Policies & Information

AFFORDABILITY POLICY

As a company offering a consumer credit facility to our customers, we are regulated by the Financial Conduct Authority (FCA) regarding our business operations and processes. As a responsible lender, we have a duty of care to make a reasonable assessment of each individual case when considering offering a credit facility to customers to minimise the risk of financial distress in the future.

The Financial Conduct Authority (FCA) state that “a lender should take adequate steps to the extent that it is reasonable and practicable” to verify that the financial information provided by the customer is correct, and that what is deemed “adequate” will depend on the individual circumstances. To this end, rather than completing extensive credit checks, Pay Later Carpets instead places a focus on the level of potential risk posed to the customer should they be unable to maintain the payments schedule as agreed, when assessing affordability.

To reduce exposure of debt to ourselves and to minimise risk and protect our customers from potential financial distress and adverse impact on their wellbeing should they be unable to maintain their agreed payments, whilst continuing to treat all customers fairly and without discrimination, Pay Later Carpets will adhere to the following operational behaviours:

Training and understanding

• All staff will receive training in identifying and dealing with customers who may be classed as “vulnerable” (see Vulnerable Customer Statement, Policy and Process)
• Staff will complete training on Managing Debt: how debt occurs, the impact of debt on consumers and processes to avoid, minimise and manage debt and provide support to customers.
• Surveyors attending appointments and providing quotes/arranging payment plans will receive training and will be competent in their role and in the clear delivery of all information when providing quotes/arranging payment plans, and will receive training in assessing affordability based on numerous factors and information provided which will include but is not limited to: Personal income, additional household income, nondiscretionary expenses, lifestyle expenses, household composition, presenting factors, evidence of understanding the credit agreement and a commitment to adhering to this, known future changes in circumstances etc. (See Affordability Assessment – Process)

Processes

• Ensure that our paperwork, documentation, and information is clear and legally compliant.
• Ensure that our processes are regularly reviewed and updated as required to support the customer’s experience.
• Provide clear verbal and written information regarding costs and repayment arrangements at all stages of the process.
• Ensure that all staff are aware of and operate within the guidelines of their specific role, with a focus on the customer and their wellbeing as priority.
• Ensure that we operate within the legal requirements and the recommendations of the Financial Conduct Authority (FCA)
• Ensure that customers are provided with all credit related information and the Terms and Conditions of our business in advance and in good time of completing any contract/agreements, and that the information contained in these are clearly discussed and questions invited during their survey appointment, and prior to signing any agreement.
• Ensure that customers are provided with information regarding their rights relating to the credit agreement both verbally and in written format. This information will include but is not limited to the customers right to cancel/ 14 day cooling off period under the Consumer Rights Act 2015 – distance selling.
• Operate a compliant and easily accessible complaints procedure and offer signposting information to customers for support in making a complaint (Trading Standards, FCA, CAB etc.)
• For customers who advise us of financial difficulties or if we become aware that a customer may be experiencing financial difficulties through our own account management processes, will provide accessible information and signposting to supporting organisations and will provide customers with a copy of our own “Managing Payment Difficulties – Policy”. We will offer a personalised support plan and named case worker to enable with the customer to achieve a positive outcome and experience.
• Ensure that our “Managing Payment Difficulties – Process” is reviewed and adhered to in order to best support customers.
• Always keep the customers experience and wellbeing central and as our main focus.

Our Commitment to this Policy

All Pay Later Carpets operations will commit to this policy and the information and guidance contained in it. We will regularly engage with customers and staff regarding their experiences, and will utilise this feedback to ensure that the policy is reviewed and revised accordingly, to ensure that it best reflects our customers’ needs and enable good outcomes.

CUSTOMER PAYMENT DIFFICULTIES POLICY – (CPDP)

1. Introduction

Pay Later Carpets operates a Customer Payment Difficulty Policy (CPDP). This policy sets out the key principles to guide our staff interactions and to enable us to implement our Customer Payment Difficulty Process (CPD Process).

The purpose of this policy is to both support staff to identify and support customers who are experiencing payment difficulties in order to reduce the negative impact on their wellbeing, in addition to providing active customers who self-identify as experiencing financial hardship or difficulty, with the information, appropriate signposting and a route to access support from ourselves in managing their credit account on an ongoing basis, in order to affordably address actual, or reduce risk of potential payment issues and subsequent adverse impact on mental and financial wellbeing.

Principles underpinning this policy:

• Pay Later Carpets ethos is based on placing the customers wellbeing at the centre of our focus, maintaining their safety, and striving to ensure that they experience positive outcomes.
• Pay Later Carpets has a duty of care to customers where we have assessed affordability and have approved them to enter into a credit agreement with us.
• All company policies and our processes are regularly reviewed and updated based on feedback from our staff and customers regarding their experiences, which will maintain the effectiveness of this specific policy, information, and guidance in supporting our customers in the most effective manner.
• Pay Later Carpets ethos also dictates that all customers are always treated with fairness.
• All engagements with customers will be carried out respectfully and with understanding and empathy.
• Staff training, skills and system service design enables early identification of customer issues allowing for early intervention and support.
• Targeted training will equip staff with the understanding, knowledge and skills required to best support customers.
• Adopting a personalised approach, we will support customers in difficulty as individuals, and will seek to find tailored solutions to their issues which best suit their individual circumstances.
• Pay Later Carpets will explore all potential, flexible and creative arrangements to identify affordable solutions to best support each customer’s specific situation.
• Effective communication will be used in all customer engagement.
• All staff and representatives of Pay Later Carpets will adhere to the guidance and instruction within this policy and the associated Processes document.
• Consideration will be always given to our Vulnerable Customer Policy and Process.
• Customer safety is prioritised and where it is evident that to pursue the debt in the long term, is likely to result in direct and significant harm to the customers financial, physical, or mental wellbeing, Pay Later Carpets will give consideration to ending the agreement, cancelling the debt and closing the account without further recovery.

2. Respecting our customers rights:

To respect the rights of our customers, Pay Later Carpets will:

1. Notify customers in writing/email within 24 hours of a Direct debit payment failure.
2. Employ CPD Process and Vulnerable Customer Policy/Process as documented.
3. Identify and record Vulnerable Customers at the earliest opportunity.
4. Direct customers to this policy.
5. On identification of potential payment difficulties, provide customers with written notification of our concerns and information on how to access available support from us.
6. Provide customers with tailored information, contact details and signposting to independent support organisations.
7. Provide customers written information regarding their legal rights in relation to the debt.
8. Place all debt recovery action temporarily on hold for 30 days to provide “breathing space” if a customer identifies as being “Vulnerable” or where there is a serious concern for their wellbeing/safety at this time (this period may be extended on review as required).
9. Work with any appointed representatives of the customer where required.
10. Adhere to GDPR and ICO regulations to protect the customers privacy rights.
11. Adhere to all legal requirements and governing body guidance in relation to recovery of amounts outstanding/debts e.g., Consumer Credit Act 2015 section 86, FCA CONC 7.3, Financial Ombudsman Service
12. Where a third-party debt recovery company is employed, ensure that they are legally compliant in their service delivery and that their FCA registration and company policy is compliant with all FCA regulations and requirements.
13. Offer customers flexible options to identify and implement affordable solutions based on the customers’ needs.
14. Customers will receive appropriate forbearance that is in their interests and takes account of their individual circumstances.

3. Support and Assistance:

Pay Later Carpets will offer personalised support and assistance to all customers experiencing financial hardship or payment difficulties. We will work with customers in a flexible manner to identify the most affordable solution to enable them to manage their account effectively. We will be led by the customers’ needs and circumstances and will ensure that their essential living requirements are prioritised and protected.

In order to provide the support identified, customers will need to communicate with us and commit to working with us to identify and implement appropriate arrangements and solutions. If the customer refuses to respond to all attempts by Pay Later Carpets, to engage in communication with us or to work with us to resolve the identified payment issues, we will be unable to continue to offer support once all attempts have been exhausted, at which stage, the customer’s credit agreement will be recorded as “Defaulted” and details of the debt will be passed to a third party debt recovery company who will seek to recover the outstanding amount on our behalf. (At this date, the company employed for this service is Cobra Financial Solutions Ltd) This action will not result in any additional interest, charges or penalties and will not impact on the customers’ credit score/rating.

4. Privacy of personal information:

All representatives of Pay Later Carpets are bound by the Data Protection Act 2018, as the implementation of General Data Protection Regulations (GDPR) and are registered with the Information Commissioners Office (ICO) to ensure that customers rights are upheld in relation to the collection, disclosure, use and storage of their personal data. As such, Pay Later Carpets will implement the seven key principles of GDPR when managing customer data to ensure that all information is handled responsibly and in accordance with regulatory requirements and with customer instructions.

5. Complaints:

Pay Later Carpets has a clear and accessible complaints procedure and customers experiencing payment difficulties will be informed of their rights to lodge a complaint at any time about any aspect of our services or processes and will be offered support and guidance in how to do this.

Customer Complaints will be dealt with in accordance with the Pay Later Carpets Complaints Procedure.

If a customer experiencing payment difficulties or financial hardship, submits a complaint which is in relation to, or has a bearing on payments or the credit account arrangement, the account will be “frozen” and further payments placed on hold whilst the complaint is addressed. The customer will be afforded all the support and assistance as would usually be available, without prejudice.

6. Commitment

All employees and representatives of Pay Later Carpets will commit to the information and direction within this policy. The policy and the processes which support it, will be subject to ongoing review and development and as such will always be available for modification if additional information or changes to processes, thought to be beneficial to the subject are identified and implemented. Pay Later Carpets invites discussion, comments, and feedback regarding any of the information contained in it.

PAYMENT DIFFICULTIES / FINANCIAL HARDSHIP?

We can support you!

Dear Customer,

In today’s current climate, we realise that there may be times when events occur which have a significant impact on personal and financial circumstances, and as a result agreements which were made in good faith at the time, can be impacted to the point that it is no longer possible to maintain them.

We recognise that from time to time, customers may experience financial hardship or payment difficulties which can have a short term or longer-term impact on their ability to continue to make their payments without adverse consequence.

As a supportive and responsible lender, Pay Later Carpets operates a Customer Payment Difficulties Policy and we want you to know that we are here to support you in times of difficulty and have a range of options available to us which we can utilise to affordably manage the issues and remove the risk to your wellbeing. Our staff are trained in customer confidentiality, and we treat all customers respectfully, with discretion and understanding. We will provide personalised support, tailored to your specific circumstances and needs, based on the information provide. 

We can provide a dedicated team member to support you and we guarantee that we will always have a solution that suits your needs. There is no debt issue which we can’t manage by working with you.

We have included a list of links to useful, independent debt support organisations and have signposted information relating to your legal rights as a consumer. Please refer to this information and available support and know that there are people who are trained to help you.

Please contact us on 03450521479 ( to prevent call charges, we will call you straight back) or email us on the address at the bottom of this letter to speak to us if you are worried about financial hardship or are having difficulty in making your payments, and our team will be happy to provide you with the support you need. 

Please remember, we can only help you if you allow us to, so it is important that you talk to us and tell us if you are struggling with your payment arrangement.

Kind regards,

Pay Later Carpets

LINKS TO SUPPORT

Health and Debt

The Counselling Directory: http://www.counselling-directory.org.uk/

Welldoing: http://welldoing.org/

Martin Lewis: Mental Health & Debt Guide 2022:

https://www.moneysavingexpert.com/credit-cards/mental-health-guide/#download

Support with managing Debt

StepChange: http://www.stepchange.org/

Citizens Advice Bureau: http://www.citizensadvice.org.uk/

The Money Charity: http://themoneycharity.org.uk/

Advice UK: http://www.adviceuk.org.uk/

Christians Against Poverty: https://www.capuk.org/

National Debtline: https://www.nationaldebtline.org/

Debt Action (Northern Ireland): http://www.adviceni.net/

Consumer Line (Northern Ireland): http://www.consumerline.org/

PayPlan: http://www.payplan.com/

Money Advice Service: https://www.moneyadviceservice.org.uk/en

Money Advice Scotland: http://www.moneyadvicescotland.org.uk/

Policy in Practice: https://betteroffcalculator.co.uk/calculator/new/step1

Legal Support

Financial Ombudsman: http://www.financial-ombudsman.org.uk/

Civil Legal Advice: https://www.gov.uk/legal-aid

Rightly: https://www.rightly.co.uk/

Your local council will also be able to signpost you to beneficial support services in your local area: www.gov.uk

PAY LATER CARPETS COMPANY ETHOS

Pay Later Carpets believes in fairness and equality to all customers. We believe that all consumers, have the same right to safely and affordably access high quality products and services and should not be placed at risk of being taken advantage of or financial detriment as a result of their personal or financial circumstances. We provide a personalised service to all customers each stage of their journey with us, and treat each customer as an individual, offering support tailored to their specific needs as required. Our customers’ wellbeing is our primary focus, and we strive to ensure that all outcomes of their experiences with us are positive.

At Pay Later Carpets, we pride ourselves on being a responsible and supportive lender. We want our customers to know they are valued and have been treated respectfully and in a personalised manner. We want them to have a close relationship with us so they feel supported should they have any issues and to be happy with the products and service they receive. Some of our customers may sit within the low/no credit score category for reasons beyond their control, they may have been made redundant, struggling to find work, young single parents, young people starting out who haven’t yet built a credit score, etc or may be categorised as “Vulnerable Customers”. We feel that these customers should not be disadvantaged, discriminated against, or taken advantage of as a result of their specific circumstances, but are entitled to protection to access the same range of high-quality products, 0% interest rate and high-quality service we would all expect to be afforded.

Pay Later Carpets is committed to conducting low risk and transparent business operations in accordance with all applicable laws, rules and regulations. We are dedicated to ensuring that all customers are treated fairly and safely and as such, we place customer welfare at the centre of our policies and processes to ensure that they have the individual and personalised support they require to achieve positive experiences.

Our company ethos reflects the principles and behaviours of “Pay Later Carpets”, and as such, each individual Pay Later Carpets staff member or representative is required to adhere to standards outlined within it. By applying our company policies and adhering to the processes outlines to underpin these, we

Pay Later Carpets are different to the rest, and we are proud of that!

CUSTOMER COMPLAINTS PROCESS

HOW TO INFORM US OF AN ISSUE OR MAKE A COMPLAINT

The policies which underpin Pay Later Carpets dictate that all operations will be carried out in a manner which is in line our company ethos, placing the customers welfare at the heart of all of our processes, to ensure they are treated with fairness.

We appreciate that from time-to-time situations may arise which unfortunately result in customer dissatisfaction. On these occasions, we encourage communication from the customer to advise us of the events which have led to this and allow us the opportunity to find a satisfactory resolution.

To raise a concern, inform us of an issue or make a complaint, customers are invited to contact us by telephone call (0345 0524179) or email us at Info@paylatercarpets.co.uk or the specific email address documented on your purchase agreement, in the first incidence as we will always endeavour to resolve any complaints on the same day they are received, however in the event that the complaint can not be resolved on the same business day, the following steps will be taken to investigate the matter:

1. We will request that you send the details of your complaint to us in writing to Pay Later Carpets, at the address stated on your agreement documents, if unsure, please call 0345 0524179 for details, or you can email us on Info@paylatercarpets.co.uk, or the specific email address on your agreement documents.

2. On receiving your written complaint, we will seek to resolve this by the end of the second working day. If we are unable to do this, we will write to you within 5 working days, to acknowledge your complaint and provide you with the name and position of the person dealing with your complaint, along with a copy of our internal procedures.

3. If your complaint has not been resolved within 4 weeks of being received, we will write to you again to explain the reason why we have been unable to resolve the complaint yet and advise you of when we will make further contact with you.

4. We will provide you with our final response within 8 weeks of receiving your written complaint which you will need to respond to in writing. This will be our final view on the complaint and will inform you of the outcomes of the investigation:

Accepted: We will offer redress and a clear explanation of how we have reached this offer.

Rejected: We will provide our rational behind this decision.

Partially Accepted/Rejected: We will provide a clear breakdown of this and any identified redress.

We will advise you of your rights should you remain dissatisfied with the decision and provide information to enable you to contact the Financial Ombudsman Service.

We are committed to the fair treatment of our customers and will review any complaints received to identify lessons we can learn from them and will implement changes to the way we do things to ensure there is no repeat.