Complaints policy
How we handle customer complaints and informal concerns
March 2024
Contents
2. Accountability, roles and responsibilities
5. Timescale for making a complaint
6. Complaints and other procedures
7. Confidentiality of complaints
9. Complaints involving multiple service areas or organisations
10. Monitoring, demonstrating learning and data recording
11. Complaints about a contractor for our services
1. Introduction
1.1 Co-developed with UK Central Government (UKCG) Departments, other public bodies, advice and advocacy groups, the UKCG Complaint Standards provide a single vision of good practice for complaint handling. This model of complaint handling procedure describes how we will put into practice the core expectations given in the Standards.
1.2 This procedure sets out how we handle complaints and informal concerns raised by customers or stakeholders and the standards we will follow. This procedure also follows the relevant requirements as given in central government guidance including: ‘Managing Public Money’, ‘The Public Value Framework’, ‘Delivering Better Outcomes for Citizens’ and ‘Corporate Governance in Central Government Departments’.
1.3 The Complaint Standards and this procedure also supports the delivery of our Customer Charter where we set out our aim to be Reliable, Responsive, build great Relationships and be Easy to Work with.
2. Accountability, roles and responsibilities
2.1 Overall responsibility and accountability for the management of complaints lies with the Director of Customer Relationships and Strategy.
2.2 We have processes in place to ensure that our senior leaders regularly review insight from the complaints we receive, alongside other forms of feedback on our service. They will make sure action is taken on learning arising from complaints so that improvements are made to our service.
2.3 Our senior leaders demonstrate this by:
- leading by example to improve the way we deal with compliments, feedback and complaints
- understanding the obstacles customers or stakeholders face when making a complaint to us and taking action to improve the experience by removing them
- making information available in a format that customers or stakeholders find easy to understand
- where available, promoting information about any internal or external support for customers who complain to us, including relevant independent help, advice and advocacy services
- making sure we listen and learn from complaints and improve services when something goes wrong
Complaints management, roles and responsibilities
2.4 When a complaint is received, there are a number of people who may be involved within the process. Their roles and responsibilities are set out below:
- Director of Customer Relationships and Strategy – accountable for the overall complaints’ strategy and policy. They will also oversee any complaints which are due to take longer than 6 months
- Head of Customer Journey – responsible for the overall complaints processes, policy and provides insight to leadership teams on complaints themes, lessons learned and process statistics to drive a learning culture
- Case Manager – a designated person within the organisation who will conduct the investigation and communicate the outcome both internally and to the customer
- Account Manager – will have visibility of the progress of the complaint investigation (if they are not assigned as the Case Manager) and are able to provide updates to the customer on request or during normal business meetings
- Subject Matter Experts – individuals or teams who support the investigation if the Case Manager believes they need support identifying technical issues or root causes
- Executive Director – may be appointed to review and lead a complaint investigation if the outcome is dissatisfactory and a review is requested
- Sector Lead – two senior roles in the organisation (who all account managers report to), they are split by customer sector and are the primary channel for all formal complaints
3. Identifying a complaint
Everyday conversations with our customers and stakeholders
3.1 Our colleagues interact with customers and stakeholders who use or manage the use of our services every day. This can often raise issues, questions and worries that colleagues can help with immediately. We encourage customers and stakeholders to discuss any issues they have with our colleagues, as we may be able to sort the issue out to their satisfaction quickly and without the need for them to make a complaint. We will refer to these throughout the rest of this document as ‘informal concerns’.
When people want to make a complaint
3.2 We recognise that we cannot always resolve issues as they arise and that sometimes our customers or stakeholders will want to make a complaint. The UKCG Complaint Standards define a complaint as: an expression of dissatisfaction, either spoken or written, that requires a response. It can be about:
- an act, omission or decision we have made
- the standard of service we have provided
It does not include dissatisfaction with a decision which has a right of appeal, reference or review by tribunal or court of law.
3.3 All complaints that we receive from our customers and stakeholders, via any source, including via a Member of Parliament, will be routed through the same channels (detailed below) and will be dealt with under this procedure.
Feedback and complaints
3.3 People may want to provide us with feedback instead of making a complaint. Feedback can be an expression of dissatisfaction (as well as positive feedback), but it is normally given without the person wanting to receive a response or make a complaint.
3.4 As an organisation which has a many-to-many relationship with its customers and stakeholders it can be difficult due to the nature of those close working relationships to determine whether issues raised should be dealt with as a complaint, or as an informal concern.
3.5 Whilst people do not have to use the term ‘complaint’. We will use the language chosen by the customer, stakeholder, or their representative, when they describe the issues they raise (for example, ‘issue’, ‘concern’, ‘complaint’, ‘tell you about’). However, we will ask that formal complaints are only raised through the channels set out below.
3.6 If we consider that a complaint (or any part of it) raised through the channels below does not fall under this procedure we will explain the reasons for this. We will do this in writing to the customer or stakeholder raising the complaint and provide any relevant explanation and signposting information.
3.7 Formal complaints will only be considered if they are made to us:
- by email to your Sector Lead
- by email through this mailbox: ResolutionHub@fcdo.gov.uk
- All UK NACE formal complaints should be directed to the email address above
3.8 For issues raised through other channels, we will always speak to people to understand the concerns they raise and whether they would like us to consider them a formal complaint, in which case we will forward those to the correct channels on their behalf.
3.9 We will consider all accessibility and reasonable adjustment requirements of people who wish to make a complaint in an alternative way. We will record any reasonable adjustments we make.
3.10 We will acknowledge complaints within a maximum of 3 working days of receiving them. This can be done in writing, electronically or verbally.
4. Who can make a complaint
4.1 Any customer or stakeholder may make a complaint to us if they have purchased, received or are receiving services from our organisation. Stakeholders could include individuals or groups who are not in direct receipt of our services but are affected or likely to be affected by any action, inaction or decision by our organisation.
4.2 If the customer or stakeholder making the complaint does not wish to deal with the complaint themselves, they can appoint a representative to raise the complaint on their behalf. There is no restriction on who may represent them. However, the stakeholder will need to provide us with their consent for the representative to raise and discuss the complaint with us and to see any relevant information.
4.3 If the person affected has died, is a child or is otherwise unable to complain because of physical or mental incapacity, then the complaint may be made on their behalf by a representative. There is no restriction on who may act as a representative but there may be restrictions on the type of information we can share with them. We will explain this when we first look at the complaint.
4.4 If at any time we see that a representative is not acting in the best interests of the customer or stakeholder affected we will assess whether we should stop our consideration of the complaint. If we do this, we will share our reasons with the representative in writing. In such circumstances we will tell the representative that they can refer the matter to the Parliamentary and Health Ombudsman if they are unhappy with our decision.
5. Timescale for making a complaint
5.1 Complaints should be made to us as soon as possible after the events complained about. This should be no later than 12 months after the date the matter being complained about happened or the date the customer or stakeholder raising the complaint found out about it, whichever is the later date.
5.2 If a complaint is made to us after that 12-month deadline we will consider it if:
- we believe there were good reasons for not making the complaint before the deadline, and
- it is still possible to properly consider the complaint
5.3 If we do not see a good reason for the delay, or we think it is not possible to properly consider the complaint (or any part of it) we will write to the customer or stakeholder making the complaint to explain this. We will also explain that, if they are dissatisfied with that decision, they can complain about it in the same way as set out later in this policy for requesting a review of the outcome of a complaint.
6. Complaints and other procedures
6.1 We make sure our colleagues are properly trained to identify when it may not be possible to achieve a relevant outcome through the complaint process alone. Where this happens, colleagues will tell the customer or stakeholder making the complaint and give them appropriate information about any other process that may help to address the issues and could provide the outcomes sought.
6.2 This can happen at any stage in the complaint handling process and may include identifying issues that could or should (by way of example):
- trigger disciplinary procedures
- trigger a police investigation
- involve any aspect of the Investigatory Powers Act 2016
- involve a referral to a tribunal or court of law
6.3 When another process may be better suited, we will provide clear information about the options available to the customer or stakeholder raising the complaint. We will make sure they understand why this is relevant and, if available and appropriate, we will advise them to seek specialist independent advice.
6.4 This will not prevent us from continuing to investigate any aspects of the complaint that fall under this procedure. Where possible, we will make sure that the customer or stakeholder raising the complaint gets a complete and holistic response to all the issues raised, which includes any relevant outcomes where appropriate. We will engage with other colleagues or organisations who can provide us with advice and support on the best way to do this.
6.5 If a customer or stakeholder is already taking part or chooses to take part in another process but wishes to continue with their complaint as well, this will not affect the investigation and response to the complaint. The only exceptions to this are if:
- the customer or stakeholder requests or agrees to a delay, or
- there is a formal request for a pause in the complaint process from the police, Investigatory Powers Commission or a judge
In such cases the complaint investigation will be put on hold until those processes conclude.
6.6 If we consider that a colleague should be subject to disciplinary procedures, we will advise the customer or stakeholder raising the complaint where it is appropriate to do so. We will share as much information with them as we can whilst complying with relevant data protection legislation.
6.7 Where a Memorandum of Understanding (MoU), Terms of Business arrangement (ToBA) or another agreement sets out a Dispute Resolution or Dispute Escalation process, this refers to the inability to reach a satisfactory outcome to a complaint or escalation of an informal concern through this Complaint Policy, which should be followed first before a dispute approach is pursued.
6.8 In the unlikely case that a MoU, ToBA, an agreement or an engagement document set out an alternative process for resolving issues or concerns prior to a Dispute Resolution or Dispute Escalation, the customer or stakeholder has the right to choose the process they would like to follow – that set out in those documents or this Complaints Policy. We will approach either methodology with a mindset to resolve issues effectively and professionally.
7. Confidentiality of complaints
7.1 We will maintain confidentiality and protect privacy throughout the complaints process in accordance with UK General Data Protection Regulations and the Data Protection Act 2018. We will only collect and disclose information to those colleagues who are involved in the consideration of the complaint or are an active contributor to management of the account.
7.2 Complaint outcomes may be anonymised and shared within our organisation to promote service improvement, unless we have specifically asked (and been given) the permission of those who will be named.
8. How we handle complaints
Making sure customers and stakeholders know how to complain and where to get support
8.1 We publish clear information about our complaints process and how customers and stakeholders can get help, advice and support with their complaint on our website and the FCDO Intranet. Your Account Manager or the Customer Insight team (who are independent from complaint investigations) can also provide help if required. You can contact the Customer Insight Team by emailing FCDOServices.ResolutionHub@fcdo.gov.uk.
8.2 We will make sure that everybody who uses (or is impacted by) our services (and those that represent them) know how they can make a complaint by having our complaints procedure and/or materials that promote our procedure on this website and the FCDO Intranet.
8.3 We will make sure that the ongoing service for anyone making a complaint will not be affected because they have made a complaint.
What we do when we receive a complaint or informal concern
8.4 We want all customers and stakeholders to have a good experience while they use our services. If somebody feels that the service received has not met our standards, we encourage them, in the first instance, to talk to the relevant delivery colleague or their account manager to see if we can resolve the issue promptly.
8.5 We want to make sure we can resolve issues quickly as often as possible. To do that, we train colleagues to proactively respond to customers and stakeholders and their representatives and support them to deal with any issues raised at our first point of contact where possible.
8.6 Colleagues who have contact with customers or stakeholders (or those that support them) will handle issues in a sensitive and empathetic way. Colleagues will make sure customers and stakeholders are listened to, get an answer to the issues quickly wherever possible, usually within a matter of days, and any learning is captured and acted on.
Our colleagues will:
- Listen to the customer or stakeholder to make sure they understand the issue(s), how they have been affected and what they would like to happen to put things right
- Resolve the complaint by identifying the corrective actions to prevent it from happening again and put it right. Then carry out these actions themselves if they can (or with the support of others)
- Communicate back formally the outcome of the investigation and the resolution actions that have either been done or are due to be completed. Where it is not possible to carry out the actions, we will explain why we can’t do this and explain what is possible. We will also share with colleagues the lessons that have been learned to improve services for others
8.7 Where a formal complaint has been raised through the channels previously identified, a Case Manager will be assigned to look after the process from end-to-end and will be in touch with the customer or stakeholder to introduce themselves within 3 working days. Where this is not possible, the Account Manager or the Customer Insight team will act on their behalf in the interim period.
8.8 Formal complaints follow the exact same process as informal concerns as set out in 8.6 above, with an additional fourth stage (between Listen and Resolve):
- Investigate the issue to understand the root cause
For all formal complaints we will look to identify the root cause to prevent the issue from happening again for the same, or other customers and stakeholders.
8.9 Where there are concerns over the handling of an informal concern (for example it is taking too long, the resolution is not satisfactory) the customer or stakeholder can escalate that issue and it will then follow the formal complaint process. This however will mean that a Case Manager will be assigned and they will go back to the start to ensure all the relevant information is captured. As a result, the timescales may be longer than how we resolve informal concerns.
8.10 An informal concern can be escalated through the following:
- In a formal operational board meeting
- By email to the relevant sector lead or the Resolution Hub mailbox (see 3.7)
Focus on early resolution of informal concerns
8.11 Our colleagues often handle informal concerns that can be resolved quickly at the time they are raised, or very soon after. We encourage colleagues to do this as often as possible so that people get a quick and effective answer to their issues.
8.12 We will acknowledge the issue (either verbally or in writing / email) within a maximum of 3 working days.
8.13 When we receive an informal concern, we are committed to making sure it is addressed and resolved at the earliest opportunity.
8.14 When a colleague believes that an early resolution may be possible, they are authorised to take action to address and resolve the issues raised and put things right for the customer or stakeholder raising them. This may mean giving a quick explanation or apology themselves or making sure a colleague who is more informed of the issues does. Colleagues will resolve informal concerns in person, by video calling software such as Microsoft Teams or by telephone wherever possible.
If we can resolve an informal concern
8.15 If we can answer or address the complaint, and the customer or stakeholder raising the informal concern is satisfied that this resolves the issues, colleagues have the authority to provide a response on our behalf. This will often be done in person, over the telephone, Microsoft Teams or in writing (by email or letter) in line with the individual circumstances.
8.16 We will only capture a summary of the informal concern and how we resolved it if this becomes escalated. This ensures we can remain agile and resolve informal concerns quickly without unnecessary red tape and bureaucracy.
If we are not able to resolve an informal concern
8.17 If we are unable to find an appropriate way to resolve the informal concern to the satisfaction of the person making it, we will explain to the person how they can progress their concerns by escalating them as described in 8.10.
A closer look into formal complaints
8.18 It may not be possible to resolve formal complaints quickly and sometimes we will require a longer period of time to carry out a closer look into the issues and carry out a detailed and fair investigation of the issues to determine what happened and what should have happened.
8.19 We will make sure colleagues involved in carrying out this work are properly trained to do so. We will also make sure they have:
- the appropriate level of authority and autonomy to carry out a fair investigation
- the right resources, support and time in place to carry out the investigation, according to the work involved in each case
8.20 Where possible, complaints will be looked at by someone who was not directly involved in the matters complained about. If this is not possible, we will explain to the person making the complaint the reasons why it was assigned to that person or team. This should address any perceived conflict of interest.
Clarifying the complaint and explaining the process
8.21 The colleague dealing with the complaint will:
- engage with the customer, stakeholder or representative raising the complaint (preferably in a face-to-face meeting or by telephone) to make sure they fully understand and agree:
- the key issues to be looked at
- how the customer or stakeholder has been affected
- the outcomes they seek
- make sure that any colleagues specifically complained about are made aware at the earliest opportunity (see ‘Support for colleagues’)
- share a realistic timescale for how long the investigation will take with the customer or stakeholder raising the complaint, depending on:
- the content and complexity of the complaint
- the work that is likely to be involved
- agree how they will keep the customer or stakeholder (and any colleague specifically complained about) regularly informed and engaged throughout
- explain how they will carry out the closer look into the complaint, including:
- what evidence they will seek out and consider
- who they will speak to
- how they will decide if something has gone wrong or not
- who will be responsible for the final response
- how the response will be communicated
Carrying out the investigation
8.22 Colleagues who carry out investigations will give a clear and balanced explanation of what happened and what should have happened. They will reference relevant legislation, standards, policies, procedures and guidance to clearly identify if something has gone wrong.
8.23 They will make sure the investigation clearly addresses all the issues raised. This includes obtaining evidence from the customer or stakeholder raising the complaint and from any colleagues involved.
8.24 We will complete our investigation within the timescale shared with the customer or stakeholder at the start of the investigation. Should circumstances change we will:
- notify the customer or stakeholder raising the complaint (and any colleagues specifically subject to the complaint) immediately
- explain the reasons for the delay
- provide a new target timescale for completion
8.25 If we cannot conclude the investigation and issue a final response within 6 months (unless we have agreed a longer timescale with the customer or stakeholder raising the complaint within the first 6 months) our Director of Customer Relationships and Strategy will write to the customer or stakeholder to explain the reasons for the delay and the likely timescale for completion. They will then maintain oversight of the case until it is completed, and a final written response is issued.
8.26 Before sending a final written response to the complaint, we will consider sharing and discussing (by telephone, in a meeting or in writing) the outcome of our investigation and the actions we intend to take, with key parties to the complaint. This will be decided on a case-by-case basis and will be based on the complexity of the issues and the identified impact. We will always consider any comments we receive before coming to a final decision and issuing a final written response.
Providing a remedy
8.27 If, following the investigation, the colleague carrying out the investigation identifies that something has gone wrong they will seek to establish what impact the failing has had on the customer or stakeholder concerned. Where possible, they will put that right for the customer or stakeholder and any other customers or stakeholders who have been similarly affected. If it is not possible to put the matter right, they will decide, in discussion with the customers or stakeholders and relevant colleagues, what action can be taken to remedy the impact.
8.28 In order to put things right, the following remedies may be appropriate:
- An acknowledgement, explanation and a meaningful apology for the error
- Reconsideration of a previous decision
- Expediting an action
- Waiving (or recompensing) a fee or penalty
- Issuing a payment or refund
- Changing policies, procedures, guidance or training to prevent the same mistake(s) happening again and to improve our service for others
The final written response
8.29 As soon as practical after the investigation is finished, the person carrying out the investigation will co-ordinate a written response. They will send this to the customer or stakeholder and any other relevant parties. The response will include:
- a reminder of the issues investigated and the outcome sought
- an explanation of how we investigated the complaint
- the relevant evidence we considered
- what the outcome is
- an explanation of whether or not something went wrong that sets out what happened compared to what should have happened, with reference to relevant legislation, standards, policies, procedures and guidance
- if something went wrong, an explanation of the impact it had
- an explanation of how that impact will be remedied for the individual
- a meaningful apology for any failings
- an explanation of any wider learning we have acted on / will act on to improve our service for other users
- an explanation of how we will keep the customer or stakeholder involved and updated on how we are taking forward all systemic learning or improvements relevant to their complaint
- confirmation that we have reached the end of our complaint procedure
- details of how to escalate the complaint to the next stage if the customer or stakeholder is not satisfied with our final response by a formal operations board or other routes
Support for colleagues
8.30 We will make sure all colleagues who look at complaints have the appropriate training, resources, support and time to respond to and investigate complaints effectively. This includes how to manage challenging conversations and behaviour.
8.31 We will make sure colleagues who are specifically complained about are made aware of the complaint and we will give them advice on how they can get support from within our organisation, and externally if required.
8.32 We will make sure colleagues who are specifically complained about can give their views on the events and respond to emerging information. Colleagues will act openly and transparently and with empathy when discussing these issues.
8.33 The person carrying out the investigation will keep any colleague specifically complained about updated. These colleagues will also have an opportunity to see how their comments are used before the final response is issued.
Requests for review and dispute resolution
8.34 In our final response to every complaint, we will clearly inform the person who has raised the complaint that if they are not happy with the outcome of our investigation, the options that are available to them to continue their formal complaint or escalation of informal concern.
8.35 The options for customers or stakeholders to continue their formal complaint or escalation of informal concern depend on the nature of the complaint and whether it is within the scope of a formal agreement (such as a MoU, ToBA, etc.):
- Where a Dispute Resolution or Dispute Escalation process is set out in a formal agreement and the nature of the complaint is a potential breach of that agreement, then the customer or stakeholder may choose either to follow that Dispute approach set out, or to continue with a Complaint Review (set out below)
- Where there is no Dispute Resolution, Dispute Escalation or the nature of the complaint is not related to the agreement, the Complaint Review is the only option for the customer or stakeholder
8.36 To request a Complaint Review, the customer or stakeholder should write by email to the relevant sector lead or the Resolution Hub mailbox (see 3.7) explaining why they think our decision is wrong, and provide us with any supporting or new evidence.
8.37 If we identify that further work is required to address the complaint we will assign an Executive Director to review the complaint and our decision. In our final response to the review request, we will clearly inform the person who has raised the complaint that if they are not happy with the outcome of our review, they can refer the matter to the Parliamentary and Health Ombudsman.
Referral to the Ombudsman
8.38 In our final response following a Complaint Review, we will clearly inform the customer or stakeholder who has raised the complaint that if they are not happy with the outcome of our investigation, they can refer the matter to the Parliamentary and Health Service Ombudsman. We will explain that the Ombudsman service is free to use, and highlight that you can contact them by visiting their website at www.ombudsman.org.uk or by calling 0345 015 4033.
9. Complaints involving multiple service areas or organisations
9.1 If we receive a complaint that involves a number of service areas or another organisation(s), we will make sure that we investigate in collaboration where appropriate and possible. Colleagues for each service area or organisation will work together to deliver a co-ordinated and comprehensive response, and will ensure that any learning is captured to help us improve our services.
9.2 The colleague investigating for the main service area or organisation will be responsible for making sure the customer or stakeholder who raised the complaint is kept involved and updated throughout.
10. Monitoring, demonstrating learning and data recording
10.1 We expect all colleagues to identify what learning can be taken from complaints, regardless of whether mistakes are found or not.
10.2 Our senior leaders take an active interest and involvement in all sources of feedback and complaints, identifying what insight and learning will help improve our services for other users.
10.3 We maintain a record of:
- each complaint we receive
- the subject matter
- and outcome (including any learning we have identified)
10.4 We measure the overall performance of our complaints service (and our delivery of the UKCG Complaint Standards) by seeking feedback on our service from customers or stakeholders who have made a complaint, any representatives they may have, colleagues who have been specifically complained about and from colleagues who have carried out the investigation. This will be done on a twice-annual basis in our stakeholder survey.
10.5 We monitor all feedback and complaints over time, looking for trends and risks that may need to be addressed.
10.6 As soon as practical after the end of the financial year, we will produce and publish a report on our complaint handling. This report will include details of the learning we have identified and explain how complaints have led to a change and improvement in our services, policies or procedures.
11. Complaints about a contractor for our services
11.1 This complaint handling procedure applies to all of the services that FCDO Services provides to its customers and partners.
11.2 Where we outsource the provision of government services to a contractor we will work with the provider to support them and ensure that they follow these same complaint handling procedures.