Customer complaints management – Internal review procedure

Audience

Department-wide

Purpose

This procedure outlines the responsibilities and processes for internally reviewing a customer complaint.

Overview

A complainant may request an internal review if they are dissatisfied with the outcome of their customer complaint and/or the way their customer complaint was handled by the Department of Education (the department). An internal review establishes if the customer complaint management process for the original complaint was appropriate and/or whether the outcome reached was reasonable.

This procedure should be read in conjunction with the:

• Customer complaints management framework and policy
• Managing unreasonable complainant conduct procedure

Responsibilities

Complainant

• cooperate in a respectful way and understand that unreasonable conduct will not be tolerated
• request an internal review within 28 days of receiving the complaint outcome
• understand that an internal review is not a re-investigation of the original customer complaint
• provide a clear idea of the problem with the complaint outcome or handling and the desired solution, and understand that the internal review request may not be examined if this does not occur
• provide all relevant information when requesting the internal review
• understand that complex internal reviews can take time to assess, manage and resolve
• understand that some decisions cannot be overturned or changed using the Customer complaints management framework
• inform the department of changes affecting the internal review, including if help is no longer required.

Original complaints officer (school, region or central office division)

• cooperate with the internal review, including providing any relevant material to the internal review officer
• ensure they do not conduct the internal review if they were involved in the original customer complaint.

Internal review officer (region or central office division)

• ensure they were not involved in managing the original customer complaint
• ensure they are in a position equal to, or higher than, the original decision maker and are authorised to make internal review decisions (including recommendations), or are nominated by such a person
• ensure they have completed appropriate departmental or other internal review training
• provide procedural fairness to complainants and persons the subject of the internal review
• consider human rights when undertaking an internal review
• advise the complainant and original complaints officer of the outcome of the internal review process
• advise the complainant that they can seek an external review if they remain dissatisfied after the internal review is conducted
• use the register to maintain appropriate records to support each step in the internal review process and enable departmental reporting.

Process

The following process does not apply:

• to customer complaints managed outside the department through an external review (e.g. a complaint to the Queensland Ombudsman or Queensland Human Rights Commission)
• to complaints that are not customer complaints, as defined under the Customer complaints management framework and Excluded complaints factsheet
• if the department has already internally reviewed the customer complaint under the framework
• if the complainant is simply seeking clarification or explanation about the original decision or process. In these cases, the complainant should be referred back to the original complaints officer.

Image 1 Internal review process flowchart

1. Internal review request

• A complainant who is dissatisfied with the outcome of their customer complaint and/or the way the complaint was handled can request an internal review by submitting the Request for internal review form or lodging the request over the phone.
  • If the request is about a complaint managed at a school, the request should be lodged with the regional office. Otherwise, the request should be lodged with the area that completed the original complaint.
  • The request must explain why an internal review is appropriate (i.e. why the original decision was unreasonable or the complaint handling process was unfair or deficient) and what action the complainant would like taken to resolve the issue. If insufficient information is provided, the internal review request may be declined.
  • If the request is taken over the phone, the complainant should be asked to confirm the information captured by the department before the internal review commences.
• The complainant should lodge the request within 28 days of receiving the original complaint outcome.
  • The internal review officer will consider requests lodged after this period on a case-by-case basis. These requests may be actioned if the:
    • complainant can provide a reasonable explanation for lodging a late request; or
    • internal review officer otherwise considers the request can be productively resolved despite the delay.
• The internal review officer will review the complainant’s request to ensure sufficient information has been provided to enable the internal review to be undertaken.
  • The internal review officer should contact the complainant if additional information is required, or the review issues need to be confirmed, or to provide information about the internal review process.
  • If the complainant does not outline the grounds of review or provides insufficient information, the internal review officer may advise the complainant that the internal review request will not be examined unless this information is provided. If the complainant does not cooperate, the remainder of this procedure does not need to be followed and the internal review is closed. 
  • If the internal review request is frivolous or vexatious, the internal review officer should advise the complainant that the internal review will not be conducted. The remainder of this procedure does not need to be followed and the internal review is closed.
  • Any decision not to proceed with an internal review request must be recorded in the register or department’s records management system.
  • If the complainant’s request raises new customer complaint issue(s), the internal review officer must tell the complainant the issue is out of scope for the internal review, but can be lodged by the complainant as a new customer complaint.
• The internal review officer will open the original complaint in the register and record the internal review request. Protected information must not be entered into the register.
• Refer to the Information security procedure for information security classifications.
• The internal review officer must provide an acknowledgement to the complainant that the request has been received. This can be provided in writing or verbally.
• The internal review officer should consider if any health, safety or resourcing issues are raised by the internal review request or the complainant’s conduct, and if they are concerned they should escalate to a manager to determine any action to take.

2. Assess and resolve

• The internal review officer must analyse the original customer complaint to determine if the customer complaints management process and/or the outcome reached was appropriate by considering and assessing:
  • information provided with the internal review request
  • material considered as part of managing the original customer complaint
  • other information provided by relevant parties, such as the original complaints officer or complainant.
• Subject to the complexity of the request, the internal review officer must aim to resolve the internal review within 45 days of receiving the internal review request.
  • The internal review officer should keep the complainant informed of any changes or emergent issues that will impact the resolution of the internal review, including a revised finalisation date if more time is required.
• Procedural fairness must be afforded to a person who is the subject of the internal review and the complainant.
• Based on the assessment undertaken, the internal review officer should identify a suitable internal review outcome. This may include, but is not limited to:
  • finding the original decision was appropriate and the complaint does not merit further investigation
  • finding the original decision was unreasonable and should be amended without further investigation
  • re-opening the original matter
  • providing a clearer explanation of the original decision to the complainant
  • amending a policy, procedure or practice, or recommending that such documents be amended
  • offering an apology or some other remedy; or
  • providing further assistance to address a service delivery complaint.
• The internal review officer must prepare an Internal review outcome report (DoE employees only) and save this in the register and/or the department’s records management system.
• The internal review officer must record appropriate notes in the register throughout the internal review.

3. Communicate outcome

• The internal review officer must advise the complainant in writing about the outcome of the internal review process. This should include:
  • a clear explanation of the final decision
  • any recommendations; and
  • any external review mechanisms available to the complainant.
• The internal review officer must also inform the original complaints officer about the outcome of the internal review.
• The internal review officer must ensure they keep appropriate records about the information provided to the complainant and original complaints officer. This should be stored in the register and/or the department’s records management system.

4. Close internal review

• The internal review officer will close the internal review and record information in the register about the internal review outcome and any further activities that need to occur.
• If further action is recommended, the internal review officer is responsible for implementing and monitoring the recommended action, or referring the matter to the responsible area for attention.

Definitions

Legislation

• Public Service Act 2008 (Qld) section 219A

Delegations/Authorisations

• Nil

Other resources

• Customer complaints management framework
• Enterprise risk management
• Enterprise risk management framework
• Managing employee complaints
• Early childhood education and care complaints management
• Managing employee complaints
• Education Queensland International – Complaints and appeals
• Enterprise risk management
• AS/NZS ISO 10002:2014 – Guideline for complaint management in organisations
• Guide: Customer complaints management and human rights
• Compliments, suggestions and customer complaints
• Customer complaints management (DoE employees only)
• Internal review outcome report template (DoE employees only)
• Internal review letter template (DoE employees only)
• Making a customer complaint – Information for parents and carers
• Internal and external review – CCMS guide (DoE employees only)
• Complaints lifecycle guide – CCMS guide (DoE employees only)

Superseded versions

Previous seven years shown. Minor version updates not included.

1.0 Customer complaints management - Internal review