Complaints Handling Procedure

 1. Definitions and Interpretation

1.1   In this Complaints Handling Procedure the following expressions have the following meanings:

“Business Day”

means, any day (other than Saturday or Sunday) on which ordinary banks are open for their full range of normal business in England & Wales;

“Complaint”

means a complaint about our services sold by Discern Genomics Limited, about our customer service, or about our employees, agents, subcontractors;

“Complaints Form”

means our standard complaints form for use by Customers, available from www.discern-genomics.co.uk/complaints-form;

“Complaints Policy”

means our customer complaints policy, available from www.discern-genomics.co.uk/complaints-policy;

“Complaint Reference”

means a unique code assigned to a Complaint that will be used to track that Complaint;

“Customer”

means a customer of Discern Genomics Limited and includes potential customers (no purchase necessary);

“Decision Letter”

means a letter informing a Customer of the outcome of their Complaint;

“External Resolution”

means the referral of a Complaint to an external body or organisation for resolution by a Customer if that Customer is not satisfied with the outcome of this Complaints Handling Procedure;

“Investigation Report”

means a report detailing the investigation of a Complaint;

“Recommendation”

means the recommended resolution to a Complaint made by the staff member handling a Complaint; and

“Resolution Action”

means the available actions to be taken in response to a Complaint as detailed in Section 6.

2. What this Complaints Handling Procedure Covers

2.1   This Complaints Handling Procedure applies to Complaints pertaining to the provision of services by Discern Genomics Limited, to our customer service and to our employees, agents, subcontractors.

2.2   For the purposes of this Complaints Handling Procedure, any reference to us, Discern Genomics Limited, also includes our employees, agents, subcontractors.

2.3   Complaints may relate to any of our activities and may include (but not be limited to):

2.3.1   The quality of our customer service;

2.3.2   The behaviour and/or professional competence of our employees, agents, subcontractors;

2.3.3   Delays, quality concerns, or other problems associated with the provision of services.

2.4   The following do not constitute Complaints. Customers raising such questions or matters should be addressed accordingly:

2.4.1   General questions about our services;

2.4.2   Matters concerning contractual or other legal disputes;

2.4.3   Formal requests for the disclosure of information including, but not limited to, those made under applicable legislation.

3. Receipt and Recording of Complaints

3.1   Customers may make Complaints to Discern Genomics using any of the following methods:

3.1.1   In writing, addressed to Dr Guan Wang, Director, Discern Genomics Limited, Sussex Innovation Centre, Science Park Square, University of Sussex, Falmer, East Sussex, BN1 9SB;

3.1.2   By email, addressed to Dr Guan Wang, Director at complaints@discern-genomics.co.uk;

3.1.3   Using our Complaints Form, available at www.discern-genomics.co.uk/complaints-form, following the instructions included with the form;

3.1.4   By contacting us by telephone on +44 (0)1273 704 472.

3.2   Upon receipt of Complaints, the following steps should be taken within 2 Business Days:

3.2.1   If a written Complaint is received by post, the Director of Discern Genomics Limited must date-stamp the letter on receipt, create a new entry in the complaints log, scan and securely store a digital copy in the secure digital complaints folder, and file the original document in a locked physical folder;

3.2.2   If a written Complaint is received by email, the Director of Discern Genomics Limited must save the email and any attachments in the secure digital complaints folder, create a new entry in the complaints log, and record the date and time of receipt in the complaints log;

3.2.3   If a Complaints Form is received (via the website), the Director of Discern Genomics Limited must save the completed form in the secure digital complaints folder, create a new entry in the complaints log, and record the date and method of receipt in the complaints log;

3.2.4   If a Complaint is made by telephone, the Director of Discern Genomics Limited must make a written record of the Complaint at the time of the call, including the key concerns raised, and confirm the details with the complainant during the call where possible. A digital copy of this record shall be securely stored, and the Complaint entered into the complaints log within 2 Business Days.

3.3   All Complaints shall be given a Complaint Reference and the investigation thereof shall begin within 3 Business Days.

3.4   All Complaints shall be acknowledged in writing within 3 Business Days of receipt by the sole Director of Discern Genomics Limited. The acknowledgement shall inform the Customer of their Complaint Reference, by whom their Complaint is to be handled, and shall include copies of our Customer Complaint Policy and this Complaints Handling Procedure.

4. Complaint Information

4.1   Customers are advised in our Complaints Policy that the following information should be provided in as much detail as is reasonably possible when making a Complaint:

4.1.1   The Customer’s name, address, telephone number and email address, indicating any preferred method of communication;

4.1.2   If the Customer is being represented by a third party, the information set out in Section 4.1.1 should be provided in reference to both parties;

4.1.3   If the Complaint relates to a particular transaction, the Subscription ID or the session booking reference;

4.1.4   If the Complaint relates to a particular employee, agent, subcontractor, the name and, where appropriate, position of that employee, agent, subcontractor;

4.1.5   Further details of the Complaint including, as appropriate, all times, dates, events, and people involved;

4.1.6   Details of any documents or other evidence on which the Customer wishes to rely in support of the Complaint;

4.1.7   Details of how the Customer would like Discern Genomics Limited to resolve the Complaint. Whilst we undertake to make all reasonable efforts to accommodate such requests, however, we are not bound to take any action beyond that which we may be contractually or otherwise legally obliged to take.

4.2   If the information detailed in Section 4.1 is missing, insufficiently detailed, or incomplete, the Director of Discern Genomics Limited should contact the Customer within 2 Business Days of receipt of the Complaint to request further information.

5. Complaints Handling

5.1   At the date of this complaints handling procedure, Discern Genomics Limited is operated by a sole Director who personally delivers all services and shall handle all Complaints.

5.2   Upon receipt of a Complaint, the Director shall consider the Complaint and make a decision within 20 Business Days whether to:

5.2.1   Investigate the Complaint fully if it is considered to be valid, in which case the procedure should resume from Section 5.3; or

5.2.2   Dismiss the Complaint if it is considered to be invalid, in which case the Customer shall be informed of the decision in writing within 5 Business Days.

5.3   Subject to delays arising from circumstances beyond the Director’s reasonable control (including, but not limited to, delays in other persons responding to communications), the Director shall have a period of 20 Business Days in which to fully investigate the Complaint and to decide upon appropriate Resolution Action(s).

5.4   If the Complaint relates to (a) particular employee(s), agent(s), subcontractor(s) (a “Complainee” or “Complainees”), the Director shall inform the Complainee(s) in question of the Complaint and arrange meetings and/or telephone calls as required to discuss the Complaint. In such cases, the Complainee(s) should not, under any circumstances, contact the Customer directly regarding the Complaint. If the Customer contacts the Complainee(s) directly regarding the Complaint (which they are requested not to do in our Complaints Policy), the Complainee(s) should respectfully refuse to discuss the matter, referring the Customer to Section 5.3 of our Complaints Policy. Any such contact should be reported to the Director.

5.5   Where the Director requires additional information or evidence in support of the Complaint, the Director shall contact the Customer using the Customer’s preferred method of communication, stating clearly what information or evidence is required. Customers should be respectfully reminded that any delay in their response to such a request may delay the resolution of their Complaint, as per Section 5.4 of our Complaints Policy.

5.6   If a Customer is unable or unwilling to provide information or evidence requested under Section 5.5, reasonable endeavours shall nevertheless be used to resolve the Complaint. If, however, it is not possible to uphold the Complaint in the absence of the requested information or evidence, the Complaint may be closed and the Customer informed of the outcome in accordance with Sections 5.9 to 5.11.

5.7   The Director shall examine and evaluate the Complaint, taking full account of all relevant statements, information, evidence and circumstances and shall maintain full objectivity and fairness at all times.

5.8   Subject to the exceptions in Section 5.8.1, during the investigation of the Complaint, all records, information, employees, agents, and subcontractors that may be necessary to enable an impartial and thorough investigation shall be made available.

5.8.1   Access to the following records and/or information is restricted and shall require the authorisation of the Director:

a)   Intake forms and any records containing special category data (including genetic, health, or family medical information);

b)   Session notes, transcripts, or recordings of support sessions;

c)   Personal data that identifies third parties (e.g. family members);

d)   Any records subject to legal professional privilege, regulatory restrictions, or statutory confidentiality obligations.

5.9   Following examination of the Complaint, the Director shall reach a decision within the time period set out in Section 5.3 (subject to the exceptions noted therein). Resolution Actions that may be chosen are set out in Section 6.

5.10   Upon reaching a decision under Section 5.9, the Director shall send an Investigation Report and Decision Letter to the Customer by first class post or by email, as appropriate. Decision Letters shall set out the decision and the Resolution Action(s). The Customer shall also be reminded of their right to seek External Resolution of their Complaint. One digital copy of the Investigation Report and Decision Letter should be retained in the secure digital complaints folder for record-keeping and quality improvement purposes. Access to these records shall be limited to the Director.

5.11   If a delay either occurs or is considered likely to occur at any stage of this procedure, the Director shall inform the Customer using the Customer’s preferred communication method. The Customer should be informed of the length or likely length of the delay and the reasons therefor.

6. Resolution Actions

When handling Complaints the following Resolution Actions may be selected, as appropriate to the facts and circumstances of a Complaint:

6.1   Providing an explanation or clarification to address any misunderstanding or miscommunication;

6.2   Issuing a formal apology and assurance of steps taken to prevent recurrence;

6.3   Correcting, amending, or re-issuing any documentation, records, or information provided in the course of services;

6.4   Offering a re-scheduling of sessions, additional support, or repeat delivery of part of the service at no extra charge (where appropriate);

6.5   Providing a partial or full refund where service delivery has demonstrably fallen short of agreed standards;

6.6   Implementing internal changes or improvements to policies, processes, or training identified as necessary through the Complaint;

6.7   Any other fair and proportionate action considered reasonable to resolve the Complaint to the Customer’s satisfaction, in line with our legal and professional obligations.

7. External Resolution

7.1   Customers have the right to seek External Resolution of Complaints if they are not satisfied with the outcome resulting from this Complaints Handling Procedure.

7.2   The Centre for Effective Dispute Resolution (CEDR) may handle any and all such referrals in accordance with its published rules, procedures, and guidance on alternative dispute resolution (ADR). The appropriate representative(s) of CEDR may require contact with Discern Genomics Limited personnel and may require access to documents and information pertaining to a Complaint in the event that a Customer refers their Complaint for External Resolution. Any and all such interactions between CEDR and Discern Genomics Limited shall take place via the Director of Discern Genomics Limited (unless otherwise authorised by the Director).

7.3   Any and all requests made by CEDR for evidence or information, whether written or oral, shall be answered without undue delay, subject to the approval and authorisation of the Director, who shall ensure that said request is reasonable and pertinent given the nature of the Complaint.

7.4   Discern Genomics Limited will engage with CEDR’s process in good faith and will give due consideration to its findings and recommendations. Where appropriate, agreed Resolution Actions arising from CEDR’s process will be implemented promptly and recorded in the complaints log.

8. Implementation of Resolution Actions

Upon the conclusion of a Complaint, the Resolution Action(s) settled upon shall require implementation in a timely manner. Responsibility for the implementation of Resolution Actions ultimately lies with the Director of Discern Genomics Limited.

9. Recording of Resolution Actions

9.1   Upon the conclusion of a Complaint and the implementation of the applicable Resolution Action(s), the Director shall log in the complaints log the Complaint Reference, the nature of the Complaint, the Resolution Action(s) taken, the date of resolution, and confirmation that the Customer has been informed of the outcome.

9.2   Copies of the Investigation Report, Decision Letter, and any related correspondence with the Customer shall be securely stored in accordance with our data protection policy. These records shall be retained for a period of 7 years, aligning with the retention period for health-related data, and shall then be securely deleted or anonymised.

10. Confidentiality and Data Protection

10.1   All Complaints, Appeals, evidence and other information gathered, held and processed under this Complaints Handling Procedure shall be treated with the utmost confidence at all times. Such information may be shared with employees, agents, subcontractors of Discern Genomics Limited only to the extent required to resolve the Complaint in question in accordance with this Complaints Handling Procedure.

10.2   In the event that the details of a Complaint are to be used for training or quality improvement purposes, in which case they will be shared with other employees, agents, subcontractors of Discern Genomics Limited beyond the scope of this Complaints Handling Procedure, the relevant Customer’s express permission must first be sought using that Customer’s preferred contact method. Personal details (that is, anything that may be used to identify the Customer) shall be removed from all information so used. Such permission may be revoked at any time in accordance with the Customer’s right to do so under Section 6.2 of our Customer Complaints Policy.

10.3   All personal information collected by Discern Genomics Limited (including, but not limited to, Customers’ names and contact details) shall only be collected, used and held in accordance with the provisions of UK data protection law (including but not limited to the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003) and Customers’ rights thereunder, as set out in our Privacy Policy available from www.discern-genomics.co.uk/privacy-policy.

11. Procedure Review and Responsibility

11.1   Overall responsibility for this Complaints Handling Procedure and the implementation thereof lies with the sole Director of Discern Genomics Limited.

11.2   This Complaints Handling Procedure shall be reviewed regularly at intervals of not more than 12 months and shall be updated as required.

11.3   This Complaints Handling Procedure was adopted on 5 June, 2026.

11.4   This Complaints Handling Procedure was last reviewed on 5 June, 2026.