer retention period will apply.

5. Data Deletion Procedures

Once data reaches the end of its retention period, Kent Auto Panels will ensure:

Digital data is permanently deleted using secure data-wiping tools or overwritten.

Physical records are shredded or disposed of using approved secure disposal methods.

Backups are reviewed regularly and old or obsolete versions are purged in line with this policy.

Deletion actions are logged where appropriate, particularly for financial or sensitive personal data.

6. Subject Access & Deletion Requests

Under UK GDPR, individuals have the right to request:

Deletion of personal data no longer needed (Right to Erasure).

Correction or restriction of inaccurate data.

Access to personal data we hold.

All requests should be submitted to our Data Protection Lead at:

info@kapmotorgroup.co.uk

Requests are processed within one calendar month, unless legally exempted.

7. Responsibilities

Role

Responsibility

Directors & Senior Managers

Ensure compliance and provide resources for data protection practices.

Data Protection Lead

Maintain retention schedules, manage deletion processes, handle requests.

All Employees

Follow this policy and report any breaches or concerns immediately.

8. Exceptions and Updates

There may be circumstances where we need to retain data longer than specified:

For ongoing legal claims or investigations.

Where a regulatory authority requires extended retention.

This policy will be reviewed annually or when changes in legislation or operations require it.

Monitoring and Compliance

As a company we will ensure that we keep up to date with regulatory and legal requirements, and that our processes and policies are updated accordingly to meet regulations.

We may conduct root analysis on our complaints to identify any patterns that may potentially form, therefore limiting the risks to our customers.

In the event a complaint identifies an area of concern within our procedure, this will be assessed and rectified where applicable.

Review

This policy will be reviewed on at least an annual basis, any updates will be reissued on this policy.

All policy changes are approved by Angus Furneaux.

Contact deatils

Financial Ombudsman

Phone

0800 023 4567

Email address

complaint.info@financial-ombudsman.org.uk

Postal Address

Financial Ombudsman Service

Exchange Tower

London

E14 9SR

The Motor Ombudsman

Phone Number

0345 2413008

Email Address

servicecomplaints@tmo-uk.org

Postal Address

The Motor Ombudsman Ltd

71 Great Peter Street

London

SW1P 2BN

Changes To The Acceptable Use Policy

We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our site.