Complaints Handling (International Best Practice) (January ... · Handling in Organisations...

January 2009

complaints handling

EFFICIENCY UNIT VISION AND MISSION

Vision statement

To be the preferred consulting partner for all government bureaux and departments and to advance the delivery of world-class public services to the people of Hong Kong.

mission statement

To provide strategic and implementable solutions to all our clients as they seek to deliver people-based government services. We do this by combining our extensive understanding of policies, our specialised knowledge and our broad contacts and linkages throughout the Government and the private sector. In doing this, we join our clients in contributing to the advancement of the community while also providing a fulfilling career for all members of our team.

This brief was researched and authored by the Research Division, Institute of Public Administration, Ireland (www.ipa.ie/research). The Research Division provides applied research services for policy makers in a wide range of public service organisations, drawing on an extensive network of contacts and experience gained over more than thirty years.

other efficiency Unit DocUments The Efficiency Unit has produced a number of guides on good practice on a wide range of areas, including outsourcing and contract management. These may be found on the Efficiency Unit website at www.eu.gov.hk.

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Complaints Handling

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Foreword

The Hong Kong Government comprises dozens of departments and tens of thousands of civil servants, enforcing hundreds of ordinances and delivering a wide range of services in accordance with countless policies and long-standing practices to a population of seven million. It is inevitable that there will be complaints. We should not be overly concerned that the public finds fault with us. We should, however, be concerned if they fault us for how we handle those complaints.

The International Organisation for Standardisation (ISO) Guidelines for Complaints Handling in Organisations addresses the following aspects of complaints handling:

Enhancing customer satisfaction Recognising and addressing the needs and expectations of complainants Providing an open, effective and easy-to-use complaints process Analysing and evaluating complaints to improve service quality Auditing the complaints handling process Reviewing the effectiveness and efficiency of the complaints handling process.

Whatever the size and nature of the department, and the profile of its customers, a complaints handling mechanism that has addressed the key points covered by the ISO will not go far wrong.

This public sector reform report highlights some of the guidelines and up-to-date best practices in complaints handling being followed around the world. The best complaints regimes combine speedy, effective action, sincerity and empathy. As Nelson Mandela once said, ‘A good head and a good heart are always a formidable combination.’

As public servants we must expect dissatisfied customers. We have choices about how the public can express that dissatisfaction. We can develop efficient and effective complaints systems that the public trust and use. Alternatively, we can wait until the public complain direct to the media, politicians or oversight agencies. As a Yugoslavian proverb puts it, ‘Complain to the one who can help you.’

One emerging trend that we should be aware of involves new media and technologies. Most dissatisfied customers do not make formal complaints. In the past they would merely inform a few friends and relatives. Today, they are just as likely to inform thousands of people through blogs, chatrooms and the like. Failure to listen and react to complaints in the future is likely to be ever more costly to our reputation.

Head, Efficiency Unit January 2009

Complaints Handling

contents 1

execUtiVe sUmmary 2

1. introDUction 6 2. access to anD confiDence in the complaints hanDling system 10 3. managing the complaints hanDling system within organisations 14

4. oVerseeing complaints hanDling – a system-wiDe perspectiVe 34

5. conclUsion 37

references 39

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Executive Summary

introDUction

A broad working definition of a complaint is ‘any expression of dissatisfaction that needs a response’(Cabinet Office, 1998). The primary focus of this report is on best international practice in complaints handling, with a particular emphasis on internal complaints handling systems within public service organisations.

A good internal complaints handling system provides benefits to the organisation: serving as a quick and efficient means of resolving difficulties that may arise; promoting good relations and communications with the public; indicating where problems and shortcomings exist in the provision of services and areas that might need improvement; and helping the organisation to avoid unfavourable publicity.

Similarly, a good complaints handling system provides benefits to the public: providing a quick, easy and cost-effective means of resolving difficulties with public bodies; obtaining redress where necessary; promoting a sense of empowerment in the individual by enabling him/her to have a role in contributing to improvements in the public service; and giving people the assurance that their complaints are being taken seriously and that they are being treated properly, fairly and impartially.

For an effective complaints handling system to operate, people need to be able to access the system and have confidence in it, good

management practices must be in place within organisations, and there must be procedures in place to enable a system-wide overview of complaints handling. Good complaints handling does not always result in the complainant being happy with the outcome, but it does ensure that the complaint is taken seriously and addressed thoroughly. Central to complaints handling is the principle of empathy with the complainant and recognition of the person’s concerns. This involves actions such as dealing with the complaint as speedily as possible, careful listening, and apologising when the organisation commits fault.

access to anD confiDence in the complaints hanDling system

A vital step in determining access to the organisation to enable complaints to be made is deciding in which ways people can lodge complaints. A variety of means are possible, including telephone, face-to-face meeting, feedback form (online and/or hard copy) and so on. However, people often do not know how to access the complaints system. More innovative organisations pro-actively encourage complaints access, through such means as information provision and distribution strategies aimed at specific target groups.

A particular fear of some people considering lodging a complaint is that they will be subject to discrimination or harassment if they proceed with their complaint. This may

Complaints Handling

EXECUTIVE SUMMARY

be a particular concern among vulnerable individuals and groups. Good practice guides indicate that, in an attempt to remove the fear of retribution, organisations should clearly inform clients that they will not be discriminated against as a result of any complaint. Another good practice is to establish internal follow-up procedures to address the risk of discrimination against clients who lodge a complaint. Such a follow-up procedure might involve contacting a sample of customers who had complained to check that the complaint had been addressed and resolved and that the customer had not encountered any difficulties or harassment as a result of lodging the complaint.

Staff may also have concerns that need to be addressed. Staff may fear being criticised for being the subject of complaints, leading to a situation where they fear complaints. To avoid this, good practice guidance suggests: creating an environment in which complaints are seen as opportunities to improve services or systems, and making sure that staff feel confident that procedures support them.

managing the complaints hanDling system within organisations

Risk assessment can be an important part of a good complaints handling system. Risk management is increasingly featured in good practice guidance. Some organisations use risk assessment tools. One risk assessment tool adopts a three-step process which firstly categorises the consequences of a complaint,

then assesses the likelihood of recurrence of the incidents or events giving rise to the complaint, and finally assigns a risk level to the complaint on the basis of the findings from the first two stages.

Particular challenges for complaints handling are present where multiple agencies are involved in delivering separate services in a single location, or in jointly delivering a single service, or where private organisations may also be involved, either alongside or as partners in the project to deliver a service. In these circumstances, it is particularly important that the respective roles and responsibilities in administering legislation, making policy, and handling complaints, are clearly spelt out and visible to the public. In the absence of clarity and visibility, members of the public can have difficulty in knowing how and where to complain. Apart from issues that cut across different sectors and organisations, making complaints by the public can also be difficult because of the sheer complexity of the public service. Simplifying this complexity for the public is a challenging but vital part of complaints handling. Some organisations and indeed sectors are now moving towards a single point of contact for complaints.

Another challenge faced by many public servants dealing with complaints is how to handle complainants who are 'difficult' in some way, either in their tone and approach, in their ability to articulate their case, or because they are making vexatious complaints with little substance. To be able to deal with such

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EXECUTIVE SUMMARY

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complaints tactfully yet forcefully requires that good procedures and standards are in place, and that staff have the skills and competencies needed to manage such difficult situations. Good practice suggests developing guidance that includes details of how to handle difficult customers, in person or on the phone, and how to deal with their letters; instructions about a cut-off point, which should be reached only after a management decision; and instructions for dealing with any further problems.

Many leading public service organisations are now providing electronic means for citizens to lodge complaints. Common initiatives are: providing an email link on web sites for citizens to electronically submit comments or complaints; providing on-line access to structured complaints forms for specific programmes; allowing citizens to complete and forward the form on-line, and having forms that can be downloaded, printed, and mailed to the organisation. Information technology is also used to enable better storage, communication and tracking of complaints.

Organisations need to periodically assess the quality of their complaints handling system. Best practice organisations tend to do this by taking and reviewing a sample of complaints and determining how well they were dealt with, the degree to which there was resolution, and the degree and quality of communication with the complainant.

A supportive culture within the organisation is vital to the success of complaints handling. In particular, to be effective, complaints systems should be supported by senior management. It is notable that in many good practice organisations the chief executive is an active proponent of complaints handling, and the complaints handling manager or unit reports directly to the chief executive and/ or the senior management team. In terms of supporting front-line staff, who most often have to deal directly with complaints, these pressures should be recognised and as much support as possible provided to enable them to do their jobs well.

oVerseeing complaints hanDling – a system-wiDe perspectiVe

Above the level of the organisation, it is important that a systemic view of complaints handling is taken. A ‘whole of government’ perspective is needed, within which the complaints handling procedures of individual organisations fit. Important aspects of this system-wide perspective are the categorisation of complaints and ensuring that lesson learning is spread system-wide.

In terms of categorising complaints, several countries and sectors encourage the use of a complaints ‘ladder’ whereby complaints are moved up the hierarchy as necessary, often using a three-tier process. The first tier is front-line staff, authorised to resolve minor complaints at first point of contact. The second tier, if the complainant is still dissatisfied, is

Complaints Handling

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EXECUTIVE SUMMARY

internal review or investigation by more senior staff or a designated complaints officer. The third tier, if complaints are not resolved internally, is to refer unresolved complaints for external review. This may be an external agency such as an Ombudsman or an alternative dispute resolution procedure.

conclUsion

Good complaints handling means:

y Being citizen focused Ensuring that people with complaints can easily access the system Dealing with people promptly and sensitively, bearing in mind their individual circumstances Being open and accountable and acting fairly and proportionately Putting things right when things have gone wrong and apologising for the mistakes made when an apology is merited.

Good complaints handling is also about seeking continuous improvement, using feedback and lessons learned to improve service design and delivery. An effective complaints system which offers a range of timely and appropriate remedies saves organisations time and money in the long run. This enhances the quality of service to its clients, has a positive effect on staff morale and improves the organisation’s relations with the citizen. It also provides useful feedback to the organisation and enables it to review procedures and systems that may be giving rise to complaints.

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1. Introduction

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Complaints handling is an important part of any organisation’s work, but one that can easily be misunderstood or under-appreciated. The challenge for most organisations is to implement a complaints handling system that effectively meets the needs of citizens and the organisation. In this regard, a number of studies examined in this report set out international good practice in complaints handling in the public service. The primary focus is on the development of internal complaints handling within organisations. In the UK an important general guiding point regarding complaints handling is stressed in the House of Commons Public Administration Select Committee (2008) report When Citizens Complain (http://www. parliament.the-stationery-office.co.uk/pa/ cm200708/cmselect/cmpubadm/409/409. pdf ), which suggests that public services need to adopt the perspective of citizens who use them: ‘They should seek to discover what complainants hope to achieve from making their views known; they should have a systematic and active strategy for monitoring and learning from complaints to inform service delivery.’

why is gooD complaints hanDling important?

In recent decades, public sector organisations in many of the most reforming countries have developed their complaints handling systems as part of quality customer service initiatives. Under the public service modernisation programme, public service organisations have been conscious of using complaints

information to further enhance and deliver quality services to the citizen. The increasing emphasis on‘personalisation’of services and responsiveness to the needs of users are important developments that also increase the need for a positive approach to be taken towards complaints.

However, it is important to remember that the state is not just a service provider, as it defines both entitlements and obligations and it also interacts with the users of its services in a variety of ways. In this context, Brewer (2007) for example warns: ‘Public sector managers and professionals need an awareness of how public reform strategies oriented exclusively towards a strengthened consumer role do risk undermining important aspects of the complaints handling and redress strategies embedded in the “rule of law” and “due process” features of citizen-oriented public administration.’ In other words, in a public service context it is not enough to simply respond speedily to an individual complainant. Attention must be given to treating all citizens fairly. This goes beyond seeing complainants as customers, to seeing them more as citizens with rights and responsibilities.

A good internal complaints handling system provides benefits to the organisation: serving as a quick and efficient means of resolving difficulties that may arise; promoting good relations and communications with the public; indicating where problems and shortcomings exist in the provision of services and areas that might need improvement; and helping

Complaints Handling

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INTRODUCTION

the organisation to avoid unfavourable publicity such as complaints lodged to the media, Ombudsman, etc. Similarly, a good complaints handling system provides benefits to the public: providing a quick, easy and cost-effective means of resolving difficulties with public bodies; obtaining redress where necessary; fostering a greater sense of inclusiveness or partnership with the public service; promoting a sense of empowerment in the individual by enabling him/her to have a role in contributing to improvements in the public service; and giving complainants the assurance that their complaints are being taken seriously and that they are being treated properly, fairly and impartially.

Having a good complaints handling system in place in an organisation can also save time and cost down the line. Many complaints in Ombudsman’s offices result from a breakdown in communications between public bodies and their clients. Studies have shown that most such complaints could and should be easily and swiftly settled at a very early stage by public bodies themselves.

John McMillan, Australian Commonwealth Ombudsman, identifies ten lessons learned from thirty years of complaints handling that summarise very well the benefits to be found in handling complaints well (see case study).

Case stUDy – ten lessons from tHirty years of Complaints HanDling

1. Complaints are a fact of lifeProblems occur in every programme and in every system, no matter how well designed or how efficient. The inevitability of problems means that it is essential to establish a system for handling complaints and for client relations, even before problems are first reported.

2. Complaints provide a window on systemic problems As often complaints are not unique and point to a recurring difficulty in an agency. If staff misunderstood a legislative or policy rule in one case, it is likely the rule was misapplied in other similar cases. The implication is that agencies should view complaints as a valuable source of intelligence on how effectively the agency is performing.

3. Complaints can stimulate organisational improvement While the prime focus in complaints handling must be to provide a remedy to a complainant, that is not the only task. A skilled complaints handling unit will examine whether a complaint has significance beyond its own facts. There is a systemic lesson to be found in most complaints.

Complaints Handling

INTRODUCTION

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4. complaints must be taken seriously by the leaders of an organisation An organisation will not be responsive to complaints unless the leadership group in the organisation sends the right message to staff. A defensive or dismissive attitude to complaints by agency leaders will soon develop into an impregnable barrier to the agency learning from its mistakes. Similarly, if a complaints unit is parked at the side of an organisation and treated as peripheral to core business, its messages will be sidelined.

5. complaints handling is suitable for all areas of business and governmentExternal oversight and complaints handling is as relevant, for example, to policing and defence, as it is to social services and taxation. Experience has illustrated that disciplined forces that have a strong internal culture can benefit a great deal by exposure to a generalist or civilian complaints agency. It is a reminder that all agencies in government are expected to be accountable, transparent and prepared to explain and defend their actions.

6. complaints handling is a specialist taskIt is easy to handle a complaint badly and cause a complainant to shift his/her focus from the topic of the complaint to the performance of the complaints agency. Complaints and investigation staff must be specially selected and properly trained, and complaints handling must be subject to constant supervision and quality assurance.

7. good complaints handling can defuse a crisis The way a complaint is handled will be as important as the outcome of any investigation. Indeed, it can almost be stated as a truth that the time taken to resolve a complaint will be inversely proportional to the chance of a satisfactory resolution.

8. complaints work transforms and improves government Government agencies are now more responsive to queries and complaints, they have service charters and internal complaints and review procedures, there are performance standards for measuring effectiveness and integrity within agencies, and there is greater transparency in decision making.

9. the price of failure is high The mistakes of an organisation are remembered for many years. All the hard work and positive achievements of an organisation can be overshadowed by one or two mistakes that gain public notoriety. Complaints cannot, of course, prevent mistakes. But they are an important part of the system for preventing or minimising damaging mistakes.

10. we can all do better There are challenges ahead and there are areas for improvement.

Source: McMillan (2007), http://www.comb.gov.au/commonwealth/publish.nsf/ AttachmentsByTitle/seminar_notes_John_McMillan/$FILE/seminar_notes_John_McMillan.pdf

Complaints Handling

http://www.comb.gov.au/commonwealth/publish.nsf/AttachmentsByTitle/seminar_notes_John_McMillan/$FILE/seminar_notes_John_McMillan.pdf

INTRODUCTION

what is a complaint?

In the UK, the Cabinet Office (1998) publication How To Deal With Complaints outlined a broad working definition of a complaint as ‘any expression of dissatisfaction that needs a response.’ When Citizens Complain (House of Commons, 2008) endorses this broad definition and recommends its use by all government organisations, however communicated; it also recommends that all such expressions of dissatisfaction be treated as complaints (p.9).

The Office of the Ombudsman in Ireland gives a broader context for this definition and suggests that the success of any complaints handling system depends on those involved in its operation being clear as to what it is intended to achieve. The Office suggests that the term complaint may cover a wide range of items, not all of which may be appropriate to the complaints handling system, e.g. matters for which there is a statutory right of appeal such as a planning appeal. In this context, a working definition used by the Office of the Ombudsman in Ireland is that a complaint exists where ‘a decision or action is taken which relates to the provision of a service or the performance of a function which, it is claimed, is not in accordance with the rules, practice or policy of the organisation or the generally accepted principles of equity and good administrative practice and which adversely affects the person concerned.’ (Office of the Ombudsman, Ireland, http:// ombudsman.gov.ie/en/Publications/ Guidelines/InternalComplaints/)

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Complaints Handling

http://ombudsman.gov.ie/en/Publications/Guidelines/InternalComplaints/

Complaints Handling

2. Access to and confidence in the complaints handling system

People need to have confidence thattheir complaint will be handled fairly andcourteously. Citizens need to know that itis easy to find out where to complain andhow to complain. They want to know thatcomplaints are not only invited but are treatedseriously, that they will be listened to withempathy, apologised to if necessary and thatactions will be taken to redress the situationas needed. A vital first step in this process isensuring access to the complaints handlingsystem for all who may wish to avail of it.

ways in which people can loDge a complaint

A vital first step in determining access to

the organisation to enable complaints to be made is deciding in which ways people can lodge complaints. The Centrelink case study from Australia shows that a variety of means of making a complaint can be used. Obtaining customer complaints may seem straightforward, but decisions need to be made as to how complaints are to be made and fed into the system to be processed.

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case stUDy – loDging a complaint with centrelink, aUstralia

Centrelink is the main delivery agency for the Australian government’s social policy agenda. In 2003–2004 Centrelink delivered services to 6.5 million people including retired people, families, sole parents, people looking for work, people with disabilities and indigenous Australians. There are six main ways a customer can make a complaint directly with Centrelink:

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By telephone, through the Customer Relations Line, and on Freecall numbers, which accepts telephone typewriter (TTY)

By telephone to a Customer Service Centre (CSC) or a Call Centre (CC)

By speaking to a Centrelink Customer Service Officer (CSO) directly at a CSC

By completing a customer comment card and lodging it either at a CSC or mail by reply paid post

By email, using a Service Feedback form that can be completed and forwarded via Centrelink’s website

By mail or facsimile

Source: Australian National Audit Office (2005), http://www.anao.gov.au/uploads/ documents/2004-05_Audit_Report_34.pdf. p.35

http://www.anao.gov.au/uploads/documents/2004-05_Audit_Report_34.pdf

ACCESS TO AND CONFIDENCE IN THE COMPLAINTS HANDLING SYSTEM

Do people know how to loDge a complaint?

Staying with the Centrelink example, the 2002 Centrelink National Customer Satisfaction Study asked those customers surveyed to identify ways in which they could make a complaint to Centrelink about its service. Some 26 per cent of customers were unable to identify at least one way in which they could make such a complaint. This figure rose to 39 per

cent for participants identified as being indigenous Australians (Australian National Audit Office, 2005).

This highlights the need for work on the part of organisations in terms of advertising their complaints system and ensuring, as far as practicable, that all clients and customers are aware that a complaints system exists and how to access it (see case study).

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case stUDy – ensUring clients know how to access the complaints system

The Treasury Board of Canada Secretariat recommends that the following questions be asked with regard to access:

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Does the organisation provide information about how to complain and to whom complaints should be made, including a contact, a phone number, and an address? How is this information disseminated?

Has the organisation published its standards of service and made them available so that people know what standards of service they may expect?

Can clients make complaints in a variety of ways – in person, in writing, by fax, and by telephone?

Does the organisation provide information about formal independent review bodies, such as relevant judicial bodies?

When necessary, has the organisation informed clients about ways that a relative or friend might help with a complaint if clients have difficulty expressing themselves?

Has the organisation designated staff to help people formulate and pursue their complaints?

Are there suitable arrangements to allow people with disabilities to complain?

Do employees know what to do when they receive a complaint?

Source: http://www.tbs-sct.gc.ca/Pubs_pol/opepubs/TB_O/11qg1-eng.asp

Complaints Handling

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A key point here is that a variety of means of letting people know that they can complain and how they can complain is needed. These may include:

Developing specific information and resources: fact-sheets, posters, translated information, kids colouring in sheets, and brochures

Regular publications: newsletters,

email alerts

Websites as a recognised source of information and useful links

User tests before distribution (e.g.

online scorecard)

Flexible distribution strategies: email, ace-to-face, mail-outs, libraries,

government and community agencies

Promotional ‘goodies’: stress balls, ridge magnets, pens, bags

Maintaining a database of key contacts.

Source: Petre (2007)

case stUDy – actiVely encoUraging complaints

One top performing acute hospital trust in the UK used all the standard methods to publicise its complaints handling system but wanted to do more to encourage people to come forward. To achieve this, they worked on an active community out-reach programme. The programme linked in with existing patient support groups, disability groups and hard-to-reach special interest groups, as well as social services. The staff worked closely with these groups by attending meetings, distributing leaflets, sharing information and talking about what they do.

The trust also established a community involvement forum. Service users and patients sit on this group and work with the trust to advise on the design of its patient information leaflets. The trust keeps this programme active by continually searching through local newspapers to learn about new groups or meetings that may also be worth targeting.

Source: Healthcare Commission (2007), http://www.healthcarecommission.org.uk/_db/_ documents/Complaints_handling_in_the_NHS.pdf, pp.17-18

Complaints Handling

http://www.healthcarecommission.org.uk/_db/_documents/Complaints_handling_in_the_NHS.pdf


Dealing with client anD staff fears anD concerns aboUt loDging a complaint

In the UK, a National Audit Office (2008) study found that only 5 per cent of people who had been dissatisfied with the services of the National Health Service made a formal complaint. Sixteen per cent made an informal complaint to which they did not expect a written response, but 79 per cent did not complain at all. Most commonly, people did not complain because they lacked confidence in the system. Thirty-two per cent who did not complain formally stated that they thought nothing would be done as a result of their complaint, while 6 per cent did not feel their complaint would be looked at with sufficient independence or fairness.

Some people considering lodging a complaint fear that they will be subject to discrimination or harassment if they proceed with their complaint. This may be a particular concern among vulnerable individuals and groups. Good practice guidelines tend to state that, in order to remove the fear of retribution, organisations should inform clients that they will not be discriminated against as a result of making a complaint. Another good practice is to establish internal follow-up procedures to address the risk of discrimination against clients who lodge a complaint. Such a follow-up procedure might involve contacting a sample of customers who had complained to check that the

complaint had been addressed and resolved and that the customer had not encountered any difficulties or harassment as a result of lodging the complaint.

Staff may also have concerns that need to be addressed. The Cabinet Office (1998) report How To Deal With Complaints suggests that ‘a “blame culture”where members of staff are criticised for being the subject of complaints only leads to a situation where staff fear complaints. They then try to brush them under the carpet, and deal with them negatively or even with hostility’. To avoid this, the guidance suggests creating an environment in which complaints are seen as opportunities to improve services or systems, and making sure that staff feel confident that procedures support them.

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3. Managing the complaints handling system within organisations

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Once a complaints handling system is in place that the public can access, it is important that the system is operated efficiently and effectively and that the needs of the complainant are addressed thoroughly, courteously and promptly. There are general principles and practices to help ensure that complaints handling is well managed in public service organisations.

iDentifying gooD practice principles in complaints hanDling

The Office of the Ombudsman, Ireland, sets out the essential principles of a good internal complaints handling system (see case study).

case stUDy – principles of a gooD internal complaints hanDling system

accessible Simple instructions about how to make a complaint should be available to the public. These should clearly identify the designated complaints handlers and explain how they will operate. The various ways in which a complaint may be made should be stated. Suitable accommodation should be provided for receiving and interviewing complainants who wish to make a complaint in person. At all times it should be emphasised that complaints are welcomed by the public body as a means of improving the quality of service provided.

simple The various stages in the complaints handling process should be kept to a minimum, with each stage in the process clearly identified. It is essential that internal disputes about the handling of the complaint do not develop. When the receipt of a complaint is being acknowledged, an outline of the various stages the complaint will go through should be sent to the complainant.

speedy Targets should be set for acknowledging receipt of complaints and the completion of their examination. Where it is not possible to meet the target for completion, interim letters, updating the complainant on progress, should be issued.

Complaints Handling

MANAGING THE COMPLAINTS HANDLING SYSTEM WITHIN ORGANISATIONS

15 fair and independent Complaints that have not been resolved by the original decision-maker should be examined objectively by persons not involved with the original decisions or actions. The examination should have regard not only to the rules governing the scheme but also to considerations of equity and good administrative practice.

confidential and impartial All complaints should be treated in confidence (except where the complainant wishes otherwise). The public should be assured that making a complaint will not adversely affect their future dealings and contacts with the body concerned. Correspondence about the complaint should be filed separately from other information held on the complainant as a client of the body.

effective The complaints system should have the authority to address all the issues giving rise to the complaint. Where the examination finds that the fault lies with the public body, the system must have the power to provide appropriate redress. A complainant who remains dissatisfied should be advised of his/her right to refer the case to the Ombudsman where appropriate.

flexible While rules are necessary to ensure consistency, too much rigidity should be avoided and there should be a degree of discretion given to those involved in the system to adjust to the changing needs and demands of complainants and to adapt to new situations.

Source: Office of the Ombudsman, Ireland, http://ombudsman.gov.ie/en/Publications/ Guidelines/InternalComplaints/

On a similar note, the Treasury Board of Canada Secretariat, in guidance on good practice in complaints handling, includes a checklist of questions to ask in order to ensure that an organisation is operating a system that is responsive to client needs

(see case study). Also, in Western Australia, five good practice principles guided the redesign of the complaints handling system in the Department of Education and Training (see case study).

Complaints Handling

http://ombudsman.gov.ie/en/Publications/Guidelines/InternalComplaints/


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case stUDy – ensUring a responsiVe complaints hanDling system

Questions to ask about responsiveness:

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Do procedures allow employees to resolve complaints on the spot if possible, and to provide immediate redress, where appropriate? If employees cannot deal with an appropriate complaint on the spot, do the procedures set out further stages, including steps for conducting a full investigation and for providing a full final reply? Are there time limits for dealing with various types of complaints, and for each step in the procedure, such as acknowledgment, interim reply, and final reply? Does the organisation monitor time limits and review them regularly? Do employees keep complainants informed of the progress of their complaint? Are staff trained to handle complaints? Are staff trained in interpersonal skills, including skills for dealing with abusive and threatening behaviour? Does the system allow employees to retrieve information about a complaintquickly?


case stUDy – improVing internal complaints hanDling in the Department of eDUcation anD training,western aUstralia

Five areas were identified where action was needed to improve complaints handling procedures:

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A centralised complaints management system to provide a rigorous, consistent approach and efficiency and effectiveness in the handling of complaints. This will facilitate transparency and clear decision-making in complaints management processes

Improved complaints assessment to determine the nature of the complaint, how it should be dealt with, who should be involved and whether investigation is needed. This will facilitate greater clarity in responding to matters relating to professional standards, grievances, employee relations and the provision of goods and services

Complaints Handling


17A risk management framework and a culture open to receiving complaints supported by: an educative and advisory role; clear guidelines with an explicit mechanism for dealing with issues according to the various degrees of seriousness and for determining the necessary and appropriate level of response; training and support at the local level; and an effective communications strategy to ensure complainants and all other stakeholders (including external agencies) are kept informed about the progress of a complaint

Coordination and collation of systemic data and clear guidelines on record keeping. This will benefit the Department by: providing information that can lead to improvements in service delivery; providing a basis for ongoing review; and enhancing the ability of the organisation to identify and respond to trends

An independent and escalated review process for investigating serious complaints, together with redress options.

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Source: Ombudsman Western Australia (2006), http://www.ombudsman.wa.gov.au/ documents/reports/DETReport.pdf

conDUcting a risk assessment of complaints

As indicated in the Department of Education and Training Western Australia case study, risk assessment can be an important part of a good complaints handling system. Risk management is increasingly featured in good practice guidance. For example, the UK Healthcare Commission recommends the use of a risk assessment tool to aid decisions on

categorising a complaint. The risk assessment tool adopts a three-step process which firstly categorises the consequences of a complaint, then assesses the likelihood of recurrence of the incidents or events giving rise to the complaint, and finally assigns a risk level to the complaint. Risk assessing a complaint can ensure that the subsequent management process and any associated investigation are proportionate to the severity of the complaint and the related risks.

Complaints Handling

http://www.ombudsman.wa.gov.au/documents/reports/DETReport.pdf


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case stUDy – DeVeloping a risk assessment tool for complaints

1. the consequence categorisation table assists in determining how tocategorise the consequences of a complaint, or the subject matter of a complaint:

category Description

serious Issues regarding serious adverse events, long-term damage, grossly substandard care, professional misconduct or death that require investigation. Serious patient safety issues. Probability of litigation high

major Significant issues of standards, quality of care, or denial of rights. Complaints with clear quality assurance or risk management implications, or issues causing lasting detriment that require investigation. Possibility of litigation

moderate Potential to impact on service provision/delivery. Legitimate consumer concern but not causing lasting detriment. Slight potential for litigation

minor Minimal impact and relative minimal risk to the provision of healthcare or the organisation. No real risk of litigation

minimum No impact or risk to provision of healthcare

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19

2. the likelihood categorisation table assists in determining the likelihood ofrecurrence of the incident or circumstances giving rise to the complaint:

likelihooD Description

frequent Recurring – found or experienced often

probable Will probably occur several times a year

occasional Happening from time to time – not constant; irregular

Uncommon Rare – unusual but may have happened before

remote Isolated or one-off – slight/vague connection to healthcare service provision

3. having assessed the consequence and likelihood categories using thetables above, the risk assessment matrix below is used to determine the level of risk assigned to the complaint:

conseqUences likelihooD of recUrrence

frequent probable occasional Uncommon remote

serious high

major

moderate meDiUm

minor

minimum low

Source: Healthcare Commission (2008a), Appendix 6.5, http://www.healthcarecommission.org.uk/_db/_documents/Complaints_Toolkit.pdf

Complaints Handling

http://www.healthcarecommission.org.uk/_db/_documents/Complaints_Toolkit.pdf


20

Dealing with cross-cUtting anD complex complaints

Particular challenges for complaints handling are present where multiple agencies are involved in delivering separate services in a single location, or in jointly delivering a single service, or where private organisations may also be involved, either alongside or as

partners in the project to deliver a service. In these circumstances, it is particularly important that the respective roles and responsibilities in administering legislation, making policy, and handling complaints, are clearly spelt out and visible to the public. In the absence of clarity and visibility, members of the public can have difficulty in knowing how and where to complain.

case stUDy – complaints hanDling in aUstralian airports

In Australia, an investigation undertaken by the Commonwealth Ombudsman examined the visibility and accessibility of complaints handling systems in airports, inter-agency collaboration in complaints handling, and how well agencies resolved systemic issues identified through complaints. A number of organisations were involved in dealing with complaints at airports: Australian Customs Service; Australian Federal Police; Australian Quarantine and Inspection Service; Department of Industry, Tourism and Resources; Department of Immigration and Citizenship; and Department of Transport and Regional Services. Overall the study found that agencies could raise greater awareness for travellers of their right to complain and how to exercise that right. The report also found that agencies could work more cooperatively in managing complaints.

Based on the findings, the Commonwealth Ombudsman Office made 14 recommendations, including that agencies should: review their complaints handling systems to ensure they comply with Australian Standard AS ISO 10002–2006; make complaints handling systems more visible to passengers; develop a joint complaints handling mechanism at major airports; improve their websites to make complaints information easier to locate and available in a range of formats so that no traveller is disadvantaged (see for example http://www.immi.gov.au/contacts/forms/services/index.htm for links from the immigration and citizenship website to the complaints section of the websites of other agencies) and review complaints handling information to ensure that it is available in the languages

Complaints Handling


21 most frequently spoken by passengers travelling to Australia. The majority of the recommendations were accepted by all the agencies, and they all recognised the importance of dealing with complaints consistently and effectively.

Source: Commonwealth Ombudsman Annual Report 2006–2007, http://www.ombudsman. gov.au/publications_information/annual_reports/ar2006-07/chapter_5/chapter_5b. html

Complaints Handling

case stUDy – complaints hanDling anD the welfare to work initiatiVe

Under a Welfare to Work initiative in Australia, a complaint could involve Centrelink for the payment matters, the Department of Employment and Workplace Relations (DEWR) for the policy, and the Department of Human Services (DHS) for the job capacity assessment component. In the case of a job seeker with a disability, the complaint may also involve the Department of Families, Community Services and Indigenous Affairs (FaCSIA). The involvement of multiple agencies can make it difficult for persons to resolve any issues of concern. They may be unclear as to which agency is best placed to address their concerns and the role of different agencies in dealing with their particular circumstances. Questions arise about which agency is responsible for poor administration relating to flawed policies and guidelines. For example, if the Ombudsman’s office forms the view that a Centrelink decision was based on flawed policy, the question arises as to which agency is responsible: DEWR as the policyholder or Centrelink as the service delivery agency, or both. This also makes it difficult to identify which agency is best placed to achieve the appropriate remedy because in some instances three or more agencies may all have some degree of shared responsibility.

The Commonwealth Ombudsman Annual Report 2006–2007 suggests that it is important that there are clear lines of responsibility and inter-agency collaboration in dealing with complaints. It is also imperative that appropriate processes to address these issues are set up at the start of the implementation of such major initiatives.

Source: Commonwealth Ombudsman, Annual Report 2006–2007, http://www.ombudsman. gov.au/publications_information/annual_reports/ar2006-07/chapter_5/chapter_5b. html

http://www.ombudsman.gov.au/publications_information/annual_reports/ar2006-07/chapter_5/chapter_5b.html

http://www.ombudsman.gov.au/publications_information/annual_reports/ar2006-07/chapter_5/chapter_5b.html


22

Apart from issues that cut across different Simplifying this complexity for the public is sectors and organisations, making complaints a challenging but vital part of complaints by the public can also be difficult because of handling (see Crerar Review and Revenue the sheer complexity of the public service. Canada case studies).

case stUDy – the crerar reView in scotlanD

The Crerar Review report considers how Scotland’s systems of regulation, audit, and inspection (referred to as ‘external scrutiny’) and complaints handling for public services could be improved. A practical example cited in the report to outline the complexity and the difficulty posed to service users wishing to make complaints was provided in evidence from the Scottish Public Service Ombudsman (SPSO) who notes that an individual wishing to make a complaint about the provision of care for her elderly mother could have been investigated through five separate complaints processes: NHS, Care Commission, the individual care home, professional bodies, or the Procurator Fiscal.

The report suggests that service users and the public would benefit from a less complex, faster and more easily accessed system. Service providers would also benefit from a simplified system and from a more consistent way of using complaints outcomes to provide assurance and drive improvement. To this end the report recommends that:

y

y

A standardised complaints handling system should be introduced for scrutiny organisations and service providers in all public services

The SPSO should oversee all public service complaints handling processes, but with the specific role of investigating front-line service failure being devolved to service providers and scrutiny bodies, to simplify the present arrangements.

The report’s proposals are intended to result in a reduction in the number of bodies dealing with complaints. The response of an action group established by the government to implement the main recommendations of the report broadly agreed with the approach outlined. The response can be accessed at http://www.scotland.gov.uk/Resource/ Doc/923/0063564.doc.

Source: Scottish Government (2007), http://openscotland.gov.uk/ Publications/2007/09/25120506/14

Complaints Handling

http://www.scotland.gov.uk/Resource/Doc/923/0063564.doc

http://openscotland.gov.uk/Publications/2007/09/25120506/14


23 case stUDy – Dealing with complexity in the reVenUe sector

Revenue Canada set up a Problem Resolution Programme to deal with high-profile problems. Problem-resolution staff in tax services offices and tax centres resolve problems that cannot be handled through regular complaints resolution channels. They locate the sources of administrative problems, solve the problems, and ensure that steps are taken to prevent their recurrence. The programme allows the department to monitor and analyse the nature and frequency of complaints, which helps the department anticipate and respond to taxpayers’ ever-changing needs and demands.


Dealing with DifficUlt complainants

Another challenge faced by many public servants dealing with complaints is how to handle complainants who are ‘difficult’ in some way, e.g. in their tone and approach, in their ability to articulate their case, or because they are making vexatious complaints with little substance. To be able to deal with such complaints tactfully yet forcefully requires that good procedures and standards are in place, and that staff have the skills and competencies needed to manage such difficult situations.

Complaints Handling


24

case stUDy – Dealing with a DifficUlt complainant in the Uk national health serVice

A complainant had presented a very detailed complaint to a health care trust regarding the care he received from the ear, nose and throat and cardiology departments at a major hospital in London. His complaint concerned the trust’s procedures; delays in appointments; being removed from the trust’s premises under the management of violent incidents policy; and the length of time that he had waited for a hearing aid. The complainant’s letters were often difficult to follow, but the trust worked extremely hard to address all of his concerns. There was good evidence that the departments at the trust worked together effectively to produce a coordinated response. Statements were taken from the appropriate staff and incorporated into the response. The trust’s investigation letter was very clear, with all medical terms explained in lay language.

The complainant was unhappy with the trust’s first response letter, but the trust did not immediately refer him to the Healthcare Commission (the independent regulator for healthcare in England). Instead they drafted a very detailed second letter to address his outstanding concerns. The trust showed great patience and empathy in dealing with a sometimes difficult complainant. It provided clear explanations of the complainant’s treatment and was prepared to provide detailed accounts of his care and treatment over a long period of time. The complainant approached the Healthcare Commission about his complaint. Having taken clinical advice, the Healthcare Commission decided that no further action was necessary.

Source: Healthcare Commission (2007), http://www.healthcarecommission.org.uk/_db/_ documents/HC_Complaints_Handling_tagged.pdf

Complaints Handling

http://www.healthcarecommission.org.uk/_db/_documents/HC_Complaints_Handling_tagged.pdf


25 case stUDy – poor practice in Dealing with a DifficUlt complainant

A London general practitioner practice removed Mr O from its patient list, having referred him to the local trust’s violent patient scheme. The reason given by the practice was that Mr O had been abusive to a member of staff when he was told that he would have to re-book an appointment after arriving late; this was apparently the third time that this had happened. Mr O complained to the practice and the trust about his removal from the list and the referral to the violent patient scheme. He felt that he had been discriminated against on the grounds of his race. Dissatisfied with the response to his complaint, Mr O requested an independent review from the Healthcare Commission.

When the Commission’s case manager reviewed the case, she could find no evidence of an investigation into these events or a record of the two previous incidents referred to. The only reference to the incident was a brief note in Mr O’s medical records saying that he had been 10 minutes late for his appointment and was abusive when asked to make another appointment. Although the British Medical Association, the Royal College of General Practitioners and General Medical Services contract (2004) all have guidelines for removing patients, there was nothing to indicate that the practice had used any of these. The Commission’s decision was to recommend that the primary care trust appoint an independent expert to investigate the circumstances of Mr O’s removal. This investigation found that there was no evidence to support the GP practice’s decisions, and that Mr O’s removal and referral to the violent patient scheme was unjustified.

Source: Healthcare Commission (2008a), http://www.healthcarecommission.org.uk/_db/_ documents/Complaints_Toolkit.pdf

With regard to people who are habitual complainants, the Cabinet Office (1998) report How To Deal With Complaints recommends that 'your complaints procedure should set out guidance on handling people who complain continually. This guidance should include: details of how to handle difficult customers, in person or on the phone, and how to deal with their letters; instructions about a cut-off point, which should be

reached only after a management decision; and instructions for dealing with any further problems: further letters from the customer should be checked to make sure that they do not contain new issues that need a reply’.

The New South Wales Ombudsman’s Office is coordinating a cross-agency project to develop and trial management strategies for complainants who behave unreasonably. ‘The

Complaints Handling



26

project recognises categories of unreasonable conduct that place an inequitable burden on the organisation’s resources and often cause distress for staff.’The New South Wales Ombudsman’s Office is ‘now trialling various management strategies for responding to unreasonable conduct. Staff attended one-day training sessions and were given material outlining a range of recommended responses to difficult behaviour. Staff have been asked to test these strategies when a complainant exhibits particular behaviour. The data from this trial will inform the project’s conclusions and final paper.’ (Source: Commonwealth Ombudsman Annual Report 2006–2007)

Using information anD commUnications technology

The extent to which information and communications technologies (ICTs) can be underused is illustrated by a UK National Audit Office (2005) report Citizen Redress, which found that most departments excluded complaints received by email or telephone. The House of Commons Public Administration Select Committee (2008) notes that in terms of accessibility of citizens to a complaints system, ‘insisting on complaints in writing can potentially defer valid complaints and prevent problems being identified. People should not be disadvantaged if they have difficulty in making a formal written complaint’ (p.9).

case stUDy – Using websites to complain

A study of the websites of fifty public and private organisations in Australia examined the visibility of complaints procedures on the websites of the organisations amongst other things. Visibility was measured by reference to four questions:

y y y y

Is the complaints process noted on the home page? Is there a ‘contact us’ button on the home page? Is there a dedicated complaints button or section at the ‘contact us’ page? How many clicks does it take to reach a page that publishes information on how to complain?

Only one company mentioned its complaints process on the home page. Forty-one sites had a ‘contact us’ button or equivalent on the home page. Only seven of these organisations dedicated a page to, or form for, complaints-capture at the ‘contact us’ page. Most of the others offered a hyperlink to an email form. Good website design favours a minimum number of clicks to navigate anywhere. The number of clicks it took to get to a page where feedback to the organisation was possible varied from one to four. On twenty-seven sites it took just a single click to get to the feedback page; fourteen sites required two clicks; two sites required three clicks and one site required four clicks.

Source: Buttle and Thomas (2003), http://smib.vuw.ac.nz:8081/WWW/ANZMAC2003/ papers/MO15_buttlef.pdf

Complaints Handling

http://smib.vuw.ac.nz:8081/WWW/ANZMAC2003/papers/MO15_buttlef.pdf


27 case stUDy – poor Use of website for complaints hanDling

The Australian National Audit Office (ANAO) (2005) reviewed the Centrelink website, and found that it was difficult for customers and business and community stakeholders to locate information on Centrelink’s complaints handling system from its website. The ANAO found that a search for the term ‘complaints’ on the Centrelink website did not provide customers or stakeholders with information as to all the avenues available to lodge a complaint (such as directly with a Centrelink staff member). The website did not contain information on the way in which Centrelink addresses the complaints that it receives. The ANAO recommended that Centrelink redesign its Internet website to:

y

y

y

y

Ensure that a search on the term ‘complaint’ provides pertinent information to customers and stakeholders on its complaints handling system Provide customers and stakeholders with more explicit information as to the various avenues by which to lodge a complaint Ensure that information on Centrelink’s complaints handling system is easily identifiable by customers and stakeholders Ensure that customers and stakeholders can lodge a complaint without being required to navigate through numerous web pages.

Centrelink acted on these recommendations, http://www.centrelink.gov.au/internet/ internet.nsf/about_us/complaints.htm

While it is useful to acknowledge the advantages of ICT in terms of easily accessible, convenient complaints handling systems for complainants and a means of developing a good complaints tracking and management system for organisations (see US postal service case study), it is also worth noting the important point that Brewer (2007) makes in terms of over-reliance on information technology and the impact on those who are

not computer literate: ‘A complaints handling system must be conspicuous, easily accessible and simple to operate. It should take account of the needs of different social groups and, even in an era of rapidly increasing computer literacy, recognise that there are many people without access to the Internet and/or the skills required to use it. An over-reliance on information technology can be a powerful form of indirect discrimination (p.552).’

Complaints Handling

http://www.centrelink.gov.au/internet/internet.nsf/about_us/complaints.htm


28

case stUDy – Us postal serVice tracking systems

The US Postal Service has established a Consumer Affairs Tracking System that records and reports every customer contact. It uses state-of-the-art imaging and database management technology coupled with highly sophisticated correspondence generation software. This system is comparable to best-in-business models. The US Postal Service also established a Call Management Initiative to create a single 1-800 number available 24 hours a day. It provides a centrally-managed consistent interface to all customers seeking information or problem resolution.

Source: http://govinfo.library.unt.edu/npr/library/papers/benchmrk/bstprac.html

In looking towards future developments, we are likely to see the use of blogs and Web 2.0 applications as an additional means of encouraging and monitoring complaints about public service organisations. As Wyld (2007) notes: ‘We will also see research on how blogs and other Web 2.0 tools are being increasingly integrated into organisational homepages, as the line between what is a blog and what is a homepage quickly begins to blur. As the penetration of text, audio and video blogging elements increases, we may well see the distinction between blog and homepage disappear, resulting in one site.’

qUality assUring complaints hanDling systems

There is a need for organisations to periodically assess the quality of their complaints handling systems. A Performance Audit of Customer Complaint Management, undertaken by Centrelink internal audit in October 2003, highlighted the need to include quality control measures in the handling of complaints. The audit showed that Centrelink’s procedures for the handling of complaints did not ensure that timely and satisfactory resolution (from the perspective of the customer) was achieved – see case study.

Complaints Handling


29 case stUDy – qUality assUring centrelink’s complaints hanDling

In Australia, a Centrelink internal audit took a random sample of 53 records from the 2,763 complaints recorded as having been received in April 2003, finding that: in six cases, the Customer Relations Unit (CRU) had referred the complaint to a Customer Service Centre or Call Centre, but there was no evidence of further action to resolve the complaint (nor any evidence of further contact with the customer about the complaint); in three other cases, the action taken was not sufficient to consider the complaint to have been resolved. In two of these cases, there was no evidence that the customer had been advised of the ‘outcome’ of the complaint; in two other cases, adequate action to contact the customer about the resolution of the complaint had not been taken; and in two other cases, action to resolve the complaint was not taken in a timely manner and there was no evidence of contact with the customer to advise of progress of the complaint.

An Australian National Audit Office (ANAO) report (2005) reviewing the internal audit findings recognised that the Centrelink internal audit only examined a small sample, but pointed out that the data show that approximately 25 per cent of the complaints examined that were recorded as resolved in reality were not resolved; were inadequately resolved; or there was insufficient information to establish that adequate resolution had occurred and/or the customer was contacted regarding the outcome of his/her complaint. The Centrelink internal audit also found that the records examined reflected a lack of clarity as to what constitutes ‘resolution’ (particularly from the perspective of the customer), a lack of focus on ensuring the achievement of resolution, and significant non-compliance with prescribed procedures.

The ANAO report pointed out that the lack of an effective quality assurance mechanism meant that Centrelink was unable to ensure that all customers who lodge a complaint were contacted regarding the outcome, or any intended action. Furthermore, the report stated that Centrelink had no procedure in place to contact a sample of customers, who lodge a complaint, to determine whether they had a positive experience with the delivery of service by a CRU. Centrelink informed the ANAO that complaints were only recorded as resolved when Centrelink had contacted the customer to explain the outcome of the complaint. However, the samples of finalised complaints examined during the Centrelink internal audit indicate that this is not always the case. It was noted by the ANAO that failure to contact all customers regarding the outcome of their complaint may result in

Complaints Handling


30

further complaints and affects Centrelink’s capacity to ensure that it has adequately addressed all the complaint issues appropriately.

The ANAO was informed by Centrelink in 2004 that revised national protocols now contain a definition of the term ‘resolution’ that applies to all tiers of the complaints handling system. They also now periodically check a sample of complaints.

Source: Australian National Audit Office (2005), http://www.anao.gov.au/uploads/ documents/2004-05_Audit_Report_34.pdf

case stUDy – monitoring cUstomer feeDback to enhance a qUality response

The best-in-business design their complaints process with input from both customers and employees. A review of best practice in complaints handling in selected American public service organisations found that in one of the organisations reviewed the customer relations personnel monitor customer feedback. They select as target issues a small number of items the customers complained about most often. Once these issues are identified, individual customer satisfaction committees are formed that link those issues with mission objectives. The complaints process is monitored to correct root causes of dissatisfaction and the results for these target customer satisfaction issues are reported to the Executive Committee.

Source: http://govinfo.library.unt.edu/npr/library/papers/benchmrk/bstprac.html

creating a sUpportiVe cUltUre for managing complaints

In the UK, the Cabinet Office (1998) report How To Deal With Complaints suggests that, to be effective, complaints systems should be supported by senior management. The report notes that ‘management should regularly review complaints information; and make

sure that complaints handling is built into the organisation’s corporate and strategic plans, and covered in annual reports.’ The report also suggests that ‘management can start to demonstrate their support for good complaints handling by sending a notice to all members of staff stressing the importance of complaints and the benefits of handling them well.’ The report recommends that ‘Chief Executives or equivalents in all public

Complaints Handling


y

y

y

y

y

y

y

y

y

y


services should be held personally responsible for effective complaints handling. And this should be reflected in job descriptions and performance appraisals, including decisions on performance-related pay.’ The report notes that in terms of supporting front-line staff, who most often have to deal with complaints, these pressures should be recognised and as much support as possible provided to enable them to do their jobs well. The report recommends that management should:

Make sure that complaints are seen as part of overall customer care

Create a team spirit so that individuals do not feel isolated and members of the team can support one another

Recognise complaints handling as an important part of everyone’s job

31

Involve staff in developing complaints procedures

Give staff the power to deal with complaints, so that they feel they ‘own’ them

Provide suitable resources (including training) so that staff can handle complaints properly

Make sure that complaints handling has status within the organisation and is considered a career opportunity

Recognise and reward staff who handle complaints well

Allow staff who handle complaints regular breaks to do other work

Display thank-you letters and action taken to improve services as a result of complaints.

case stUDy – integrating complaints hanDling with hUman resoUrce management practices

To develop customer relations, Swale Borough Council (UK) has made customer care, including handling complaints, part of performance appraisal for all staff.

Source: Cabinet Office (1998), http://archive.cabinetoffice.gov.uk/servicefirst/1998/ complaint/index.htm

Complaints Handling

http://archive.cabinetoffice.gov.uk/servicefirst/1998/complaint/index.htm


32

Case stUDy – Using training to DeVelop Complaints HanDling skills

In the UK, HM Customs and Excise included a self-assessment exercise at the end of their Handling Complaints training booklet. The introduction to the exercise explains: ‘The questions are designed to focus your attention on to some of the critical elements within the system and, at the same time, to test your understanding of the departmental complaints handling system as a whole. Try to answer them as quickly and honestly as you can (this way, you will see, at a glance, which – if any – aspects of the system you are less up to speed with). On the page following the self-assessment exercise, each question is cross-referred to the relevant section of the main text containing the answer’. This allows readers to assess their learning quickly by comparing their replies with what it says in the booklet.

Source: Cabinet Office (1998), http://archive.cabinetoffice.gov.uk/servicefirst/1998/ complaint/index.htm

The UK National Audit Office (NAO) (2008) stresses the importance of the example of top management in a review of complaints handling in health care trusts. They found that ‘the culture in terms of complaints handling is dependent on the leadership provided by the chief executive, who sets the tone within the trust. The relationship between the chief executive and the complaints manager and the level of interest the chief executive takes in complaints adds to the clout a complaints manager has when dealing with trust staff. Chief executives also demonstrated their commitment to complaints by locating their complaints manager close to their own office.’ The NAO report found that ‘two thirds of complaints managers report

directly to senior management, with three quarters providing them with complaints information on a quarterly, or more frequent, basis. Seventy-one per cent of adult social service departments had complaints on the agenda of senior management team meetings at least quarterly, though in 8 per cent of authorities complaints were only on the agenda annually. (Source: National Audit Office (2008), http://www.nao.org.uk/ publications/0708/learning_from_complaints. aspx)

Training and development supports can also play a significant role in helping create a culture that encourages the acceptance of complaints handling in organisations.

Complaints Handling

http://www.nao.org.uk/publications/0708/learning_from_complaints.aspx



33 case stUDy – DeVeloping a complaints toolkit for staff

The UK Healthcare Commission published a toolkit to inform and improve complaints handling in the National Health Service. The toolkit is intended ‘as a helpful guide to NHS bodies and primary care providers on how to handle complaints in an efficient and effective manner. The toolkit further aims to foster a culture of learning from complaints within the NHS in order to drive service improvement.’

Source: Healthcare Commission (2008), http://www.healthcarecommission.org.uk/_db/_ documents/Complaints_Toolkit.pdf

Complaints Handling


4. Overseeing complaints handling – a system-wide

perspective

34

Above the level of the organisation, it is important that a systemic view of complaints handling is taken. A ‘whole of government’ perspective is needed, within which the complaints handling procedures of individual organisations fit. Important aspects of this system-wide perspective are the categorisation of complaints and ensuring that lesson learning is spread system-wide.

categorising complaints – the complaints ‘laDDer’

In terms of categorising complaints, several countries and sectors encourage the use of a complaints ‘ladder’ whereby complaints are moved up the hierarchy as necessary, often using a three-tier process. Best practice complaints management is illustrated by a three-stage process.

case stUDy – a three-tier complaints hanDling process recommenDeD by the treasUry boarD of canaDa secretariat

While there should be as few stages as possible, a good system provides at least three levels of review:

First stage: The intake officer screens the complaint and registers it if it is appropriate. Then front-line staff attempt to resolve it.

Second stage: When clients are still dissatisfied, a more senior official or a complaints officer investigates their complaints and reports the results to them.

Third stage: When the organisation cannot resolve the complaint internally, you should consider using mutually acceptable, alternative dispute resolution mechanisms. These include mediation, which helps the parties move toward a mutually agreeable solution while remaining in control of the process. If this is not possible, a third party could mediate or arbitrate the matter.


Complaints Handling

OVERSEEING COMPLAINTS HANDLING – A SYSTEM-WIDE PERSPECTIVE

ensUring lesson learning

External agencies can have an important support role to play in developing system-wide good practice, based on evidence from their position overseeing complaints handling practice (see case study on guiding departments in strengthening their complaints management processes). This is an example of promoting system-wide lesson learning in good practice in complaints handling. Such reports aim to disseminate good practice and promote more effective complaints handling within and across public service organisations.

There is a variety of players and avenues that can be used to promote lesson learning. For example, in the UK, the House of Commons Public Administration Select Committee (2008) suggests that while individual organisations need to take responsibility for the complaints services they provide, ‘we identify a need for a centrally co-ordinated official effort to champion good practice in complaints handling and to monitor how organisations across government handle and learn from complaints in practice. The Cabinet Office is best placed to take on this role.’ The Public Administration Select Committee emphasises that it is important to put things right for the citizen but the dominant culture across the public service must invite and value complaints. Ombudsman offices and audit offices also have a role to play in spreading good practice lessons across the system.

35

Complaints Handling

OVERSEEING COMPLAINTS HANDLING – A SYSTEM-WIDE PERSPECTIVE

36

case stUDy – a gooD practice example to gUiDe Departments in strengthening their complaints management processes

In guidance it issued to all departments, the New South Wales Ombudsman Office promoted the Department of Education and Training (DEET) as an example of best practice complaints handling system. In 2001 DEET rationalised and brought together in a single document the procedures for managing different types of complaints and grievances: Responding to Suggestions, Complaints and Allegations. There are three possible procedures, with performance standards including time frames for response and quality of response:

Remedy and systems improvement procedure is used for a suggestion or complaint that is about policies and procedures, or a departmental policy position.

Negotiation procedure is used for a complaint about a person, i.e. not about an alleged serious breach of legislation, policy, procedure or contract.

Investigation procedure is used for a complaint or allegation about a serious breach of legislation, policy, procedure or contract.

This framework enables staff to assess suggestions, complaints and allegations to determine which procedure applies and who the delegate is that can initiate the procedure.

The framework includes information on: advice about anonymous suggestions, complaints and allegations; confidentiality and privacy – rights and obligations; procedural fairness; protection against victimisation; false and malicious complaints and allegations; appeal processes; disciplinary action; possible outcomes for each procedure; record keeping; statistics; and external reporting.

Source: Ombudsman Western Australia (2006), http://www.ombudsman.wa.gov.au/ documents/reports/DETReport.pdf

Complaints Handling


y

y

y

y

y

y

5. Conclusion

Good complaints handling means:

Being citizen focused

Ensuring that people with complaints can easily access the system

Dealing with people promptly and sensitively, bearing in mind their individual circumstances

Being open and accountable and acting fairly and proportionately

Putting things right when things have gone wrong

Apologising for the mistakes made when an apology is merited.

Good complaints handling is also about seeking continuous improvement, using feedback and lessons learned to improve service design and delivery. An effective complaints system that offers a range of timely and appropriate remedies saves organisations time and money in the long run. It enhances the quality of service to its clients, has a positive effect on staff morale and improves the organisation’s relations with the citizen. It also provides useful feedback to the organisation and enables it to review procedures and systems that may be giving rise to complaints.

To the greatest possible extent, complaints should be handled at a local level, with a focus on communication between the organisation and complainant at this initial stage. Greater communication, training of staff in complaints handling and accessible and informative complaints handling systems and procedures need to be in place for effective and efficient

improvements in service. The use of advances in information and communication technology (ICT) systems can also provide benefits in terms of communicating to customers more effectively the complaints procedures, providing information on the complaints process and providing the organisation with an efficient tracking mechanism of how the complaints are being handled. Studies show that an effective complaints handling system provides ‘free’ market research and this should be welcomed, rather than viewing complaints as a negative element where staff who are complained against are blamed.

The most efficient complaints handling systems provide transparent, accessible information on the processes or systems involved in complaints handling in order to enable ease of access for citizens when they are unhappy or have not received satisfactory service or treatment. Effective complaints handling systems not only outline the organisation’s internal complaints handling systems but also provide information on external bodies who can deal with the issue if redress has not been achieved satisfactorily for the complainant at a local level.

Some organisations are now using risk assessment tools to aid decisions on categorising a complaint. Furthermore, a number of studies examined in this report recommend that a central point of co-ordination and contact needs to be in place for complaints handling involving a number of agencies.

37

Complaints Handling

CONCLUSION

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‘But handling complaints effectively is not just about value for money. Crucially, it is about establishing a responsive relationship between the apparatus of the state and the people who use this apparatus’ (House of Commons Public Administration Select Committee, 2008, p.7). The structure of any complaints handling system must incorporate the needs of the citizen as paramount and integral to the effective administration and delivery of complaints handling systems to ensure that treatment is fair and equitable to all complainants in a transparent and easily accessible system. For the organisation, the structure of any complaints handling system must avoid the blame game. Instead it should provide a supportive environment in which staff can learn from mistakes, improve service or treatment, and realise the learning potential of complaints to deliver quality, citizen-centred public services.

Complaints Handling

References

Australian National Audit Office (2005), The Auditor General Audit Report No.34, 2004–2005 Performance Audit, Centrelink’s Complaints Handling System, Commonwealth of Australia, http://www.anao.gov.au/uploads/documents/2004-05_Audit_Report_34.pdf

Brewer, B. (2007), ‘Citizen or customer? Complaints handling in the public sector’, International Review of Administrative Sciences, An international Journal of Comparative Public Administration, Vol.73, No. 4, pp.549-556, Belgium: International Institute of Administrative Sciences (IIAS)

Buttle, F. and Thomas, L. (2003), Complaints handling in Australia: evidence from organisational websites, http://smib.vuw.ac.nz:8081/WWW/ANZMAC2003/papers/MO15_buttlef.pdf

British and Irish Ombudsman Association (2007) Guide to principles of good complaint handling, http://www.bioa.org.uk/docs/BIOAGoodComplaintHandling.pdf

Cabinet Office (1998), Service First, How to deal with complaints, http://archive.cabinetoffice.gov.uk/servicefirst/1998/complaint/index.htm

Commission for Local Administration in England (2007), Special Report: Local partnership and citizen redress, Advice and Guidance from the Local Government Ombudsman, http://www.lgo.org.uk/pdf/partnerships-sr.pdf

Commonwealth Ombudsman Annual Report (2006-2007) Chapter 5, Challenges in complaint handling, http://www.ombudsman.gov.au/publications_information/annual_reports/ar2006-07/ chapter_5/chapter_5c.html

Healthcare Commission (2008a), Complaints Toolkit, Handling complaints within the NHS, http://www.healthcarecommission.org.uk/_db/_documents/Complaints_Toolkit.pdf

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Complaints Handling

http://www.ombudsman.gov.au/publications_information/annual_reports/ar2006-07/chapter_5/chapter_5c.html


http://www.lgo.org.uk/pdf/partnerships-sr.pdf


http://www.bioa.org.uk/docs/BIOAGoodComplaintHandling.pdf

http://smib.vuw.ac.nz:8081/WWW/ANZMAC2003/papers/MO15_buttlef.pdf


REFERENCES

40

Healthcare Commission (2008b), Spotlight on complaints: a report on second stage complaints about the NHS in England, http://www.healthcarecommission.org.uk/_db/_documents/Spotlight_on_ Complaints_08.pdf

Healthcare Commission (2007), Is anyone listening? A report on complaints handling in the NHS, http://www.healthcarecommission.org.uk/_db/_documents/Complaints_handling_in_ the_NHS.pdf

House of Commons Public Administration Select Committee (2008), When Citizens Complain, http://www.parliament.the-stationery-office.co.uk/pa/cm200708/cmselect/ cmpubadm/409/409.pdf

House of Commons Public Administration Select Committee Fourth Report of Session 2004-2005, Choice, Voice and Public Services HC 49-1, http://www.publications.parliament.uk/pa/cm200405/cmselect/cmpubadm/49/49i.pdf

McMillan, J. (2007), Thirty Years of Complaint Handling – What have we learnt?, Commonwealth Ombudsman 30th Anniversary Seminar 9 August, http://www.comb.gov.au/commonwealth/publish.nsf/AttachmentsByTitle/seminar_ notes_John_McMillan/$FILE/seminar_notes_John_McMillan.pdf

National Audit Office (NAO) (2005), Citizen Redress: What citizens can do if things go wrong with public services, London: The Stationery Office, http://www.nao.org.uk/publications/0405/citizen_redress.aspx

National Audit Office (NAO) (2008), Feeding back? Learning from complaints handling in health and social care, http://www.nao.org.uk/publications/0708/learning_from_complaints.aspx

Office of the Ombudsman, Ireland, The Ombudsman’s Guide to Internal Complaints Systems, http://ombudsman.gov.ie/en/Publications/Guidelines/InternalComplaints/

Complaints Handling

http://www.healthcarecommission.org.uk/_db/_documents/Spotlight_on_Complaints_08.pdf

http://www.healthcarecommission.org.uk/_db/_documents/Complaints_handling_in_the_NHS.pdf

http://www.parliament.the-stationery-office.co.uk/pa/cm200708/cmselect/cmpubadm/409/409.pdf

http://www.comb.gov.au/commonwealth/publish.nsf/AttachmentsByTitle/seminar_notes_John_McMillan/$FILE/seminar_notes_John_McMillan.pdf

http://ombudsman.gov.ie/en/Publications/Guidelines/InternalComplaints

http://www.nao.org.uk/publications/0708/learning_from_complaints.aspx

http://www.nao.org.uk/publications/0405/citizen_redress.aspx

http://www.publications.parliament.uk/pa/cm200405/cmselect/cmpubadm/49/49i.pdf

REFERENCES

Ombudsman Western Australia (2006), Report by the Ombudsman on complaints management processes in the Department of Education and Training, http://www.ombudsman.wa.gov.au/documents/reports/DETReport.pdf

Petre, C. (2007), Reaching our target audience: making the ombudsman more accessible, Commonwealth Ombudsman 30th Anniversary Seminar 9 August, http://www.comb.gov.au/commonwealth/publish.nsf/AttachmentsByTitle/seminar_ notes_Clare_Petre/$FILE/seminar_notes_Clare_Petre.pdf

Queensland Ombudsman (2006), Guide to developing effective complaints management policies and procedures, http://www.ombudsman.qld.gov.au/Portals/0/docs/Publications/CM_Resources/ Developing%20effective%20complaints%20management%20policy%20and%20 procedures%202006.pdf

Scottish Government (2007), The Crerar Review: The Report of the Independent Review of Regulation, Audit, Inspection and Complaints Handling of Public Services in Scotland, http://www.scotland.gov.uk/Publications/2007/09/25120506/0

US Department of Labor Occupational Safety & Health Administration, Federal OSHA Complaint Handling Process, http://www.osha.gov/as/opa/worker/handling.html

US General Accounting Office (GAO) (2000), Letter from Linda D. Koontz, Associate Director, Governmentwide and Defense Information Systems to The Honourable Ernest Hollings, Committee on Commerce, Science and Transportation in relation to the subject of Internet: Federal Web-based Complaint Handling, July 7 2000, http://www.gao.gov/archive/2000/ai00238r.pdf

Wyld, D.C. (2007), The Blogging Revolution: Government in the Age of Web 2.0, Washington DC: IBM Center for the Business of Government, http://www.businessofgovernment.org/pdfs/WyldReportBlog.pdf

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Complaints Handling

http://www.comb.gov.au/commonwealth/publish.nsf/AttachmentsByTitle/seminar_notes_Clare_Petre/$FILE/seminar_notes_Clare_Petre.pdf

http://www.ombudsman.qld.gov.au/Portals/0/docs/Publications/CM_Resources/Developing%20effective%20complaints%20management%20policy%20and%20procedures%202006.pdf

http://www.businessofgovernment.org/pdfs/WyldReportBlog.pdf

http://www.gao.gov/archive/2000/ai00238r.pdf

http://www.osha.gov/as/opa/worker/handling.html

http://www.scotland.gov.uk/Publications/2007/09/25120506/0


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