Complaints policy

1. Definition and Scope

1.1       A complaint or concern is an expression of dissatisfaction about an act, omission or decision of the organisation, or about the standard of service provided, which requires a response.

1.2       A complaint can be made by the person who is affected (usually someone using our services). Alternatively, it may be from a person acting on behalf of the person, where they have given consent for a third party to act on their behalf, the person lacks capacity, or has delegated authority (for example has a Lasting Power of Attorney).

1.3       If someone is acting on someone else’s behalf, it may be necessary to obtain written permission to disclose any personal information relevant to the investigation of the complaint, unless the person affected is unable to give consent, or has died.

1.4       We will only consider complaints made within twelve months of the event happening or within twelve months of discovering that there is cause to complain, unless there are good reasons for not having made the complaint within this timeframe. In this case, Step One may still decide to consider the complaint, if it remains possible to investigate the complaint fairly and effectively.

1.5       Step One will deal with complaints made by employees about a matter relating to their employment, or broader concerns about the organisation under the Grievance or Raising a Concern (Whistleblowing & Freedom to Speak Up) policy.

2. Roles and Responsibilities

2.1       The Board of Trustees will be given high-level information about all complaints raised by people who use our services (and their representatives) and what we are doing to address any problems. The Board of Trustees will help create an open culture based on listening, learning, and not blaming.

2.2       The Senior Leadership Team bears the organisational responsibility to ensure that the culture of services is one of openness and transparency and recognise that we have a Duty of Candour when dealing with any complaints. The Senior Leadership Team will ensure that we respond to complaints raised by people who use our services positively, and that appropriate action is taken to address them.

2.3       The Governance and Assurance Manager is responsible for reviewing information resulting from concerns and complaints, and ensuring that this results in improved service delivery, whether in response to highlighted faults or as a proactive measure to improve performance and increase the satisfaction of people who use Step One’s services. The Governance and Assurance Manager will determine the most appropriate route for handling concerns and complaints and will keep a comprehensive record of all complaints which reach investigation level.

2.4       Service Managers are responsible for ensuring that:

• They foster and promote an open culture where managers and colleagues provide regular opportunities for people who use their services to discuss concerns.
• They are responsible for supporting people who raise concerns or complaints via this policy, and for dealing with them in a timely way.
• They respond positively to any concerns raised and take timely, proportionate, and appropriate action to address them.
• Ensuring accurate and comprehensive records of individual complaints handled through frontline resolution.

2.5       All Step One Colleagues are required to understand their responsibilities to deal with any concerns or complaints raised by people who use Step One services, including the requirement to cooperate fully with any investigation. Colleagues are responsible for identifying concerns and complaints, escalating these to their line manager, and trying to resolve them wherever possible.

3. Principles of Complaints Handling

3.1       The organisation will ensure that complainants:

• Know how to complain and access support during the process.
• Feel confident that the organisation will take their complaint seriously and that it will not affect the support/services they receive.
• Understand their concerns will be investigated and when and how they will be informed about the outcome of that investigation.
• Receive a timely response that addresses and takes account of their concerns transparently and comprehensively.
• Trust that Step One will take appropriate action to learn from complaints and where possible, to prevent issues recurring.

3.2       All people who use our services should be provided with information so that they know how to raise a concern or complaint, as set out in Step One’s ‘Tell us what you think – How to make a comment, suggestion or complaint’ leaflet.

3.3       A person can make a complaint in writing (letter or email) or verbally (by phone or face-to-face). If the person raises their complaint verbally, the staff member should make a written record, and provide this to the complainant.

3.4       Managers and colleagues dealing with complaints should treat complainants with compassion, sensitivity, dignity and respect at all times. Colleagues should address any cultural, religious, or other specific needs and make any reasonable adjustments required. Colleagues should provide information on appropriate advocacy services.

3.5       Colleagues should offer all complainants the opportunity to discuss their concerns, desired outcomes, how their complaint will be investigated, and when they will receive a response.

3.6       A thorough investigation should be carried out for all complaints to understand what has happened and if possible, the reasons why.

3.7       The person investigating should acknowledge the complaint within 3 working days. The organisation will aim to respond within 20 working days. This may be extended in exceptional circumstances, e.g., due to the complexity of the complaint, the number of issues involved, annual leave, and any other factors which may affect the length of time that it will take to investigate and respond to the complaint. Step One should have provided a full response to all complaints within 40 working days.

3.8       The person investigating the complaint will agree with the complainant how they would like us to share the findings of the investigation with them. The investigator will inform the complainant of any delay in responding to their complaint, the reasons for this, and the progress of the investigation.

3.9       Step One will provide evidence-based responses which address complaints openly, honestly, and comprehensively, and take account of the complainant’s views. Any written communication should be clear, using language that is easy to understand.

3.10     Step One will acknowledge if mistakes have been made and offer a full apology. The organisation will explain any action taken to put things right and to try to prevent the same thing from happening again. In the response, we will tell the complainant how they can progress their complaint if they remain dissatisfied.

3.11     Managers will monitor and follow up actions arising from complaints, maintaining all relevant information, evidence, and documentation, and ensuring that it adequately reflects action taken and outcomes of learning.

3.12     Colleagues who are the subject of a complaint will be offered support, for example, through the Employee Assistance Programme.

4. Unreasonable Complaint Behaviour Procedure 

4.1       There may be a point reached where nothing further can reasonably be done to assist the complainant or to solve their problem. This procedure is to enable colleagues to identify when this point has been reached and clarify the actions to be taken when situations like this arise.

4.2       If a colleague thinks they are dealing with a complainant who is acting unreasonably, they should inform the Governance and Assurance Manager immediately. In such circumstances, colleagues should keep a documented record of all contacts with the complainant to support any decisions made about a complainant acting unreasonably and to demonstrate the ‘excessive’ nature of the contact.

4.3       The decision to invoke this procedure rests solely with the Chief Executive Officer who must be satisfied that every effort has been made to answer the complaint appropriately and the complainant is exhibiting one or more of the following:

• Acting in an abusive, aggressive, threatening, or irrational manner.
• Rejecting accurate documented evidence.
• Refusing to define a complaint that can be investigated.
• Continuing to evolve the content of the complaint to prolong the complaint unreasonably.
• Displaying unreasonable demands or expectations and failing to accept these may be unreasonable, e.g. insisting on immediate responses from senior staff when they are not available.
• Using threats and unreasonable behaviour such as involving the media to ‘short-circuit’ the agreed complaints procedure.
• Pursuing excessive and unreasonable levels of contact with staff.
• Having an unreasonable expectation about what can be achieved through the complaints process.

4.4       Following agreement to invoke this procedure the Governance & Assurance Manager will write to the complainant highlighting their unreasonable behaviour and state that no further correspondence will be entered into unless they raise a new issue or provide new information.

5. Monitoring

5.1       The Governance and Assurance Manager will monitor all concerns and complaints raised and the implementation of this policy through reviewing the complaints log, investigation reports, response letters and action plans.

5.2       Complaints, learning from complaints, and the operations of this concerns and complaints policy and procedures sit within the Quality Assurance Framework. The Quality Assurance and Improvement Committee is responsible for overseeing complaints made about Step One services.

6. Equality Statement

6.1       This policy and procedure has been assessed to ensure that, if applied consistently, it would not disproportionately affect any of the groups with protected characteristics: age, civil partnership and same-sex marriage, disability, gender, gender re-assignment, marriage, pregnancy and maternity, race, religion or belief, or sexual orientation.

6.2       The organisation will consider reasonable adjustments throughout the policy at the request of the person raising a concern or complaint. Step One recognises the Equality Act 2010 and the duties to foster inclusion, eliminate discrimination and advance equality of opportunity.

7. Policy Review 

7.1       This Policy will be reviewed every 2 years unless there is a change in law or company policy / guidance which may result in earlier changes.