Complaints & Disputes Procedure.

Document IDIDN-UK-POL-011
Version 1.0
ClassificationInternal
Owner UK Costumer Success Manager
Approved byDirector Global Regulatory & Government Affairs
Effective date 27/04/2026
Review cycleAnnual

1. Purpose

This procedure establishes how IDnow GmbH receives, investigates, resolves, and records complaints and disputes relating to its identity verification services certified under the UK Digital Identity and Attributes Trust Framework (DIATF).

2. Scope

This procedure applies to:

  • Complaints from end users (identity subjects) about the identity verification process.
  • Complaints from relying parties or other trust framework participants.
  • Disputes between IDnow and relying parties, users, or other certified providers.
  • Escalations to or from regulatory bodies.

3. Definitions

Complaint: An expression of dissatisfaction by a user, relying party, or third party regarding IDnow’s identity verification services or conduct.

Dispute: A disagreement between IDnow and another trust framework participant that cannot be resolved through normal business communication.

Complainant: The individual or organisation raising the complaint or dispute.

4. How to Raise a Complaint or Dispute

Complaints and disputes may be submitted via:

These details are published on the IDnow website and within the service interface.

5. Complaints and Disputes Handling Process

5.1 Acknowledgement

All complaints are acknowledged within 2 working days of receipt. The acknowledgement confirms the reference number and expected timeline.

5.2 Investigation

The UK Costumer Success Manager assigns an investigator, gathers relevant evidence, and determines the root cause. Target completion: 10 working days.

5.3 Resolution

A written response is provided to the complainant within 15 working days, setting out the findings and any corrective actions taken. If the timeline cannot be met, an interim update is provided with a revised deadline.

5.4 Escalation

If the complainant is dissatisfied with the outcome, they may request escalation to the Head of Costumer Success. The escalation is reviewed within a further 10 working days.

Where appropriate, complainants are informed of their right to refer the matter to relevant regulatory channels, including the Information Commissioner’s Office (ICO) for data protection matters or the Office for Digital Identities and Attributes (OfDIA).

6. Regulatory Channels

IDnow’s complaints and disputes procedures take account of the following regulatory channels:

  • OfDIA – as the governing body for the UK DIATF.
  • ICO – for complaints relating to personal data processing.
  • Any Conformity Assessment Body (CAB) engaged for DIATF certification.

Where a complaint raises issues that may require regulatory notification, the UK Compliance Manager assesses the need for onward reporting.

7. Record Keeping

IDnow maintains a complaints and disputes register that records:

  • Date received and reference number.
  • Complainant details (anonymised where appropriate).
  • Nature of the complaint or dispute.
  • Investigation findings and corrective actions.
  • Outcome and date of closure.
  • Any escalation or regulatory referral.

Records are retained for a minimum of 5 years from the date of closure. Complaint records are made available to OfDIA or the appointed CAB upon request.

8. Publication

A summary of this procedure, including contact details and expected timelines, is published on the IDnow website and is accessible to all users and relying parties.

9. Review and Continuous Improvement

This procedure is reviewed at least annually, or following a significant complaint, regulatory change, or audit finding. Trends from the complaints register are reported to management as part of the management review process.