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Customer complaints management – Internal review procedure

Version number 1.1 | Version effective 07 January 2020
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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:

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 shows a flowchart of the Internal review process, starting with a dissatisfied customer seeks an internal review. 1 Internal review request 2 Assess and resolve 3 Communicate outcome 4 Close internal review

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

Term

Definitions

Complainant

A person, organisation or their representative/advocate making a customer complaint.

A complainant is a ‘customer’ for the purposes of the customer complaints management framework if they are directly affected by the issue they are complaining about (e.g. a student complaining about something that has happened to them at school), or they are authorised representative of someone who has been directly affected (e.g. a parent complaining on behalf of their child).

Complaints officer

A complaints officer is a departmental employee who is involved in managing customer complaints. Complaints officers may work in schools, regions or divisions. Their functions may include, but are not limited to, intake, assessment, management, resolution, and data entry. The management of a customer complaint may involve one or more complaints officers.

Complaints requiring further action

A reporting status applied when the complaint is closed. This is used in departmental reporting. Customer complaints will require further action if the complaint:

  • is subject to internal review;
  • has resulted in changes to departmental policies, procedures or practices; or
  • is subject to an external review (e.g. by the Queensland Ombudsman or Queensland Human Rights Commission).

Complaints requiring no further action

A reporting status applied when the complaint is closed. This is used in departmental reporting. Customer complaints require no further action if the department has resolved/finalised the complaint at the point of service and there is no request for further action by the complainant or others (e.g. Queensland Ombudsman or Queensland Human Rights Commission).

Customer complaint

A customer complaint is defined in section 219(4) of the Public Service Act 2008 as a complaint about the service or action of a department, or its staff, by a person who is directly affected by the service or action. Examples may include complaints about:

  • a decision made, or failure to make a decision, by a departmental employee
  • an act, or failure to act, by the department
  • the formulation of a proposal or intention by the department
  • the making of a recommendation by the department
  • the customer service provided by a departmental employee.

Days

Depending on the nature of the complaint and the area managing the complaint, customer complaints will be managed within either working days (i.e. business days) or school days (i.e. days during the school term).

External review

A process conducted by an external review body (e.g. Queensland Ombudsman or Queensland Human Rights Commission) to ensure departmental decision-making is fair, reasonable and proper.

Frivolous complaint

A frivolous complaint is one that is trivial or meritless in nature, and does not justify the resources that would be required to action it.

Internal review

A process conducted by appropriately trained departmental staff on request from the complainant which examines if the complaint management process for the original customer complaint was appropriate and/or if the outcome reached was reasonable. An internal review is not a re-investigation of the original customer complaint.

Internal review officer

An internal review officer is a departmental employee who conducts an internal review. The officer must be:

  • independent from the original customer complaint; and
  • in a position equal to, or higher than, the original decision-maker and authorised to make internal review decisions (including recommendations), or nominated by such a person.

Internal review officers will be regional or divisional staff. An internal review may involve more than one internal review officer.  

Involved in managing the original customer complaint

To ensure independence, an internal review officer must not have been involved in managing the original customer complaint. Examples of ‘involvement’ include:

  • providing advice on how the original customer complaint should be handled or complaint findings
  • gathering information or evidence, or conducting interviews
  • providing a complaint outcome.

If an internal review officer has general awareness of a customer complaint, this does not constitute being ‘involved’ in the original complaint handling process. In these situations, the internal review officer can undertake the internal review without compromising the independence of the process. Examples of general awareness include:

  • overhearing staff talking about the customer complaint
  • taking a phone message about the complaint
  • reading a file note
  • briefly discussing a complaint (e.g. at a team meeting).

Procedural fairness

Providing any party who may be affected by an internal review with a fair hearing and a reasonable opportunity to respond to any claims. Procedural fairness is also known as natural justice.

Protected information

Very sensitive and confidential information, where unauthorised and/or premature disclosure might cause damage to one or more parties. Refer to the Information security procedure for more information.

Register

A tool used to capture and record customer complaints data, including information about the complainant, their complaint, how the department has resolved the matter, and any reviews undertaken.

The Customer Complaints Management System (CCMS) is the department’s enterprise system for recording, assessing, managing, resolving and reporting on customer complaints. The CCMS should be used as the register for regional and divisional customer complaints.

Schools can record complaints in a school system or use a local register.

Reporting status

An assessment of the customer complaint completed at the point of resolution which identifies if the complaint requires no further action, or requires further action.

Unreasonable complainant conduct

Conduct is likely to be unreasonable where it involves actions or behaviours which because of the nature or frequency, raises substantial health, safety, wellbeing, resource or equity issues for the department, its staff, other service users or the complainant themselves. Examples include:

unrelenting contact (e.g. excessive and unnecessary phone calls or emails) 

  • demanding conduct (e.g. demanding more reviews than departmental procedures allow, or demanding a different outcome without showing the original decision was incorrect)
  • unreasonable lack of cooperation (e.g. refusing to identify the issue of complaint or providing disorganised information)
  • unreasonable arguments (e.g. making irrational claims)
  • unreasonable behaviour (e.g. aggression or violence to staff, or threatening harm to self and others).

The Managing unreasonable complainant conduct procedure provides more information.

Vexatious complaint

A vexatious complaint is a complaint that is not brought in good faith, and is instead designed to harass, annoy, or create a resource burden for the department.

Legislation

Delegations/Authorisations

  • Nil

Other resources

Superseded versions

Previous seven years shown. Minor version updates not included.

1.0 Customer complaints management - Internal review

Review date

15 October 2022
Attribution CC BY

Policies and procedures in this group

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