Complaintshandling Final

complaints handling
J

EFFICIENCY UNIT
i
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.

Complaints Handling

Foreword

The Hong Kong Government comprises dozens of departments and tens of thousands of
ii 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:

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

Executive Summary

introDUction management practices must be in place
2 within organisations, and there must be
A broad working definition of a complaint is procedures in place to enable a system-
‘any expression of dissatisfaction that needs a wide overview of complaints handling.
response’ (Cabinet Office, 1998). The primary Good complaints handling does not always
focus of this report is on best international result in the complainant being happy with
practice in complaints handling, with a the outcome, but it does ensure that the
particular emphasis on internal complaints complaint is taken seriously and addressed
handling systems within public service thoroughly. Central to complaints handling is
organisations. the principle of empathy with the complainant
and recognition of the person’s concerns.
A good internal complaints handling system This involves actions such as dealing with
provides benefits to the organisation: serving the complaint as speedily as possible,
as a quick and efficient means of resolving careful listening, and apologising when
difficulties that may arise; promoting good the organisation commits fault.
relations and communications with the public;
indicating where problems and shortcomings access to anD confiDence
exist in the provision of services and areas in the complaints hanDling
that might need improvement; and helping system
the organisation to avoid unfavourable
publicity. A vital step in determining access to the
organisation to enable complaints to be made
Similarly, a good complaints handling is deciding in which ways people can lodge
system provides benefits to the public: complaints. A variety of means are possible,
providing a quick, easy and cost-effective including telephone, face-to-face meeting,
means of resolving difficulties with public feedback form (online and/or hard copy)
bodies; obtaining redress where necessary; and so on. However, people often do not
promoting a sense of empowerment in the know how to access the complaints system.
individual by enabling him/her to have a role More innovative organisations pro-actively
in contributing to improvements in the public encourage complaints access, through
service; and giving people the assurance that such means as information provision and
their complaints are being taken seriously distribution strategies aimed at specific
and that they are being treated properly, target groups.
fairly and impartially.
A particular fear of some people considering
For an effective complaints handling system lodging a complaint is that they will be
to operate, people need to be able to access subject to discrimination or harassment if
the system and have confidence in it, good they proceed with their complaint. This may

Complaints Handling

EXECUTIVE SUMMARY

be a particular concern among vulnerable then assesses the likelihood of recurrence
individuals and groups. Good practice guides of the incidents or events giving rise to the 3
indicate that, in an attempt to remove the complaint, and finally assigns a risk level to
fear of retribution, organisations should the complaint on the basis of the findings
clearly inform clients that they will not be from the first two stages.
discriminated against as a result of any
complaint. Another good practice is to Particular challenges for complaints handling
establish internal follow-up procedures to are present where multiple agencies are
address the risk of discrimination against involved in delivering separate services in
clients who lodge a complaint. Such a a single location, or in jointly delivering a
follow-up procedure might involve contacting single service, or where private organisations
a sample of customers who had complained to may also be involved, either alongside or as
check that the complaint had been addressed partners in the project to deliver a service.
and resolved and that the customer had not In these circumstances, it is particularly
encountered any difficulties or harassment important that the respective roles and
as a result of lodging the complaint. responsibilities in administering legislation,
making policy, and handling complaints, are
Staff may also have concerns that need to clearly spelt out and visible to the public. In
be addressed. Staff may fear being criticised the absence of clarity and visibility, members
for being the subject of complaints, leading of the public can have difficulty in knowing
to a situation where they fear complaints. To how and where to complain. Apart from
avoid this, good practice guidance suggests: issues that cut across different sectors and
creating an environment in which complaints organisations, making complaints by the
are seen as opportunities to improve services public can also be difficult because of the
or systems, and making sure that staff feel sheer complexity of the public service.
confident that procedures support them. Simplifying this complexity for the public
is a challenging but vital part of complaints
managing the complaints handling. Some organisations and indeed
hanDling system within sectors are now moving towards a single
organisations point of contact for complaints.

Risk assessment can be an important part Another challenge faced by many public
of a good complaints handling system. Risk servants dealing with complaints is how to
management is increasingly featured in good handle complainants who are 'difficult' in
practice guidance. Some organisations use some way, either in their tone and approach, in
risk assessment tools. One risk assessment their ability to articulate their case, or because
tool adopts a three-step process which firstly they are making vexatious complaints with
categorises the consequences of a complaint, little substance. To be able to deal with such

Complaints Handling

EXECUTIVE SUMMARY

complaints tactfully yet forcefully requires A supportive culture within the organisation
4 that good procedures and standards are is vital to the success of complaints handling.
in place, and that staff have the skills and In particular, to be effective, complaints
competencies needed to manage such systems should be supported by senior
difficult situations. Good practice suggests management. It is notable that in many good
developing guidance that includes details practice organisations the chief executive is
of how to handle difficult customers, in an active proponent of complaints handling,
person or on the phone, and how to deal and the complaints handling manager or unit
with their letters; instructions about a cut-off reports directly to the chief executive and/
point, which should be reached only after a or the senior management team. In terms of
management decision; and instructions for supporting front-line staff, who most often
dealing with any further problems. have to deal directly with complaints, these
pressures should be recognised and as much
Many leading public service organisations are support as possible provided to enable them
now providing electronic means for citizens to do their jobs well.
to lodge complaints. Common initiatives
are: providing an email link on web sites for oVerseeing complaints
citizens to electronically submit comments hanDling – a system-wiDe
or complaints; providing on-line access to perspectiVe
structured complaints forms for specific
programmes; allowing citizens to complete Above the level of the organisation, it is
and forward the form on-line, and having important that a systemic view of complaints
forms that can be downloaded, printed, handling is taken. A ‘whole of government’
and mailed to the organisation. Information perspective is needed, within which the
technology is also used to enable better complaints handling procedures of individual
storage, communication and tracking of organisations fit. Important aspects of this
complaints. system-wide perspective are the categorisation
of complaints and ensuring that lesson
Organisations need to periodically assess learning is spread system-wide.
the quality of their complaints handling
system. Best practice organisations tend to In terms of categorising complaints, several
do this by taking and reviewing a sample of countries and sectors encourage the use of
complaints and determining how well they a complaints ‘ladder’ whereby complaints
were dealt with, the degree to which there are moved up the hierarchy as necessary,
was resolution, and the degree and quality often using a three-tier process. The first tier
of communication with the complainant. 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

EXECUTIVE SUMMARY

internal review or investigation by more
senior staff or a designated complaints 5
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
y Ensuring that people with complaints
can easily access the system
y Dealing with people promptly and
sensitively, bearing in mind their
individual circumstances
y Being open and accountable and acting
fairly and proportionately
y 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.

Complaints Handling

1. Introduction

Complaints handling is an important part information to further enhance and deliver
6 of any organisation’s work, but one that can quality services to the citizen. The increasing
easily be misunderstood or under-appreciated. emphasis on ‘personalisation’ of services and
The challenge for most organisations is to responsiveness to the needs of users are
implement a complaints handling system important developments that also increase
that effectively meets the needs of citizens the need for a positive approach to be taken
and the organisation. In this regard, a number towards complaints.
of studies examined in this report set out
international good practice in complaints However, it is important to remember that
handling in the public service. The primary the state is not just a service provider, as it
focus is on the development of internal defines both entitlements and obligations
complaints handling within organisations. and it also interacts with the users of its
In the UK an important general guiding services in a variety of ways. In this context,
point regarding complaints handling is Brewer (2007) for example warns: ‘Public
stressed in the House of Commons Public sector managers and professionals need an
Administration Select Committee (2008) awareness of how public reform strategies
report When Citizens Complain (http://www. oriented exclusively towards a strengthened
parliament.the-stationery-office.co.uk/pa/ consumer role do risk undermining important
cm200708/cmselect/cmpubadm/409/409. aspects of the complaints handling and
pdf ), which suggests that public services redress strategies embedded in the “rule of
need to adopt the perspective of citizens law” and “due process” features of citizen-
who use them: ‘They should seek to discover oriented public administration.’ In other
what complainants hope to achieve from words, in a public service context it is not
making their views known; they should enough to simply respond speedily to an
have a systematic and active strategy for individual complainant. Attention must be
monitoring and learning from complaints given to treating all citizens fairly. This goes
to inform service delivery.’ beyond seeing complainants as customers,
to seeing them more as citizens with rights
why is gooD complaints and responsibilities.
hanDling important?
A good internal complaints handling system
In recent decades, public sector organisations provides benefits to the organisation: serving
in many of the most reforming countries have as a quick and efficient means of resolving
developed their complaints handling systems difficulties that may arise; promoting good
as part of quality customer service initiatives. relations and communications with the public;
Under the public service modernisation indicating where problems and shortcomings
programme, public service organisations exist in the provision of services and areas
have been conscious of using complaints that might need improvement; and helping

Complaints Handling

INTRODUCTION

the organisation to avoid unfavourable Having a good complaints handling system
publicity such as complaints lodged to in place in an organisation can also save time 7
the media, Ombudsman, etc. Similarly, a and cost down the line. Many complaints in
good complaints handling system provides Ombudsman’s offices result from a breakdown
benefits to the public: providing a quick, in communications between public bodies
easy and cost-effective means of resolving and their clients. Studies have shown that
difficulties with public bodies; obtaining most such complaints could and should be
redress where necessary; fostering a greater easily and swiftly settled at a very early stage
sense of inclusiveness or partnership with by public bodies themselves.
the public service; promoting a sense of
empowerment in the individual by enabling John McMillan, Australian Commonwealth
him/her to have a role in contributing to Ombudsman, identifies ten lessons learned
improvements in the public service; and from thirty years of complaints handling
giving complainants the assurance that their that summarise very well the benefits to
complaints are being taken seriously and be found in handling complaints well (see
that they are being treated properly, fairly case study).
and impartially.

Case stUDy – ten lessons from tHirty years of Complaints
HanDling

1. Complaints are a fact of life
Problems 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

4. complaints must be taken seriously by the leaders of an organisation
8 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 government
External 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 task
It 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

INTRODUCTION

what is a complaint?
9
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/)

Complaints Handling

2. Access to and confidence in the complaints
handling system
People need to have confidence that ways in which people can
10 their complaint will be handled fairly and loDge a complaint
courteously. Citizens need to know that it
is easy to find out where to complain and A vital first step in determining access to
how to complain. They want to know that the organisation to enable complaints to
complaints are not only invited but are treated be made is deciding in which ways people
seriously, that they will be listened to with can lodge complaints. The Centrelink case
empathy, apologised to if necessary and that study from Australia shows that a variety of
actions will be taken to redress the situation means of making a complaint can be used.
as needed. A vital first step in this process is Obtaining customer complaints may seem
ensuring access to the complaints handling straightforward, but decisions need to be
system for all who may wish to avail of it. made as to how complaints are to be made
and fed into the system to be processed.

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:

y By telephone, through the Customer Relations Line, and on Freecall numbers, which
accepts telephone typewriter (TTY)
y By telephone to a Customer Service Centre (CSC) or a Call Centre (CC)
y By speaking to a Centrelink Customer Service Officer (CSO) directly at a CSC
y By completing a customer comment card and lodging it either at a CSC or mail by
reply paid post
y By email, using a Service Feedback form that can be completed and forwarded via
Centrelink’s website
y 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

Complaints Handling

ACCESS TO AND CONFIDENCE IN THE COMPLAINTS HANDLING SYSTEM

Do people know how to loDge cent for participants identified as being
a complaint? indigenous Australians (Australian National 11
Audit Office, 2005).
Staying with the Centrelink example, the 2002
Centrelink National Customer Satisfaction Study This highlights the need for work on the part
asked those customers surveyed to identify of organisations in terms of advertising their
ways in which they could make a complaint complaints system and ensuring, as far as
to Centrelink about its service. Some 26 per practicable, that all clients and customers
cent of customers were unable to identify are aware that a complaints system exists
at least one way in which they could make and how to access it (see case study).
such a complaint. This figure rose to 39 per

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:

y 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?
y Has the organisation published its standards of service and made them available so
that people know what standards of service they may expect?
y Can clients make complaints in a variety of ways – in person, in writing, by fax, and
by telephone?
y Does the organisation provide information about formal independent review bodies,
such as relevant judicial bodies?
y 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?
y Has the organisation designated staff to help people formulate and pursue their
complaints?
y Are there suitable arrangements to allow people with disabilities to complain?
y 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


A key point here is that a variety of means of y User tests before distribution (e.g.
12 letting people know that they can complain online scorecard)
and how they can complain is needed. These y Flexible distribution strategies: email,
may include: face-to-face, mail-outs, libraries,
government and community
y Developing specific information
agencies
and resources: fact-sheets, posters,
translated information, kids colouring y Promotional ‘goodies’: stress balls,
in sheets, and brochures fridge magnets, pens, bags
y Regular publications: newsletters, y Maintaining a database of key
contacts.
email alerts
y Websites as a recognised source of Source: Petre (2007)
information and useful links

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


Dealing with client anD staff complaint had been addressed and resolved
fears anD concerns aboUt and that the customer had not encountered 13
loDging a complaint any difficulties or harassment as a result of
lodging the complaint.
In the UK, a National Audit Office (2008)
study found that only 5 per cent of people Staff may also have concerns that need to be
who had been dissatisfied with the services addressed. The Cabinet Office (1998) report
of the National Health Service made a formal How To Deal With Complaints suggests that ‘a
complaint. Sixteen per cent made an informal “blame culture” where members of staff are
complaint to which they did not expect a criticised for being the subject of complaints
written response, but 79 per cent did not only leads to a situation where staff fear
complain at all. Most commonly, people did complaints. They then try to brush them under
not complain because they lacked confidence the carpet, and deal with them negatively
in the system. Thirty-two per cent who did not or even with hostility’. To avoid this,
complain formally stated that they thought the guidance suggests creating an
nothing would be done as a result of their environment in which complaints are seen
complaint, while 6 per cent did not feel their as opportunities to improve services or
complaint would be looked at with sufficient systems, and making sure that staff feel
independence or fairness. confident that procedures support them.

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

Complaints Handling

3. Managing the complaints handling system within
organisations
Once a complaints handling system is in place iDentifying gooD practice
14 that the public can access, it is important principles in complaints
that the system is operated efficiently hanDling
and effectively and that the needs of the
complainant are addressed thoroughly, The Office of the Ombudsman, Ireland,
courteously and promptly. There are general sets out the essential principles of a good
principles and practices to help ensure that internal complaints handling system (see
complaints handling is well managed in case study).
public service organisations.

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

fair and independent
Complaints that have not been resolved by the original decision-maker should be 15
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 (see case study). Also, in Western Australia,
Canada Secretariat, in guidance on good five good practice principles guided the
practice in complaints handling, includes redesign of the complaints handling system
a checklist of questions to ask in order to in the Department of Education and Training
ensure that an organisation is operating a (see case study).
system that is responsive to client needs

Complaints Handling


case stUDy – ensUring a responsiVe complaints hanDling
16 system

Questions to ask about responsiveness:

y Do procedures allow employees to resolve complaints on the spot if possible, and to
provide immediate redress, where appropriate?
y 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?
y 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?
y Does the organisation monitor time limits and review them regularly?
y Do employees keep complainants informed of the progress of their complaint?
y Are staff trained to handle complaints?
y Are staff trained in interpersonal skills, including skills for dealing with abusive and
threatening behaviour?
y Does the system allow employees to retrieve information about a complaint
quickly?


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:

y 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
y 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


y A risk management framework and a culture open to receiving complaints supported
17
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
y 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
y An independent and escalated review process for investigating serious complaints,
together with redress options.

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

conDUcting a risk categorising a complaint. The risk assessment
assessment of complaints tool adopts a three-step process which
firstly categorises the consequences of a
As indicated in the Department of Education complaint, then assesses the likelihood of
and Training Western Australia case study, recurrence of the incidents or events giving
risk assessment can be an important part rise to the complaint, and finally assigns a
of a good complaints handling system. Risk risk level to the complaint. Risk assessing a
management is increasingly featured in complaint can ensure that the subsequent
good practice guidance. For example, the UK management process and any associated
Healthcare Commission recommends the use investigation are proportionate to the severity
of a risk assessment tool to aid decisions on of the complaint and the related risks.

Complaints Handling


case stUDy – DeVeloping a risk assessment tool for
18
complaints

1. the consequence categorisation table assists in determining how to
categorise 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

Complaints Handling


2. the likelihood categorisation table assists in determining the likelihood of
recurrence of the incident or circumstances giving rise to the complaint: 19

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 the
tables 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


Dealing with cross-cUtting partners in the project to deliver a service.
20 anD complex complaints In these circumstances, it is particularly
important that the respective roles and
Particular challenges for complaints handling responsibilities in administering legislation,
are present where multiple agencies are making policy, and handling complaints, are
involved in delivering separate services in clearly spelt out and visible to the public. In
a single location, or in jointly delivering a the absence of clarity and visibility, members
single service, or where private organisations of the public can have difficulty in knowing
may also be involved, either alongside or as 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


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 21
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

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

Complaints Handling


Apart from issues that cut across different Simplifying this complexity for the public is
22 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 A standardised complaints handling system should be introduced for scrutiny
organisations and service providers in all public services
y 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


case stUDy – Dealing with complexity in the reVenUe sector
23
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


case stUDy – Dealing with a DifficUlt complainant in the Uk
24 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.

documents/HC_Complaints_Handling_tagged.pdf

Complaints Handling


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

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 reached only after a management decision;
complainants, the Cabinet Office (1998) report and instructions for dealing with any further
How To Deal With Complaints recommends problems: further letters from the customer
that 'your complaints procedure should should be checked to make sure that they do
set out guidance on handling people who not contain new issues that need a reply’.
complain continually. This guidance should
include: details of how to handle difficult The New South Wales Ombudsman’s Office
customers, in person or on the phone, and is coordinating a cross-agency project to
how to deal with their letters; instructions develop and trial management strategies for
about a cut-off point, which should be complainants who behave unreasonably. ‘The

Complaints Handling


project recognises categories of unreasonable Using information anD
26 conduct that place an inequitable burden commUnications technology
on the organisation’s resources and often
cause distress for staff.’The New South Wales The extent to which information and
Ombudsman’s Office is ‘now trialling various communications technologies (ICTs) can
management strategies for responding to be underused is illustrated by a UK National
unreasonable conduct. Staff attended one-day Audit Office (2005) report Citizen Redress,
training sessions and were given material which found that most departments excluded
outlining a range of recommended responses complaints received by email or telephone.
to difficult behaviour. Staff have been asked The House of Commons Public Administration
to test these strategies when a complainant Select Committee (2008) notes that in terms
exhibits particular behaviour. The data from of accessibility of citizens to a complaints
this trial will inform the project’s conclusions system, ‘insisting on complaints in writing can
and final paper.’ (Source: Commonwealth potentially defer valid complaints and prevent
Ombudsman Annual Report 2006–2007) 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 Is the complaints process noted on the home page?
y Is there a ‘contact us’ button on the home page?
y Is there a dedicated complaints button or section at the ‘contact us’ page?
y 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


case stUDy – poor Use of website for complaints hanDling
27
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 Ensure that a search on the term ‘complaint’ provides pertinent information to
customers and stakeholders on its complaints handling system
y Provide customers and stakeholders with more explicit information as to the various
avenues by which to lodge a complaint
y Ensure that information on Centrelink’s complaints handling system is easily
identifiable by customers and stakeholders
y 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 not computer literate: ‘A complaints handling
advantages of ICT in terms of easily accessible, system must be conspicuous, easily accessible
convenient complaints handling systems for and simple to operate. It should take account
complainants and a means of developing a of the needs of different social groups and,
good complaints tracking and management even in an era of rapidly increasing computer
system for organisations (see US postal literacy, recognise that there are many people
service case study), it is also worth noting the without access to the Internet and/or the
important point that Brewer (2007) makes skills required to use it. An over-reliance on
in terms of over-reliance on information information technology can be a powerful
technology and the impact on those who are form of indirect discrimination (p.552).’

Complaints Handling


case stUDy – Us postal serVice tracking systems
28
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 qUality assUring complaints
are likely to see the use of blogs and Web hanDling systems
2.0 applications as an additional means of
encouraging and monitoring complaints There is a need for organisations to periodically
about public service organisations. As Wyld assess the quality of their complaints handling
(2007) notes: ‘We will also see research on systems. A Performance Audit of Customer
how blogs and other Web 2.0 tools are being Complaint Management, undertaken by
increasingly integrated into organisational Centrelink internal audit in October 2003,
homepages, as the line between what is a highlighted the need to include quality control
blog and what is a homepage quickly begins measures in the handling of complaints. The
to blur. As the penetration of text, audio and audit showed that Centrelink’s procedures for
video blogging elements increases, we may the handling of complaints did not ensure that
well see the distinction between blog and timely and satisfactory resolution (from the
homepage disappear, resulting in one site.’ perspective of the customer) was achieved
– see case study.

Complaints Handling


case stUDy – qUality assUring centrelink’s complaints
hanDling 29

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


further complaints and affects Centrelink’s capacity to ensure that it has adequately
30 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 sure that complaints handling is built into
cUltUre for managing the organisation’s corporate and strategic
complaints plans, and covered in annual reports.’ The
report also suggests that ‘management can
In the UK, the Cabinet Office (1998) report start to demonstrate their support for good
How To Deal With Complaints suggests that, complaints handling by sending a notice to
to be effective, complaints systems should be all members of staff stressing the importance
supported by senior management. The report of complaints and the benefits of handling
notes that ‘management should regularly them well.’ The report recommends that
review complaints information; and make ‘Chief Executives or equivalents in all public

Complaints Handling


services should be held personally responsible y Involve staff in developing complaints
for effective complaints handling. And this procedures 31
should be reflected in job descriptions and y Give staff the power to deal with
performance appraisals, including decisions complaints, so that they feel they
on performance-related pay.’ The report ‘own’ them
notes that in terms of supporting y Provide suitable resources (including
front-line staff, who most often have to training) so that staff can handle
deal with complaints, these pressures should complaints properly
be recognised and as much support as y Make sure that complaints handling
possible provided to enable them to do has status within the organisation and
their jobs well. The report recommends that is considered a career opportunity
management should: y Recognise and reward staff who handle
complaints well
y Make sure that complaints are seen as y Allow staff who handle complaints
part of overall customer care regular breaks to do other work
y Create a team spirit so that individuals y Display thank-you letters and action
do not feel isolated and members of taken to improve services as a result
the team can support one another of complaints.
y Recognise complaints handling as an
important part of everyone’s job

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


Case stUDy – Using training to DeVelop Complaints HanDling
32 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) directly to senior management, with three
stresses the importance of the example of quarters providing them with complaints
top management in a review of complaints information on a quarterly, or more frequent,
handling in health care trusts. They found that basis. Seventy-one per cent of adult social
‘the culture in terms of complaints handling service departments had complaints on
is dependent on the leadership provided by the agenda of senior management team
the chief executive, who sets the tone within meetings at least quarterly, though in 8 per
the trust. The relationship between the chief cent of authorities complaints were only
executive and the complaints manager and on the agenda annually. (Source: National
the level of interest the chief executive takes Audit Office (2008), http://www.nao.org.uk/
in complaints adds to the clout a complaints publications/0708/learning_from_complaints.
manager has when dealing with trust staff. aspx)
Chief executives also demonstrated their
commitment to complaints by locating Training and development supports can
their complaints manager close to their also play a significant role in helping create
own office.’ The NAO report found that a culture that encourages the acceptance of
‘two thirds of complaints managers report complaints handling in organisations.

Complaints Handling


case stUDy – DeVeloping a complaints toolkit for staff
33
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.’

documents/Complaints_Toolkit.pdf

Complaints Handling

4. Overseeing complaints handling – a system-wide
perspective
Above the level of the organisation, it is categorising complaints –
34 important that a systemic view of complaints the complaints ‘laDDer’
handling is taken. A ‘whole of government’
perspective is needed, within which the In terms of categorising complaints, several
complaints handling procedures of individual countries and sectors encourage the use of
organisations fit. Important aspects of this a complaints ‘ladder’ whereby complaints
system-wide perspective are the categorisation are moved up the hierarchy as necessary,
of complaints and ensuring that lesson often using a three-tier process. Best practice
learning is spread system-wide. 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
35
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.

Complaints Handling

OVERSEEING COMPLAINTS HANDLING – A SYSTEM-WIDE PERSPECTIVE

case stUDy – a gooD practice example to gUiDe Departments
36 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

5. Conclusion

Good complaints handling means: improvements in service. The use of advances
in information and communication technology 37
y Being citizen focused (ICT) systems can also provide benefits
y Ensuring that people with complaints in terms of communicating to customers
can easily access the system more effectively the complaints procedures,
y Dealing with people promptly and providing information on the complaints
sensitively, bearing in mind their individual process and providing the organisation with
circumstances an efficient tracking mechanism of how
y Being open and accountable and acting the complaints are being handled. Studies
fairly and proportionately show that an effective complaints handling
y Putting things right when things have system provides ‘free’ market research and
gone wrong this should be welcomed, rather than
viewing complaints as a negative element
y Apologising for the mistakes made when
where staff who are complained against
an apology is merited.
are blamed.
Good complaints handling is also about
The most efficient complaints handling
seeking continuous improvement, using
systems provide transparent, accessible
feedback and lessons learned to improve
information on the processes or systems
service design and delivery. An effective
involved in complaints handling in order
complaints system that offers a range of
to enable ease of access for citizens when
timely and appropriate remedies saves
they are unhappy or have not received
organisations time and money in the long
satisfactory service or treatment. Effective
run. It enhances the quality of service to its
complaints handling systems not only outline
clients, has a positive effect on staff morale
the organisation’s internal complaints handling
and improves the organisation’s relations with
systems but also provide information on
the citizen. It also provides useful feedback
external bodies who can deal with the issue
to the organisation and enables it to review
if redress has not been achieved satisfactorily
procedures and systems that may be giving
for the complainant at a local level.
rise to complaints.

Some organisations are now using risk
To the greatest possible extent, complaints
assessment tools to aid decisions on
should be handled at a local level, with a focus
categorising a complaint. Furthermore,
on communication between the organisation
a number of studies examined in this
and complainant at this initial stage. Greater
report recommend that a central point of
communication, training of staff in complaints
co-ordination and contact needs to be in
handling and accessible and informative
place for complaints handling involving a
complaints handling systems and procedures
number of agencies.
need to be in place for effective and efficient

Complaints Handling

CONCLUSION

‘But handling complaints effectively is not
38 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, 39
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

Complaints Handling

REFERENCES

Healthcare Commission (2008b),
40 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

REFERENCES

Ombudsman Western Australia (2006),
Report by the Ombudsman on complaints management processes in the Department of 41
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

Complaints Handling

EffiCiEnCy unit
13/f., West Wing
Central Government Offices
11 ice House Street
Central
Hong Kong

Email: euwm@eu.gov.hk
tel: 2165 7255
fax: 2524 7267
Website: www.eu.gov.hk

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