Scottish Widows Complaint: PO-14071

This page presents two chronological lists of the main events of the case, with summary information and links. These reference all relevant correspondence (excluding trivial items, or those not part of the case). Also referenced are details of all events involving Scottish Widows (only) in the Detailed Chronology page (this page also includes event details not directly relevant to the case).

The need to present two chronologically-ordered lists arises from the extreme delays resulting from Scottish Widows' use of post. Thus the sequence of events as seen from my side as the recipient of this post is quite different from the sequence of events from their side as sender. Only by viewing the sequence of events from both sides can one obtain a complete picture.

The first list contains the complete significant correspondence, both with Scottish Widows and with other parties, in chronological order of the dates on which I received it (my side). The second list contains relevant correspondence with Scottish Widows (only), in chronological order of the dates on which the documents were sent (their side).

The following color coding is used for descriptions: letter | telephone/fax | email.

Links to PDF documents open in one of up to three additional windows (or tabs) in the following categories: Correspondence (Scottish Widows); Correspondence (Other); General. You can leave each window open and click more links in that category to add more documents to it; you can then navigate through the documents added to that window using the browser left/right arrows. Using this facility, you can create a selection of documents in each category for review. NB: This does not work in the current version of Microsoft Edge, as the new document replaces rather than adds to the existing window contents. If you close the window, a fresh one will be created next time. Links to web pages and the MP3 audio file open in a new window.

Events involving Scottish Widows and Other Parties (My Side)

The date in the first column is that on which I sent or received the document(s), and provides a link to further details. For events involving Scottish Widows, this link is to the corresponding event details on the Detailed Chronology page of the website; for those involving other parties, it is to the PDF document containing the correspondence.

The second column gives the sender and receiver of the correspondence:

ICM	Ian Clive McInnes
SW	Scottish Widows
TPAS	The Pensions Advisory Service
TPO	The Pensions Ombudsman
WIX	Wixted & Co. Solicitors
AF	Action Fraud

15 Mar 2016	ICM-SW	Sent fax to enquire on options for pension encashment.
18 Mar 2016	SW-ICM	Received an email describing a paperless procedure involving a telephone interview.
05 Apr 2016	ICM-SW	Nightmare 1.5 hour telephone interview with Scottish Widows.
05 Apr 2016	SW-ICM	Received an email and attached PDF document specifying verification and certification requirements.
11 Apr 2016	ICM-SW	Sent an email with 8 PDF verification documents attached.
21 May 2016	ICM-SW	Sent a follow-up email, after having received nothing.
16 Jun 2016	SW-ICM	Received four postal items, including a letter and (changed and erroneous) form in rejection of my documents. And on this very day, Scottish Widows sent a letter terminating my application.
26 Jun 2016	ICM-SW	Requested a copy of Scottish Widows' Internal Dispute Resolution Procedure (not realising then that this does not apply to Personal Pension Plans). But this clearly gave Scottish Widows the hint that I was about to make a complaint.
01 Jul 2016	SW-ICM	Received two password-protected PDF documents. The first (dated 27 June) claimed ignorance of the term Internal Dispute Resolution Procedure. The second (dated 30 June after attempts to telephone me) requested me to post the (now valid) documents.
06 Jul 2016	TPAS-ICM	Received a very helpful email from TPAS (which includes the text of my online application at the top). This puts me right about the IDRP. It also states that evidence of identity is not a pensions-specific matter, so they are not experts in this area; but supplied useful links to info on government anti-money laundering regulations. This provided the starting point of my investigations into verification requirements, as it was clear that Scottish Widows applies them only to pensions.
06 Jul 2016	SW-ICM	Received seven postal items, including four further requests for documents with forms. The first three of these forms was the same as that sent with the rejection letter; the fourth form was a new version similar (but not identical) to the PDF form. The last request of 01 June was sent in response to my follow-up email.
10 Jul 2016	ICM-SW	Sent an interim (but detailed) complaint by email.
13 Jul 2016	SW-ICM	Received an email in response to the above, offering only discussion by telephone, and discouraging the use of email (citing concerns over my online safety). A further identical email was received two days later on 15 June.
17 Jul 2016	ICM-SW	Rejected discussion by telephone for three very clear reasons: firstly I had made clear that my impaired hearing made this difficult; secondly, that this would leave no record for TPO to review (their clear reason for offering only this medium); and thirdly that discussion by telephone was not appropriate for this involved case. I gave a link to my website.
17 Jul 2016	ICM-TPAS	Sent a further email to TPAS, stating that I had made a complaint to Scottish Widows, and giving a link to my website.
18 Jul 2016	TPAS-ICM	Reply from TPAS, indicating that they were set up to deal with documents rather than websites, and again intimating that they could not help with evidence of identity issues.
24 Jul 2016	ICM-TPAS	Enquired what documentation TPAS required, and how they could help with my case. I gave a link to my newly-created Document List page to give easy access to printable documents.
01 Aug 2016	SW-ICM	Received an offer to accept my national ID card (alone) as verification, provided it were emailed by my bank (with some additional stipulations that appeared to be invented on the spot).
04 Aug 2016	SW-ICM	Received two postal items: the first (sent 16 June) closing my application; the second (sent 30 June) a copy of the email of that date requesting me to post the (now acceptable) documents.
19 Aug 2016	TPAS-ICM	Received a notification that my application is to be passed to another advisor.
19 Aug 2016	TPAS-ICM	Received another acknowledgement, giving my case number.
28 Aug 2016	ICM-TPO	Made an initial enquiry to TPO, not being sure at what stage they would handle my complaint.
30 Aug 2016	TPO-ICM	Reply from Carl Monk (Assistant Adjudicator), stating that they will need a Final Response from Scottish Widows to proceed.
08 Sep 2016	TPAS-ICM	Initial email from my TPAS caseworker, raising doubts as to what they could do, as they were not experts in verification. However, they offered to question Scottish Widows' postal responses to my emails.
11 Sep 2016	ICM-TPAS	Reply to the above, setting out my case more fully.
15 Sep 2016	SW-ICM	Received four postal items, including a follow up to the email of 01 August, and their Final Response. The latter refers me to the Financial Ombudsman, and encloses their leaflet. It deals mainly with the delays (for which the blame is laid squarely on the Mexican postal service), and ducks the main issue (that I legitimately cannot fulfil their "verification" requirements).
18 Sep 2016	ICM-TPAS	Update to state that I had received Scottish Widows' Final Response, and had prepared a list of questions to put to them to probe their verification policies. They appear to apply these only to certain types of pension policy, which is not consistent with their being legitimate AML measures.
23 Sep 2016	TPAS-ICM	Reply to the above, offering to pursue Scottish Widows' use of postal communications, but not wanting to get involved with AML issues or Scottish Widows' policies. It suggested that I ought to send the list of questions to Scottish Widows myself, but offered to comment on any replies (none were received).
24 Sep 2016	ICM-TPO	Sent application form and covering letter to TPO, by DHL Express Letter. This cost the equivalent of around £50. The alarming error in selection of post rather than email as my preferred means of communication is corrected on the form I sent (I did not get chance to rescan it first).
25 Sep 2016	ICM-TPAS	Sent reply to TPAS stating that I did not feel that questioning Scottish Widows' use of post would achieve a useful outcome. I also stated that their Final Response was to deny me any means of encashment, and having no prospect of a satisfactory arbitrated settlement, I had sent an application to TPO. I also stated that I would like my list of questions to be raised with Scottish Widows, but queried how best to do this in such a way as to put pressure on them to respond.
26 Sep 2016	TPAS-ICM	Reply from TPAS, closing my case as I had approached TPO, but suggesting that I put the questions to Scottish Widows myself before TPO starts to investigate.
29 Sep 2016	ICM-SW	Sent PDF document containing list of Questions (mainly to probe their verification policies).
29 Sep 2016	ICM-TPO	Sent a follow up to my application to TPO (that they had just received), giving links to my online documents, and stating that I had sent Scottish Widows the list of questions.
30 Sep 2016	TPO-ICM	Acknowledgement from TPO, indicating that it would be several weeks before they decide whether to investigate my complaint. Hopefully the decision will be made on the criteria given in their leaflet, which I clearly fulfil; I would be mortified if they did not pursue this case.
04 Oct 2016	TPO-ICM	A further acknowledgement, from Carl Monk (who responded to the initial email I sent to TPO, and will be my main contact).
10 Oct 2016	SW-ICM	Received three postal items, including complaint information arising from the email of 13 July, which inappropriately refers one to the Financial Ombudsman.
30 Oct 2016	ICM-TPO	Email to TPO, asking whether it was worthwhile for me to chase up on the list of questions I sent to Scottish Widows.
31 Oct 2016	TPO-ICM	Reply to above, suggesting that I wait another month.
10 Nov 2016	SW-ICM	On 08/09 November received 5 telephone calls with 3 voicemail messages requesting me to call back.
10 Nov 2016	ICM-TPO	Email to TPO, reporting the telephone calls and voicemail messages from Scottish Widows.
23 Nov 2016	TPO-ICM	Reply to the above, suggesting that if I did not want to return their calls, I should email them requesting a written response.
23 Nov 2016	ICM-SW	Email sent to Scottish Widows in response to their voicemails, following the above suggestion.
23 Nov 2016	ICM-TPO	Notified TPO that I had sent the above email.
02 Dec 2016	TPO-ICM	Email from TPO advising me of email encryption.
02 Dec 2016 02 Dec 2016	TPO-ICM	Email with password-protected PDF requesting me to resend the link in my email of 23 November, as their system denied access to it.
03 Dec 2016 03 Dec 2016	ICM-TPO	Email to TPO sent by the secure service with a PDF document both as a link and as an attachment.
04 Dec 2016	ICM-TPO	Follow up to the above, using the normal service.
12 Dec 2016	TPO-ICM	Acknowledgement of my emails of 03/04 December.
18 Jan 2017	TPO-ICM	Request for Customer Survey participation from another department, stating that my case had been closed.
18 Jan 2017	TPO-ICM	Correction, but only to say that they had sent the wrong version of the form, and would subsequently send me another email.
18 Jan 2017	ICM-TPO	My response to the above survey emails, reflecting my concern (especially bearing in mind the lack of action on my case). I asked for reassurance that my case would be investigated, and some indication of when this would happen.
20 Jan 2017	TPO-ICM	The reply was hardly reassuring. He said that the survey was sent to the wrong people (whereas the survey department said that they sent the wrong version). Furthermore, the only "reassurance" given was repetition of a statement of 31 October 2016 "your application is earmarked for an adjudicator", this time in the present perfect tense; this unfortunately did nothing to affirm that my case had not been closed subsequently.
15 Feb 2017	TPO-ICM	Another request for Customer Survey participation (this time presumably with the correct version of the form). Either they had failed to correct an error made some four weeks ago, or my case had indeed been closed as they stated.
05 Apr 2017	ICM-TPO	It is now over 6 months since I was told that my application "is earmarked for an adjudicator", and I have received not a shred of information on my case since. Bearing in mind this and the survey issues (plus the gravity of the case), it should not be surprising that I was in despair. So I emailed TPO expressing my concerns, and again asking for reassurance that they would investigate my case, and could deal with it appropriately.
07 Apr 2017	TPO-ICM	Reply stating that my email had been forwarded to Barry Berkengoff. At last I had the the name of the Senior Adjudicator who was to investigate my case.
29 Apr 2017	ICM-WIX	Enquiry sent to award-winning solicitors Wixted & Co, as I was becoming increasingly worried about the situation with TPO. This was the only appropriate practice I could find that supplied an email address, rather than offering only callback by telephone. However, in the great British tradition, I was not given the courtesy of a reply.
14 May 2017	ICM-TPO	Five weeks later, I have still received no response, or any other information on my case. For some time now, I have been facing serious financial difficulties, and my situation is becoming more perilous with every passing week. This, the prospect of having lost my personal pension funds, the gross injustice exposed by these abuses, and the lack of any legal remedy, have made me despondent; and my depressed state of mind is also adversely affecting my partner. I sent this to Barry Berkengoff (I surmised his email address as it was not given), challenging him to give me some proper reassurance.
15 May 2017	TPO-ICM	At last, a response from the investigator of my case. But this raises many doubts as to what TPO can and will do.
17 May 2017	ICM-TPO	My response to the above, urging him to look at the website that I have spent hundreds of hours developing. I express concerns over whether TPO is the right body to deal with this case.
20 May 2017	ICM-AF	I feel a moral duty to ensure that the fraudulent part of Scottish Widows' conduct is dealt with appropriately, so I made an online report (unfortunately belated) to Action Fraud.
22 May 2017 22 May 2017	AF-ICM	Received an acknowledgment, with attached PDF document (I obscured the password for security reasons).
22 May 2017	TPO-ICM	Received a more informative response from BB. This raised questions as to whether TPO would investigate my case at all now that I had reported it to Action Fraud (even though there was no indication that TPO would deal with its criminal side, and in any case no guarantee that AF would investigate it).
24 May 2017	ICM-TPO	My reply, stating that I had reported my case to Action Fraud, out of concerns that its criminal aspect would otherwise not be dealt with.
26 May 2017	TPO-ICM	Response to the above, stating that his jurisdiction is limited to instances of maladministration, and that he would review my website when he had access. I was concerned that, despite the statements I made in my emails, that he seemed to think that my problems were due to slightly different processes for overseas customers to ensure appropriate ID checks are made.
10 Jun 2017 10 Jun 2017	ICM-TPO	If he had not obtained access to my website by now, he most likely never would, so I sent an email with a ZIP of most of my website, to be followed by another email with the remainder. But this was rejected by their delivery system. I therefore sent another email without the attachment. The second email here is that which was to contain the remaining separate files.
13 Jun 2017	TPO-ICM	He indicated that the access denial was long-term, but would access my website using another connection.
14 Jun 2017	ICM-TPO	Acknowledged his willingness to do the above.
15 Jun 2017	TPO-ICM	He stated that he would review my website early next week.
12 Jul 2017	ICM-TPO	It seems clear that he has still done nothing, so another email to chase up - this time expressing my concerns more bluntly.
14 Jul 2017	TPO-ICM	As expected, received a prompt reaction to my email, denying any wrongdoing, and stating that the delay was simply due to a heavy workload and that he does investigations only one day a week. He offered no evidence of progress on my case, saying only that he would "be in touch shortly". This is exactly what he said in his email of 15 May (received only after surmising his email address and contacting him directly after waiting 5 weeks without response). And he has clearly been sitting on my case since late October 2016. Even if there were a genuine intent to investigate it, these circumstances indicate that this would not even start for many more months, maybe years. I will therefore not pursue the matter further, to save my health and wellbeing.

Events involving Scottish Widows (Their Side)

The first column contains a link to the corresponding document, and gives its date. The second column contains a link to details in the Detailed Chronology page; for items sent by Scottish Widows, it gives the date on which the communication was received.

15 Mar 2016	(ICM)	Fax to enquire on options for pension encashment.
18 Mar 2016	18 Mar	Email response to fax enquiry.
05 Apr 2016	(ICM)	Telephone interview with Scottish Widows.
05 Apr 2016	05 Apr	Email specifying general verification and certification requirements.
05 Apr 2016	05 Apr	PDF form, sent as an attachment to the above email, specifying accepted verification documents for Name and Address, plus additional certification and other requirements.
05 Apr 2016	16 Jun	Confirmation of telephone interview for policy P56879Q.
05 Apr 2016	06 Jul	Confirmation of telephone interview for policy N80803X.
06 Apr 2016	06 Jul	Request for documents for policy N80803X, comprising letter plus form. However this paper form is quite different from the PDF equivalent, and contains conspicuous errors. Both specifications affecting me have changed. The printout is badly paginated. It now seems that this version (which I denote Mk I) is older than the PDF - perhaps it is from a stock of preprinted copies.
06 Apr 2016	06 Jul	Letter and form identical to the above, but for policy P56879Q.
11 Apr 2016	(ICM)	Email with detailed explanations in response to verification requirements, with 8 document scans attached.
14 Apr 2016	16 Jun	Letter in rejection of my documents, with another Mk I form (this time properly paginated).
21 May 2016	(ICM)	Follow-up email, having received neither payment nor reply.
24 May 2016	06 Jul	Request for documents for policy P56879Q with another Mk I form, identical to that sent on 14 April, but occupying two more pages.
26 May 2016	10 Oct	Request for documents for policy P56879Q, identical to the above except having previous pagination.
01 Jun 2016	06 Jul	Request for documents for policy N80803X, referring to my follow-up email. But this has both a different letter (now apparently requiring original documents as well as certified ones) and a Mk II form (similar but not identical to the PDF version).
16 Jun 2016	04 Aug	Letter closing my application, as my documentation was inadequate and I had not responded to their requests for further information. This was sent just 15 days after the above response to my follow-up email; so their allowed response time of 14 days must include post both ways, and is rigidly enforced. And the fact that they had recently received this follow-up email discredits their statement we must assume that you do not wish to proceed with this claim.
26 Jun 2016	(ICM)	Request for Scottish Widows' IDRP (complaint hint).
27 Jun 2016	01 Jul	Password-protected PDF claiming ignorance of the term IDRP.
30 Jun 2016	01 Jul	Password-protected PDF requesting me to post the (now apparently acceptable) documents. Sent after telephoning me without success.
30 Jun 2016	04 Aug	Postal version of the above.
10 Jul 2016	(ICM)	Interim but detailed complaint.
13 Jul 2016	13 Jul	Response from Specialist Complaints, offering only discussion by telephone, and refusing to deal with my complaint by email.
15 Jul 2016	15 Jul	Another email from Specialist Complaints, identical to the above.
15 Jul 2016	10 Oct	Letter from the same source containing complaint information (inappropriately referring me to the Financial Ombudsman).
17 Jul 2016	(ICM)	My reply to the above emails, declining discussion by telephone, and giving a link to my website.
01 Aug 2016	01 Aug	Email in response to my interim complaint, offering to accept a scan of my certified ID card (alone) as verification if it were emailed by my bank (with certain dubious stipulations).
22 Aug 2016	15 Sep	Follow-up letter to the above (which did not appear to need a reply).
24 Aug 2016	15 Sep	Final response, again referring me to the Financial Ombudsman. This ignores the main issue and reasserts their original verification requirements, blaming the poor communication on the Mexican postal service. Again, only telephone is offered for any follow up.
29 Sep 2016	(ICM)	Sent list of Questions to Scottish Widows to both the address given for verification documents, and to the Specialist Complaints who offered to talk to me on the telephone. Received notification that the latter will be out of the office until 10 October.
10 Nov 2016	10 Nov	On 08/09 November received 5 telephone calls with 3 voicemail messages requesting me to call back.
23 Nov 2016	(ICM)	Email sent to Scottish Widows in response to their voicemails, at the suggestion of TPO.