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WebTraderUK - Code of Practice

A trader, which is a current member of WebTraderUK, must prominently display the WebTraderUK logo on their website and agree to comply with the WebTraderUK Code of Practice. This does not mean that WebTraderUK or any of its associated companies recommends the products offered by the trader or the customer service provided outside the areas covered in the Code.

Part 1: WHAT YOU MUST DO
You must provide clear and adequate information about your products and services to enable consumers to make informed decisions.

You must prominently display the WebTraderUK logo on your website. It is not required that the logo appears on your homepage, but it is recommended. The logo must be linked to www.webtraderuk.org.uk where consumers will be able to access the WebTraderUK Code of Practice.

1.1 Website

You must provide the following information on your website. This information must be presented clearly and be available to the consumer prior to purchase of any of your products or services.
  • Your full contact details, including your phone and fax numbers, geographic and email addresses, and a contact name or department for complaints or queries.
  • The price of your goods and/or services. This must be easily found and clearly shown in £'s sterling. You must display the actual price the consumer will be charged without any hidden extras such as tax, packaging or delivery. If extra charges, such as delivery, cannot always be included in the price of the product (e.g. due to alternative delivery options) the full price must be clearly displayed prior to purchase. You must also include your VAT registration number (if applicable).
  • Clear ordering instructions
  • A description of the different ways of paying
  • A customer services phone number, the times when the service is available and the cost of the calls. All customer service staff must be aware of your obligations under this Code.
  • The right to cancel the contract and how to exercise this right.
  • Any restrictions including how long the offer remains valid and any cooling off periods
  • The terms and conditions of your contract displayed clearly and plainly. They must be easily found on your website. You must state that the terms of the contract do not affect consumers' statutory rights.
  • Your privacy policy. You must provide your customers with a privacy policy to give information regarding the use of their personal data, including any use for direct marketing purposes. If you intend to share your customers email addresses with third parties you must first obtain the customer’s consent. If you intend to use customer data for direct marketing purposes or if you intend to pass data to third parties for marketing purposes, you must obtain the customer’s prior consent at the point of data collection.
  • Details of any relevant professional body or bodies you belong to.
  • You should provide a brief, simply-worded summary of the protection that your membership of WebTraderUK provides to the consumer. This does not have to be on your home page, but should be easily accessible (e.g. on an easily accessed help page). As a minimum, you should tell customers that they have added protection for delivery, payment security, after-sales service and complaint resolution, that you comply with data protection laws, and that you will not sell their email address or other personal information without permission.
1.2 Advertising

Your online advertising must meet the standards of the British Code of Advertising, Sales Promotion and Direct Marketing. See the CAP Code at www.cap.org.uk. You must also comply with the rulings of the ASA, which you can see at www.asa.org.uk. You should clearly identify any advertising on your website from other people or organisations. You must take care not to create a demand that cannot be met.

1.3 Returns and refunds

Your website, advertising and direct marketing to consumers must be able to be read by those with poor eyesight. This may include, where relevant, a separate version for those with disabilities (e.g. a separate, clearly identified large-font website, or Braille version of offline literature).

You should provide a way for the deaf to contact you for queries and complaints. You are advised to offer support by email but providing a Minicom or similar service would be an acceptable alternative.

You should cater for any other disabilities wherever it is relevant and realistically feasible.

1.4 International consumers

If you trade internationally, you should consider offering versions of your website or other literature in alternative languages. This is not compulsory, but if you provide information in non-English languages you should either be able to answer queries and complaints in these languages, or if not, clearly state prior to purchase that you do not provide this service.

1.5 Returns and refunds

If you have a returns and refunds policy that offers consumers more rights than they have under the law or this Code, you should inform the customer clearly what these rights are, with easy to follow instructions on how to take advantage of these rights. You must also state that these rights will not affect the consumer’s statutory rights.

1.6 Guarantees

If you provide a guarantee or warranty, you must make the following clear:
  • what is covered
  • for how long
  • that the guarantee or warranty does not affect consumers' statutory rights.
1.7 The Sale
  1. Confirmation
    Before the contract, you must confirm the total price the consumer will pay. After the contract has been agreed, you must confirm the order by email or post immediately after the order is placed. The confirmation must include:

    • your company name
    • an order or reference number
    • the total price, including postage and packing and all taxes
    • instructions on how to cancel the contract, including where the cancellation notice should be sent, that you require such cancellation notices to be in writing, if this is the case, that the consumer is under a duty to take reasonable care of the goods, and whether the customer must pay for the cost of returning the goods or make them readily available for collection.


  2. Cancellation
    Unless the law permits otherwise, you must tell customers that they have a right to cancel their order in the following circumstances:

    • provided you have already told your customer in writing of their right to cancel, consumers can cancel goods within seven working days after the day on which the goods have been received
    • if you do not tell your customer in writing of their right to cancel, either before or when the goods are delivered, but do so within three months after the goods are received by the customer, the cancellation right ends seven working days after the day on which the customer receives the written information
    • if you do not tell the customer of their right to cancel, the customer’s cancellation rights will end after three months and seven working days counting the day after the day on which the customer received the goods
    • in the case of services, consumers can cancel up to seven working days from the day after the conclusion of the contract – if you have told the customer of their right to cancel, the right ceases once the service has begun with the customer’s agreement.

    You must tell the customer that they have the right to cancel the goods either prior to the conclusion of the contract or, at the latest, at the time of delivery of the goods – if delivery is not to a third party. As regards services, you must tell the customer of the right to cancel prior to the commencement of the contract. You can, prior to the conclusion of the contract, tell the consumer in writing that he will not be able to cancel the contract once the performance of the services has begun with his agreement.

    When the consumer cancels, you must return their money within 30 days of the cancellation. You may charge the customer the cost of returning the goods but only if you stated this in your terms and conditions at the time of sale. However, you will have to reimburse the cost of the goods/service plus any postage and package/delivery charges paid by the consumer.

  3. Delivery
    You must deliver the goods within 30 days, unless the consumer has agreed otherwise. Prior to purchase, you must tell the consumer the date that the goods will be delivered prior to purchase and preferably offer the consumer a choice of dates. If you cannot deliver the goods on the date that has been agreed you should tell the consumer immediately and agree on another time for delivery. If you cannot agree on another time, you must offer the consumer a refund. You may also offer the consumer an alternative to the original goods ordered but if the consumer wants a refund you must give this in full immediately or at most within 30 days.

  4. Receipts
    You must provide the consumer with a receipt.

1.8 Mistakes, complaints and disputes
  1. Consumer Law
    You must meet your obligations under the consumer protection laws currently in force. You can find out more about these at the web sites via the Office of Fair Trading and the Department of Trade and Industry. You must be governed by the law of England and Wales.

  2. Faulty Goods
    If the goods fail to correspond to their description, are not of satisfactory quality or are not reasonably fit for their purpose, you must offer the consumer a remedy. Where you are notified within a reasonable time of the problems (i.e. usually perceived to be within six months of purchase), you must offer the consumer a full refund plus relevant associated losses. Thereafter, the consumer is entitled to damages, which will most commonly be taken in the form of an effective repair. If the complaint is received by you within a reasonable time, you must not insist that the consumer seek redress direct from the manufacturer under any guarantees/warranties.

  3. Mistakes in bills, receipts or payments
    You must correct any mistakes in bills, receipts or payments as soon as possible and at the latest within 30 days of agreeing to do so.

  4. Complaints
    You must have an effective system for handling complaints. Your complaints procedure must be available to read online, readily available and accessible within working hours and confidential. You must:

    • acknowledge complaints within five working days
    • advise the consumer how long it will take to resolve the complaint
    • keep the consumer informed throughout the process

    You must offer maximum cooperation with local consumer advisers or any other intermediary consulted by a consumer when making a complaint. You must provide the same level of cooperation to an intermediary acting on behalf of a complainant as you would offer to the complainant.

  5. Disputes
    You must provide details about any dispute resolution scheme you belong to, including any Ombudsman scheme or regulator.
1.9 After-sales service

You must provide a free or reasonably charged after-sales service to answer queries about products, both before and after purchase. The charge for this service must be clearly shown to the consumer prior to purchase. All queries must be dealt with in a professional and user-friendly manner, and answered in a reasonable amount of time. Usually a week to answer queries by email would be considered the maximum reasonable timescale. However, you should acknowledge that the query has been received and is being dealt with on receipt of the query and also outline the time span within which the complaint will be processed.

Please note that after-sales service is not the same as complaint handling and it is advisable to have separate contact details for each facility. You should not make any charge for complaint handling.

1.10 Privacy and security
  1. Data Protection Act
    You must meet the conditions of the Data Protection Act 1998 (DPA). When collecting personal data you must ensure that:
    • you provide customers with information on what you are going to do with their data when you collect this information. If you intend to process data for one purpose (e.g. fulfilling the order) then you can only process the information for this reason unless you also tell the customer of the other purposes (e.g. to send direct marketing) for which you would like to use the data. You must enable consumers to prevent the processing of their data for direct marketing purposes. You must display a clear and prominent statement before or at the time when the consumer provides personal information stating:

      • what data are being collected
      • how data are collected
      • who is collecting the information
      • what the data will be used for
      • if tracking technology is being used, such as cookies, you must explain why they are used and tell the consumer how to refuse such use and what this means as far as the online service is concerned.

    • you provide customers with the opportunity to opt-out of receiving marketing communications from you. If you intend to share data with third parties, which includes companies within your group, you must provide your customers with the opportunity to opt-out of this. Where you intend to share email addresses with third parties you must get the consent from your customers before you do this
    • you provide the consumer with the option to withhold personal data that are not needed for the transaction and you only collect data that are adequate, relevant and not excessive to your needs
    • you do not keep data for longer than necessary
    • you do not collect and/or further process sensitive personal data without the explicit consent of the consumer. Sensitive data are data relating to race or ethnic origin, political opinions, religion, whether a member of a trade union, physical or mental health, sexual life and criminal offences
    • you allow consumers, who submit the appropriate requests, access to their own personal information. You may charge a £10 administration fee to process such requests. Such requests must be handled within 40 days. However, you must ensure consumers are who they say they are (e.g. secure the request in writing and check signatures and/or passwords/security questions).
    • you ensure that personal data are accurate and up to date. You may want to provide an address or email address that a customer can use to verify, update or amend their personal data. You should include a statement that the updating will take place within a certain period (e.g. 40 days) from receipt of the request
    • you only hold personal data for as long as needed and for the purpose it was collected
    • you take appropriate measures to ensure personal data are secure, and there is no unauthorised or unlawful processing or accidental loss of data
    • you tell the consumer if you are going to transfer personal information outside the European Economic Area. The EEA consists of the 25 Member States of the European Union, plus Lichtenstein, Iceland and Norway.

    You should state that personal information provided to you via your website will be used only for the purposes outlined at the time of collection. You should state what those purposes are likely to be.

  2. Privacy policy
    The following sub-headings are suggested for use in your online privacy policy:

    • Introduction
      You may want to state that you take the confidentiality of personal data seriously. You should provide contact details for your customer in case they have any questions or comments on the Privacy Policy.

      You may also want to state that your Privacy Policy only relates to personal data collected by you via your website and that any personal data collected by you is used in accordance with data protection legislation.

      You may want to state that your Privacy Policy does not apply to personal data provided to you by any other means or via any other website, and that customers should be aware that if they provide personal data to other companies, the privacy polices of those companies determine the uses to which that information is put and your Privacy Policy does not apply.

    • The Data Protection Act 1998
      You may want to state that your website complies with the principles of the Data Protection Act 1998. [Please note the above points under 1.10(i) that you need to bear in mind].

    • Use Made of Personal Information
      You may want to state that personal information provided to you via your website will be used for the purposes outlined at the time of collection.

      If you use personal information for statistical analysis you should state this in your Privacy Policy, as well as at the time of data collection.

      You may want to outline the purposes for which personal data will be collected and processed. For example, to provide goods and services, newsletters, process orders, administration, and marketing, advertising and promotions (unless a customer elects to opt-out of receiving such communications), and notification of events, workshops and training session (again, unless a user elects to opt-out of receiving such communications).

      You may want to state that processing personal data for the above purposes may entail passing the information to employees, contractors, agents and/or to professional advisors. You should state if written agreements exist between yourself and such parties and that there must be no disclosure or further processing of such personal data.

      If you want to share data with third parties, as well as providing the necessary opt-out/opt-in clauses, you may also want to state in your Privacy Policy that from time to time you will share personal information with selected third parties but a customer is free to elect not to receive marketing communications from such third parties. You must state how customers can notify you of this.

    • Order Forms
      If you use an order form that also collects contact details you may want to state that the data collected on the form is used to fulfill customer orders and for billing purposes but if you have trouble processing an order, the contact details will be used to advise the user accordingly.

    • Consent
      You should state that by providing personal data to you, your customers consent to the processing of their data by you as described in your Privacy Policy.

    • Use of Data For Direct Marketing Purposes
      You may also want to state that at each point of data collection your customers are given the opportunity to opt-out of receiving future direct marketing material from you and where customers do not opt-out of such communications, you may provide information on your products, goods and services.

      You must provide customers who want you to stop sending such communications with an email address to write to.

    • Disclosure of Data to Third Parties
      Alongside the above point, you may also want to state that at each point of data collection users are given the appropriate opportunity to opt-out of or opt-in to having their personal data passed on to selected third parties.

      Again, you must provide customers who want you to stop sending such communications with an address to write to.

    • Verifying, updating and amending personal information
      You may want to give users a postal or email address to write to if they want to verify, update or amend their personal data.

      You should state that verifying, updating or amending personal data will take place within a certain timeframe (e.g. within 40 days of receipt of the request).

    • Cookies
      If you use cookies, it is useful to explain to your customers what a cookie is. A useful statement is as follows:

      “A ‘cookie’ is a small text file that is placed on a user's computer hard drive by a website. There are several types of cookie and the most common are often referred to as 'session' cookies. These are used to keep track of information needed by a user as they travel from page to page within a website. These cookies have a short lifetime and expire within a few minutes of the user’s leaving the website.

      “Other types of cookie can be used to track Internet activity after the user has left a website, these are usually sponsored by organisations external to the website being visited and are generally known as third party cookies. These usually have a long lifetime, with several months being quite common. They are 'harvested' and 'refreshed' whenever the user visits a page where the same or a similar cookie is being used.”

      You could then go on to describe the type of cookies you use via your website and what you do with the data your collect via your cookies.

    • Links to Third Party Websites
      If you link to other websites from your own website you may want to state that your Privacy Policy applies solely to the personal data collected by you and does not apply to third party websites that users may access from your website.

      You may want to state that you are not responsible for the privacy policies of third party websites and that you advise your customers to read the privacy policies of other websites before registering any personal data.

    • Security
      You may want to tell customers that you hold personal data in accordance with the security provisions of UK data protection legislation and give a telephone number or email address for questions about security.

      You must have an effective security policy that you review regularly. WebTraderUK may ask you for details of this policy and its operation.

      An effective security policy would include:

      • ensuring that your website is secure so that consumers' personal information and transactions remain confidential and cannot be accessed by non-authorised individuals
      • ensuring that the content of your site cannot be changed/amended without your knowledge or agreement
      • ensuring any subcontractors or third parties involved in transactions from your website follow your security policy
      • an assurance that there are regular reviews of the security of your systems
      • ensuring changes to your systems are made in a secure way
      • following the security guidelines of your system suppliers, including updates.
1.11 To continue WebTraderUK membership

In order to remain a member of WebTraderUK and display the logo on your website you must pay us the current annual fees. Fees are subject to change. You must also write to us on an annual basis, reaffirming your commitment to upholding the WebTraderUK Code.

You must appoint one person at your company to be responsible for compliance with the Code. It is the appointed person’s responsibility to make sure that all staff at the company are fully aware of their personal responsibilities for compliance of the Code and their legal responsibilities, and that they are trained to fulfill these responsibilities. We must be given this person’s name in writing with a signed confirmation of their responsibility. Another person can take over this position with no notice, but you must notify us in writing and again provide a signed confirmation of their responsibility. We will be available to answer any queries the appointed person has regarding compliance of the Code.

Part 2: WHAT YOU MUST NOT DO

2.1 Unsolicited commercial email

You must not send emails to consumers who have not given their consent, unless they are existing customers, or have made a purchase enquiry. You must include an unsubscribe mechanism on each unsolicited email you send to your customer database and consumers who have made a purchasing enquiry.

2.2 Children

Any communications aimed at children (i.e. a person under 18 years of age) must be appropriate to their age and must not exploit their credulity, lack of experience or sense of loyalty.

You must not accept an order from someone you know or suspect to be a child without the consent of the child's parent or guardian.

If the child is under 12 years of age, you must not collect any personal information without the consent of his/her parent or guardian. If the child is 12 years of age or over, you should only collect information necessary to send him/her appropriate communications as long as the child understands what is involved.

You must not disclose information collected from children (someone under 14) to anyone else without the consent of a parent or guardian.

You must not ask the child for personal information about other people. You must not entice a child to give personal information by offering him/her a reward or a prize.

2.3 High-pressure selling

You must not use any high-pressure selling techniques on your website or in your advertising or direct mailings. High-pressure selling is defined as any marketing whereby the consumer feels pressured to purchase a good or service. Examples of high pressure selling include sending excessive emails to a consumer, or suggesting they will be at risk if they do not purchase a product (e.g. virus scan advertising suggesting the consumer’s computer will be in imminent danger if they do not purchase the product). Generally, sending more than two marketing emails to a consumer per week would be considered excessive, except when the consumer has explicitly requested to be contacted (e.g. signing up for a daily bulletin) or when emails are one-off occurrences (to confirm orders, delivery etc.).

2.4 Exploitation of disabled and vulnerable consumers

You must make sure your website, advertising and direct marketing do not exploit disabled or vulnerable consumers. Exploitation may include, but is not limited to, providing information that is misleading or the use of small print such that consumers may not be aware of the true terms and conditions, or nature of their purchase.

Part 3: WHAT WE WILL DO

3.1 Legal guidance

Subscribers to WebTraderUK who have problems resolving a consumer complaint may seek the guidance of the WebTraderUK Secretariat, subject to the condition that this guidance is advisory only. You must co-operate with the WebTraderUK Secretariat in seeking to solve the complaint.

3.2 Mediation service and dispute resolution

If a consumer is unable to resolve a dispute directly with you, he/she may approach the WebTraderUK Secretariat for advice and mediation. The WebTraderUK Secretariat will check to see that you have dealt with the complaint in accordance with this Code of Practice, and if appropriate, will suggest a course of action for you and the consumer to take. Failure to successfully resolve a complaint may result in your removal from the scheme. Your removal from the scheme will not prevent the consumer from going to court. If a consumer remains dissatisfied with the mediation offered, they may make an official complaint against you to the Direct Marketing Authority, which acts as the independent dispute resolution system for WebTraderUK. The consumer may make use of the arbitration service provided under the terms of the WebTraderUK Code of Practice by the Chartered Institute of Arbitrators.

The WebTraderUK mediation service is available free to all customers of WebTraderUK subscribers. The Chartered Institute of Arbitrators charges consumers a registration fee on the scale of:

Total Claimed (£) Registration Fee (inc VAT)
Less than 500 £11.75
Between 501 and 1,000 £17.62
Between 1,001 and 5,000 £35.25
Between 1,001 and 5,000 £35.25
Between 5,001 and 10,000 £58.75


The trader must pay the Institute’s administration costs, the Arbitrator’s fees and expenses, and those of any expert or legal advisor appointed by him/her. The Chartered Institute of Arbitrators has the right to change these fees without notice. See www.arbitrators.org for more information on the Chartered Institute of Arbitrators’ dispute resolution service and their current fees. We do not guarantee that the fees stated in this Code are up to date.

3.3 Monitoring

We will monitor the effectiveness of this Code through feedback, complaints, mystery shopping (which is outsourced) and other research. We will deliver an annual report to the Office of Fair Trading (OFT) concerning the compliance of the traders who subscribe to the scheme.

The Direct Marketing Association, on behalf of WebTraderUK, will administer research into the effectiveness of this Code by asking several relevant questions in their annual Consumer Perceptions Survey. The results of the survey will then be published, along with the results of mystery shopping and other research that has been conducted, and a report will provided to the Office of Fair Trading.

3.4 Enforcement

If we discover that you have not complied with this Code, we will refer your case to the Direct Marketing Authority. The Authority will investigate, and if appropriate, ask you to take action to resolve the complaint. You must agree to take this action within a specified timescale. If the breach is serious, you could be excluded from the scheme and in extreme circumstances could be ‘named and shamed’. There is an appeal procedure and we can provide details on request.

In extreme circumstances, we reserve the right to require you to cease displaying the WebTraderUK logo and to remove any information stating that you are a member of WebTraderUK whilst a case against you is investigated. You must comply with this request within one week if asked. You should still maintain your commitments to the Code as doing so will support your case.

3.5 Bankruptcy

In the event of the bankruptcy of a member company, we will not be responsible for refunding any money owed to the consumer or for providing any goods not delivered. We expect consumers to be aware of their statutory rights and the added protection given when purchasing on a credit card (see section 75 of the Consumer Credit Act 1974).

3.6 Review

We will consult regularly with advisory bodies and may change our Code at any time to reflect changing consumer concerns in the industry. The Code will be reviewed in full at least every three years.

Changes to our Code of Practice are indicated by the date at the end of this document. You will be informed of major changes and you will be given the opportunity to update your website accordingly. We will always be able to help you if you have a query about this.

Contact us:
e-mail: headoffice@WebTraderUK.org.uk
phone: Administration- 01628 637 112
fax: 01628 637 112
post: WebTraderUK, DMA House, 70, Margaret Street, London, W1W 8SS.
website: www.webtraderuk.org.uk
www.arbitrators.org www.dma.org.uk