Our Ref: 12/270263 City of Charles Sturt 72 Woodville Road, Woodville, South Australia 5011 T 08 8408 1111 F 08 8408 1122 www.charlessturt.sa.gov.au

Customer Experience Policy

Reference Number: 4.37

Type: Council Policy

Category: Customer Service

Relevant Community Plan Outcome: • Be bold and innovative in our practices, leadership and decision making.

Responsible Officer(s): Manager Public Health & Safety

First Issued/Approved: February 1998

Minutes Reference: CoS 2/09/2019, Item 3.39

Last Reviewed: September 2019

Next Review Due: September 2021

Applicable Legislation: Local Government Act 1999 Public Interest Disclosure Act 2018

Related Policies: Staff Code of Conduct Policy Training and Development Policy Public Consultation Policy Electronic Communications Policy Internal Review of Council Decision Policy Council Members Code of Conduct Policy Unreasonable Requests for Service, Information and Complaints Policy DAP Complaint Handling Policy

Related Procedures: Customer Experience Procedure (includes Complaints Handling and Request for new or increased service procedure) Public Interest Disclosure Procedure

1. Purpose The City of Charles Sturt is committed to delivering the highest level of service to its customers and ensuring

that the way in which Council delivers its customer experience has a positive influence on the community’s perception of the effectiveness and value of Council. The customer experience includes not only face to face or over the phone transactions, but also those conducted via the web, social media and other forms of communication.

Section 270 of the Local Government Act 1999 requires Council to establish policies and procedures to

respond to reasonable requests for the provision of a service by the Council or for the improvement of a service provided by the Council and to deal with complaints about the actions of the Council, employees and/or other persons acting on behalf of the Council:

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The purpose of this policy is to: • Provide a customer experience across all aspects of Council business that is consistent, professional

and treats every customer with respect, courtesy, fairness and responsiveness; • Provide guidance on what may constitute a reasonable request for a service or an improvement to a

service; • Distinguish between requests, complaints and feedback to Council and give direction on management

of requests and complaints; and • Establish a standardised process for assessing and processing requests and complaints.

2. Scope This policy applies to all Council staff and volunteers who have contact with the public and is applicable to: • All aspects of customer interactions • All requests for service and complaints made to the City of Charles Sturt, from individuals and

organisations that utilise the services provided by Council.

Requests for review of Council decisions should be referred to the mechanisms identified in the following policy: • Internal Review of Council Decisions Policy

3. Policy Statement Council is committed to the provision of a quality experience to customers and aims to provide services fairly

and efficiently. It also assesses reasonable requests for the provision of new or increased services and monitors requests to identify ways in which it can proactively improve its services.

Council also recognises the importance of complaints to the organisation and regards them as opportunities

to improve its services by resolving complaints in a prompt, impartial and just manner. Complaints provide the organisation with an opportunity to gather information on a variety of services and service delivery methods and to identify customer needs and expectations. This information helps Council work towards improving customer experience.

4. Guiding Principles

• Courtesy - Council will provide a customer experience which is based on quality and pride in the services delivered to the community by using common sense, compassion and courtesy.

• Responsiveness – Council will be responsive to the needs of the community. • Fairness – Council will be open, honest and will follow through with our commitment. • Respect – Council will treat all customers respectfully and in an equitable manner.

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5. How to Make a Reasonable Request for Service In processing requests for service, emphasis will be placed on: • Public safety and emergencies; • Fulfilling Council’s strategic and business plans; and • Using Council resources efficiently and effectively. The operations of Council are based on a range of planned actions, many of which have been the subject of community consultation processes. The annual budget is set, and the rates determined, to fund a specific range of activities, which includes responding to reasonable requests as well as the completion of business plans and public works. Requests for service are considered in this context. A person can make an application for a service either verbally or in writing. In determining how to respond to a request for service, Council will consider the community need in light of: • An assessment of risk; • Statutory responsibilities; • The content of Council’s strategic management plans, annual business plans, annual works program

and the Annual Budget; • Relevant Council policies and codes; and • Established service standards and response times for regular Council activities.

In Council’s experience, most requests for existing Council services fit within well established guidelines which will be explained to the customer/applicant at the outset. Where further evaluation is necessary before committing Council to undertake the work, the applicant will be informed accordingly.

Other requests may be best suited to scheduling to coincide with work in a particular suburb or season. Reasonable requests for additional major works or new services will be referred to Council for consideration as part of the next annual budget cycle review and public consultation. If a request cannot be fulfilled in a reasonable timeframe or is a service that is not the responsibility of the Council to deliver, the applicant will be advised, including an explanation of why this decision was taken.

5.1 Timeframes for Response

The initial response to requests will be processed within 3 business days. Where requests are unable to be responded to within 5 business days, the applicant will be advised of the process and the anticipated timeframe for a detailed response. The circumstances of individual requests for service will vary greatly. Routine requests are often subject to established service response standards. Requests for additional major works or new services will need to be referred to Council for consideration as part of the next annual budget cycle of review and public consultation.

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6. Complaint Process

A complaint is an expression of dissatisfaction with a product or service delivered by the organisation or its representatives that have failed to reach the standard stated, implied or expected. This includes complaints about a service that has been, or should have been delivered. Complaints can originate from members of the public, elected members, contractors or staff. A customer may register a complaint verbally or in writing. Where required, assistance will be made available in preparing a written application, including the use of an interpreter, in providing assistance with a disability or by referring applicants to an advocate. All staff are empowered to handle complaints in the first instance and it is preferred they are dealt with promptly at the initial point of contact. Where this is not possible, we will seek to resolve the complaint as soon as possible and acknowledge the customer within 3 business days. The principles of natural justice will be observed. This means processes will be fair, equitable and reasonable. All parties will have access to relevant information and are able to respond where relevant.

The CEO has the discretion to refer the complaint to an independent third party for mediation, conflict resolution or neutral evaluation where the CEO believes appropriate.

6.1 Complaints involving a representative of the City of Charles Sturt

There are many representatives of the City of Charles Sturt. Complaints of this nature are handled differently depending on the representative involved. a. Staff member – this may relate to how a staff member has behaved or undertaken their

responsibilities. All complaints regarding a staff member are referred to the appropriate Manager. b. Council member - this may relate to how a Council member has conducted themselves or undertaken

their responsibilities. All complaints regarding Council members are handled in accordance with the Council Member Code of Conduct Policy.

c. Contractor - this may relate to how a contractor has conducted themselves or undertaken their responsibilities. All complaints are referred to the Business Unit Manager/Supervisor responsible for the specific work being undertaken by the contractor.

d. Volunteer – this may relate to how a volunteer has conducted themselves or undertaken their responsibilities. All complaints regarding volunteers are referred to the Volunteer Service Development Officer.

6.2 Complaints governed by legislation or statutory review

Council may be limited in its authority by policies and/or legislation. When a customer complains about a problem which exceeds Council’s jurisdiction they may be referred to an external source. It is important that the complainant is provided with details of the relevant authority and policy and/or legislation to assist them to understand Council’s role.

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6.3 Complaints disclosing public interest information The community have a right to demand that Council conducts itself with integrity, honesty and diligence. If you have formed a reasonable suspicion that this is not happening, and you consider the conduct could raise a potential issue of corruption, misconduct or maladministration in public administration, then you should consider making a complaint or report to the Office for Public Integrity (OPI). The Office of Public Integrity contact details are: Level 1, 55 Currie Street Adelaide, GPO Box 11066, Adelaide SA 5001 (08) 8207 1777

6.4 Complaints under the Public Interest Disclosure (PID) Act

Council supports the appropriate disclosure of public interest information. Public Interest Information falls into two categories:

1. Environmental and Health Information • information that raises a potential issue of a substantial risk to the environment or to the health or

safety of the public generally, or significant section of the public

2. Public Administration Information • information that raises a potential issue of corruption, misconduct or maladministration in public

administration

What is an Appropriate Disclosure of Public Interest Information? Environmental and Health Information Disclosure An appropriate disclosure made to a relevant authority (e.g Council)

• informant (ie the person making the disclosure) believes on reasonable grounds that the information is true (or may be true, and is of sufficient significance to justify disclosure so truth may be investigated) and

• that the disclosure is made to the Responsible Officer, member, officer or employee of the Council

Public Administration Information Disclosure • informant reasonably suspects the information raises a potential issue of corruption, misconduct

or maladministration in public administration • informant is a Public Officer • that the disclosure is made to a

• Responsible Officer or a person responsible for the supervision of public officer or Responsible Officer (for a disclosure about a Public Officer) or

• made to a member, officer or employee of Council (in relation to a disclosure made about a location within the Council area)

• wants to have their information kept confidential and have the protections under the PID Act Council’s management of the assessment and investigation of these disclosures is contained in its Public Interest Disclosure Procedure.

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6.4 Internal Review of Council Decision Complaints

Sometimes complaints regarding a Council decision policy, procedure, service or fee require a formal application to be lodged and, in this instance, the formal complaint will then be handled in accordance with Council’s Internal Review of Council Decisions Policy and Procedures.

7. Other Options While Council prefers to resolve requests for review directly with our customers, it does not negate customers’ rights to seek an external review of a decision through the State Ombudsman Ombudsman SA Level 9, 55 Currie Street, Adelaide PO Box 3651, Rundle Mall SA 5000 Telephone: (08) 8226 8699 Facsimile: (08) 8226 8602 Email: ombudsman@ombudsman.sa.gov.au

and, other legal appeal processes or the Courts at any time during the complaint handling process.

8. Definitions List all key terms and acronyms that are used in the policy, and their definition.

Key Term – Acronym Definition Complaint A complaint is made when a customer:

• expresses or infers dissatisfaction with a product or service delivered by the organisation which has, or should have, been received that has failed to reach the standard stated, implied or expected. This may include decisions of Council, its policies, procedures, charges, employees, agents or the quality of Council services; and/or • informs and notifies the Council of his/her belief that the Council has failed to act upon a request for service within a reasonable timeframe.

Feedback can take the form of comments, both positive and negative, about services provided by Council without necessarily forming the basis of a complaint

Request for Service an application to have Council or its representative take some form of action to provide or improve a Council service

New Service A service not currently provided by Council

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Internal Review of Council Decision A formal request for a review under the Local Government Act 1999 Section 270

Public Officer Schedule 1 of the Independent Commissioner Against Corruption Act provides a list of public officers. Public Officers include

• Members of the South Australian Parliament

• Members of the South Australian judiciary • South Australia Police officers • Public service employees • Councillors • Council employees • Persons contracted to perform work for a

public authority or the Crown

19/202547 City of Charles Sturt 72 Woodville Road, Woodville, South Australia 5011 T 08 8408 1111 F 08 8408 1122 www.charlessturt.sa.gov.au

Public Interest Disclosure Procedure

Procedure Name: Public Interest Disclosure Procedure

Reference Number:

Classification Internal - Procedure

First Issued/Approved: August 2019

Review Frequency: 2 Years

Last Reviewed: August 2019

Next Review Due: August 2021

Owner: General Manager Corporate Services

Council File Reference:

Applicable Legislation: Public Interest Disclosure Act

Relevant Policies: Customer Experience Policy

Related Procedures:

Compliance Standard: 1. Purpose

The purpose of this procedure is to set out the steps to be taken to capture and respond to appropriate disclosures made under the Public Interest Disclosure Act 2018 (PID Act), and to outline the protection offered to those who make appropriate disclosures. The PID Act creates an obligation to maintain the confidentiality of all people who make an appropriate disclosure of public interest information. The Chief Executive Officer is committed to ensuring that the City of Charles Sturt has a culture that supports open and honest discussion. The City of Charles Sturt aims that elected members, staff, contractors, volunteers and members of the community feel that they can make complaints to the appropriate person without fear of reprisal. It is recognised that there are times where those parties may wish to make a protected disclosure, and as such the CEO has appointed Responsible Officers and ensured that there is a system in place for dealing with disclosures and ensuring the identity of informers is protected. It is expected that these systems be tested annually to ensure Informants Identities are being protected.

2. Procedure What Disclosures of Public Interest Information can be made? There are two categories of Public Interest Information:

1. Environmental and Health Information Information that raises a potential issue of a substantial risk to the environment or to the health or safety of the public generally, or significant section of the public

2. Public Administration Information Information that raises a potential issue of corruption, misconduct or maladministration in public administration

What is an Appropriate Disclosure of Public Interest Information? Environmental and Health Information Disclosure An appropriate disclosure made to a relevant authority (e.g Council) by any member of the community where;

• informant (ie the person making the disclosure) believes on reasonable grounds that the information is true (or may be true, and is of sufficient significance to justify disclosure so truth may be investigated) and

• that the disclosure is made to a Responsible Officer, member, officer or employee of the Council, and

Public Administration Information Disclosure An appropriate disclosure made by a Public Officer where;

• informant reasonably suspects the information raises a potential issue of corruption, misconduct or maladministration in public administration, and

• the disclosure is made to a • Responsible Officer or a person responsible for the supervision of a public officer or

Responsible Officer (for a disclosure about a Public Officer) or • Member, officer or employee of Council (in relation to a disclosure made about a location

within the Council area) A diagram of the Assessment is contained in the Table in Appendix A Confidentiality of the informant Central to this procedure is the requirement to keep the informant’s identity confidential, unless the Informant has allowed their details to be provided to another person. There are only a few circumstances where this will not happen (as allowed for in the Public Interest Disclosure Guidelines which can be found at icac.sa.gov.au/pid-guidelines ) :

• required by the Office of Public Integrity (OPI) • where there is imminent risk of serious injury or death • where necessary for an investigation

There are very few occasions where an Informant’s identity is required for an investigation to be undertaken. Where this is the case, the Informant will be consulted first. If the informant declines, the Responsible Officer/Investigating Officer will advise the Informant that their assessment/investigation may be compromised because of this. If the Responsible/Investigating Officer considers the disclosure of significant importance to investigate they will seek legal advice before releasing the Informant’s identity.

Overview of Procedure Disclosure Made To Responsible Officer

Disclosure Made To Staff or Elected Member

Responsible Officer (RO) receives disclosure

Responsible Officer (RO) assesses the complaint

RO notifies relevant authority (if necessary)

RO notifies OPI of appropriate disclosure

RO notifies Informant of Assessment within 30 days

RO forward to appropriate person for investigation (if

warranted)*

Appropriate person notifies Informant (if an Informant

has disclosed their details to be given to the person

investigating) within 90 Days

If action taken, RO notifies OPI

Staff Member / Elected Member receives

disclosure

Staff Member/ Elected Member contacts

Responsible Officer (RO)

RO assists Staff Member/Elected Member

in process

RO assists Staff Member/Elected Member

assesses the complaint

RO assits RO assists Staff Member/Elected Member to notify relevant authority

(if necessary)

RO assists Staff Member/Elected Member

to notify OPI of appropriate disclosure

Staff Member/Elected Member notifies

Informant of Assessment within 30 days

RO forward to appropriate person for investigation (if

warranted)*

Appropriate person notifies Informant (if an Informant has

disclosed their details to be given to the person investigating) within

90 days

Investigator notifies OPI

Further information of each of the Steps is Contained in Appendix A Appendix A Council’s Procedure- Those Receiving Disclosures

Framework Task

Receive Council’s preference is for disclosures to be made directly to one of the Responsible Officers

• Alana Martin - Team Leader Governance and Business Support 8408 1233 ajmartin@charlessturt.sa.gov.au

• Nicky Cavallo - Team Leader Customer Contact 84081 260 ncavallo@charlessturt.sa.gov.au

• Mick Davey- Coordinator Arboriculture 8408 1514 mdavey@charlessturt.sa.gov.au • Shin-Yi Ong- Senior People and Culture Advisor People and Culture 8408 1116

song@charlessturt.sa.gov.au • Candie Trimboli- Senior People and Culture Advisor 8408 1508

ctrimboli@charlessturt.sa.gov.au Contact can also be made:

o By email to ResponsibleOfficer@charlessturt.sa.gov.au o In hard copy mail to Responsible Officer PO Box 1 Woodville SA 5011

There is a single Responsible Officer responsible for monitoring communication. Where a disclosure is made to an employee or Elected Member, they should contact a Responsible Officer as soon as possible who will assist them in meeting legislative requirements. Where an employee or Elected Member receives a public interest disclosure, they must not divulge the identity of the informant, even to the Responsible Officer, without express permission of the informant.

Assessment

Does the disclosure suggest there is an imminent risk of serious physical injury or death to any person or the public generally? If so, the recipient of the disclosure must immediately communicate such information as may be necessary to mitigate that risk to the most appropriate agency (eg. South Australia Police, SafeWork SA, SA Ambulance, Environment Protection Authority).

If the recipient of the disclosure forms a reasonable suspicion that the matter(s) the subject of the disclosure involve(s) corruption in public administration or serious or systemic misconduct or maladministration in public administration, the recipient must notify OPI immediately and follow all instructions, this may mean that parts of this procedure are not followed

Framework Task

Types of Public Interest Information

1. Environmental and Health Information Information that raises a potential issue of a substantial risk to the environment or to the health or safety of the public generally, or significant section of the public

2. Public Administration Information Information that raises a potential issue of corruption, misconduct or maladministration in public administration

Is it a Public Interest Disclosure?

Framework Task

Notification to OPI

Those who have received the disclosure will as soon as practicable notify OPI of the disclosure via the online notification form at icac.sa.gov.au OPI will provide a unique reference number. This reference number should be used when referring matters to investigation

Stored The Responsible Officer will manage the storage of information in the following way: Record Management

• Contacted the IS Service Desk for a Secure Public Interest Disclosure container • Confirm who should have access (in the majority of cases it will just be one

Responsible Officer) • The Naming Convention will be Public Interest Disclosure- [OPI identification

Does the disclosure relate to environmental health

information (see definition above)

Does the disclosure relates to a location within the

Council area?

Has the disclosure been made to a member, officer

or employee of Council

Does the disclosure relate to public administration

information (see definition above)

Does the Informant reasonably suspect the

information raises a potential issue of corruption,

misconduct or maladministration in public

administration

Is the informant a public officer?

Does the disclosure relate to a Public Officer?

Has the disclosure made to someone who is a

Responsible Officer OR to someone who is

responsible for the management or supervisor

of the employee

Does the disclosure relate to a location within the

Council area?

Has the disclosure been made to a member, officer

or employee of Council

Framework Task Number] – [Date Complaint Received] – Responsible Officer [Name]

• Responsible Officers will audit the documents in the container to ensure no one else has access to the documents

• Where someone else accessed documents this will be raised as a Code of Conduct issue for investigation

• Where an investigation has been referred internally to manage (i.e. as a disciplinary investigation), the records in relation to the actual investigation will be managed in line with People and Culture processes

Other Systems • The Responsible Officer email address is monitored by a single Responsible Officer

who will delete the emails from the email account once read. For the purposes of record management these emails will be saved without any identifying details (as above). When this Officer is on leave it will be assigned to another Responsible Officer for the duration of the period.

• Where a disclosure has been captured through Council’s Customer Requests Systems the Responsible Officer will work to ensure that the record is deleted from the system and those who, inadvertently have become aware of the disclosure are made aware of their obligations not to disclosure the information that they have learnt.

• The Responsible Officer will also make the Informant aware that this has occurred.

Notification to Informant

The Responsible Officer (or person to whom the disclosure has been made) will notify the informant of the assessment within 30 days of receiving the disclosure. Where the matter requires referral, the Responsible Officer will ask the Informant if they have permission to disclose the Informant’s Identity. Where the informant does not give this permission they should be made aware that the Investigating Officer will be unable to contact them, advising of the outcome.

Referral to Authority

Where the Responsible Officer (or person who had received disclosure) has assessed it as appropriate the disclosure shall be referred to the appropriate authority. Examples may be OPI, the Ombudsman, EPA, SafeWork SA, SAPOL, DPTI etc. Where an Informant has given permission to disclose their details care should be given to disclose the complaint to an appropriate person within the organisation. In handing over the complaint the following must be conveyed;

• That it is a disclosure under the Public Interest Disclosure Act • The OPI Reference Number • Remind them of their obligations:

o to keep the Informant’s details in confidence o to notify the informant within 90 days of action taken (where aware of the

Framework Task Informant’s details)

o to notify OPI of the Action taken

Referral Internally to Investigate

Where the Responsible Officer (or person who had received disclosure) has assessed it as appropriate, the disclosure shall be referred to the appropriate staff member for investigation. Where an Informant has given permission to disclose their details care should be given to disclose the complaint to an appropriate person within the organisation. In handing over the complaint the following must be conveyed;

• That it is a disclosure under the Public Interest Disclosure Act • The OPI Reference Number • Remind them of their obligations:

o to keep the Informants details in confidence o to notify the informant within 90 days of action taken (where aware of the

Informant’s details) o to notify OPI of the Action taken

Investigation Undertaken by Responsible Officer

Where the Responsible Officer (or person who had received disclosure) has assessed it as appropriate the disclosure shall be referred to the Responsible Officer for investigation. Responsible Officers have the authority to purchase legal advice as needed. Where an Informant has given permission to disclose their details care should be given to disclose the complaint to an appropriate person within the organisation. The Responsible Officer will

o notify the informant within 90 days of action taken (where aware of the Informant’s details)

o notify OPI of the Action taken

Consult Where appropriate the Responsible Officer will inform the CEO where a disclosure has been received and, if the matter requires investigation where it has been referred to. Dependent on the nature of the disclosure, other staff and/or elected members may need to be consulted or interviewed.

Complaints with the Procedure

If an Informant believes that his or her disclosure is not be dealt with appropriately, they can contact the General Manager Corporate Services 8408 1240.

Public Interest Disclosure Act- Information For Those Making A Disclsoure

What is the Public Interest Disclosure Act? • Protects people (informants) who make appropriate disclosure of public interest information • This means, if you request it, your identity will be kept confidential, except where

• Required by the Office of Public Integrity (OPI) • Where there is imminent risk of serious injury or death • Where absolutely necessary for an investigation

• Penalties on individuals for • not keeping information confidential • victimisation • preventing or hindering a disclosure

• There is also a penalty for false or misleading disclosure • Penalties for both include jail time

What Disclosures of Public Interest Information Can Be Made? Environmental and Health Information

3. Information that raises a potential issue of a substantial risk to the environment or to the health or safety of the public generally, or significant section of the public

If information falls under this category- you should consider if the Environmental Protection Agency (EPA) is the appropriate authority. You have the right to make a protected disclosure with EPA 8204 2004.

Public Administration Information

• Information that raises a potential issue of corruption, misconduct or maladministration in public administration

If information falls under this category you may have a duty to report to ICAC /OPI. See https://icac.sa.gov.au/obligations for more information. You have the right to make a protected disclosure with ICAC/OPI

What is an Appropriate Disclosure? • Protections are provided to public officers who make an appropriate disclosure of public administration

information and for anyone who makes an appropriate disclosure of environmental and health information. • Any member of the community can make a disclosure of environmental and health information, however, to

gain the protections provided under the PID Act, they: • must believe on reasonable grounds that the information is true; or • if they are not in a position to form such a belief, believe on reasonable grounds that the information

may be true and is of sufficient significance to justify its disclosure so that its truth may be investigated.

• The City of Charles Sturt is a relevant authority for Environmental Health Information where the issue occurs within its boundaries and where an issue of corruption, misconduct or maladministration is related to the work it does (or its contractors do).

• It is Council’s preference that these disclosures be made to Council’s Responsible Officers.

Who Are Council’s Responsible Officers? • Alana Martin - Team Leader Governance and Business Support 8408 1233 ajmartin@charlessturt.sa.gov.au • Nicky Cavallo - Team Leader Customer Contact 84081260 ncavallo@charlessturt.sa.gov.au • Mick Davey- Coordinator Arboriculture 8408 1514 mdavey@charlessturt.sa.gov.au • Shin-Yi Ong- Senior People and Culture Advisor People and Culture 8408 1116 song@charlessturt.sa.gov.au • Candie Trimboli- Senior People and Culture Advisor 8408 1508 ctrimboli@charlessturt.sa.gov.au

Process