Customer complaints management procedure

Audience

Department-wide

Purpose

This procedure outlines the responsibilities and processes for the consistent management of customer complaints across the Department of Education (the department).

Overview

A complaint is a customer complaint if it involves an expression of dissatisfaction about the service or action of the department, or its staff, and the complainant is directly affected by the service or action. Customer complaints are an opportunity to identify issues and take action to improve service delivery and customer experiences, and drive a culture of continuous improvement.

This procedure should be read in conjunction with the:

• Complaints and grievances management policy 
• Customer complaints management framework
• Internal review procedure
• Managing unreasonable complainant conduct procedure.

Not all complaints received by the department are customer complaints. Other complaints need to be managed in a different way. Refer to the department's Complaints and grievances management policy for additional information.

Some complaints or matters may meet the definition of a customer complaint but also engage other processes. If the matter meets the definition of a customer complaint it must be recorded as a customer complaint and included in departmental reporting. These complaint types include:

• complaints about harm, or risk of harm, to a student attending a state school which are dealt with in accordance with the Student protection procedure
• human rights complaints, if also a customer complaint, will be managed in accordance with this procedure
• privacy complaints, if also a customer complaint, will be managed under the Information privacy and right to information procedure.

Responsibilities

Complainant

• visit the department’s website for information about complaint processes or lodge a customer complaint with the school or education centre, region or division
• provide all relevant information including a clear idea of the problem and the desired solution
• cooperate in a respectful way and be aware that unreasonable conduct will not be tolerated
• understand that complex customer complaints can take time to assess, manage and resolve
• be aware that some decisions cannot be overturned or changed using the Customer complaints management framework
• inform the department of changes affecting the customer complaint, including if help is no longer required
• request an internal review within 20 days of receiving the outcome of the customer complaint if dissatisfied with the way the complaint was handled or if the outcome is unreasonable.

All staff involved in managing customer complaints (complaints officers)

• manage customer complaints according to this procedure and the department’s framework, policy, Internal review procedure and Managing unreasonable complainant conduct procedure
• direct customers to the department’s website if they are seeking information about making a customer complaint
• decide if a customer complaint is frivolous or vexatious
• assess if a customer complaint also engages another process, such as privacy complaints 
• consider human rights when responding to a customer complaint
• ensure confidentiality of personally identifiable information about the complainant or any other person involved in the complaint
• provide procedural fairness to complainants and persons who are the subject of the customer complaint
• keep an up-to-date customer complaint register
• resolve customer complaints promptly and in accordance with timeframes
• advise the complainant that they can seek an internal review within 20 days if they are dissatisfied with the way their customer complaint was handled or believe the outcome was unreasonable
• maintain appropriate records to support each step of the process and enable accurate departmental reporting
• participate in customer complaint management training and awareness activities.

Additional responsibilities for principals or deputy principals

• ensure information about how to make a customer complaint and how a complaint will be managed is available at the school or education centre (for example, information displayed in the reception or a school complaints process on the school or education centre website). School resources can be found here (DoE employees only). 
• escalate a request for an internal review to the regional office for management
• report to the regional director on customer complaints matters as required
• seek advice on complex matters and alternative dispute resolution (DoE employees only), as required.

Additional responsibilities for complaints officers in regional offices and central office divisions

• undertake internal reviews as an internal review officer in accordance with the Internal review procedure
• report to Strategy and Performance on customer complaints matters
• ensure information about how to make a customer complaint is available in the reception area
• review customer complaint information to inform improvements to service delivery.

Supervisors and managers

• provide support and advice to complaints officers and implement appropriate health, safety and wellbeing arrangements
• ensure staff are provided with initial and ongoing complaints management training and are empowered to resolve complaints.

Director-General

• publish annual customer complaints data on the department’s website by 30 September
• ensure a commitment to responding to and learning from complaints as part of the department's continual quality improvement.

Customer complaints coordinators, Strategy and Performance

• maintain customer complaints management resources
• provide system administration support for the Customer Complaints Management System (CCMS)
• manage quarterly and annual customer complaints and human rights reporting
• provide advice and guidance to staff involved in customer complaints management
• review customer complaints management activities to identify opportunities for better practice
• organise training to ensure staff understand the department’s customer complaints management approach and their responsibilities
• seek and action feedback about the customer complaints management approach from complainants and staff.

Process

The department’s approach to handling customer complaints is based on the Australian/New Zealand Standard (AS/NZS ISO 10002:2022 – Guidelines for complaint management in organisations).

Image 1 Process review flowchart

1. Early resolution

Receive complaint, record in register and provide acknowledgement

• The complainant will raise an issue with the department, either in writing, over the phone, or in person.
  • The complaints officer should provide any necessary assistance to the complainant, including assisting those who may be vulnerable due to factors such as age, disability, location or issues accessing digital services, and offer support such as directing the person to interpreter services or support agencies or supporting the complainant to document the complaint.
• The complaints officer must decide if the issue is a customer complaint.
  • It will be a customer complaint if all criteria below are met:
    •  the complainant is dissatisfied with the service or action of the department or its staff
    • the complainant is directly affected by the service or action; and
    • some outcome is sought.
  • It will not be a customer complaint if the customer is:
    • requesting more information
    • requesting a change in services or requesting a new service
    • making a suggestion for improving the department’s services
    • providing feedback on the department’s performance
    • not directly affected by the decision or action of the department
    • providing information (for example, reporting an incident).
• If the issue is a customer complaint, the complaints officer must record the customer complaint in the register. Protected information must not be entered into the register.
  • Refer to the Information security procedure for information security classifications.
• If the issue is not a customer complaint, it must still be actioned, but it will either be dealt with as standard correspondence or under a different complaints process as outlined in the department's Complaints and grievances management policy.
  • Complainants should be advised, as soon as practicable if the department is unable to deal with their complaint.
• The complaints officer must provide acknowledgement to the complainant that the complaint has been received and will be treated as a customer complaint, in writing or verbally, within 3 days (where possible) of the complaint being received by the department.
  • Include information about the complaint process, expected timelines and complainant responsibilities. 
• The complaints officer should consider if any health, safety, wellbeing or resourcing issues are raised by the complaint or the complainant’s conduct, and if they are concerned they should consider the Managing unreasonable complainant conduct procedure or escalate to a manager to determine any action to take.
• The complaints officer should assess if they have any conflicts of interest with regards to the complaint. If any conflict exists, it should be declared and the complaint referred to someone else.

Assess and resolve

• The complaints officer will consider if the customer complaint is frivolous or vexatious.
  • If not frivolous or vexatious, proceed through the following steps to assess and resolve the complaint.
  • If the complaint is frivolous or vexatious, the complaints officer should advise the complainant that the complaint will not be examined. This must be recorded in the register or department’s records management system. The remainder of this procedure does not need to be followed and the complaint is closed.
• The complaints officer must also decide if the complaint engages or limits human rights contained in Part 2 of the Human Rights Act 2019 (Qld) by considering the following questions:
  • Are any human rights engaged or impacted by the decision or action complained about?
  • If so, did the decision or action being complained about limit those human rights?
  • If so, was the limitation lawful, justified and reasonable in the circumstances?

The Guide: Customer complaints management and human rights provides more information about assessing if a customer complaint engages human rights. The complaints officer must document and save their assessment of human rights considerations(DoE employees only) in the department's records management system.

• Customer complaints should be assessed and resolved at the point of receipt, where possible. The complaints officer assesses the customer complaint and determines the best way to resolve it by:
  • considering the circumstances of the complaint, the parties involved, and the requested outcomes
  • identifying each complaint issue and who needs to resolve it
  • identifying relevant benchmarks, standards or criteria to assess the complaint against (for example, legislation, policies, or procedures); and
  • gathering relevant information or documentation, including from the complainant.
• The complaints officer will contact the complainant if additional information is required to confirm the complaint issues or the outcome sought, or to provide information about the customer complaints management process, such as timeframes and complainant responsibilities.
• The complaint officer will communicate with the complainant by the most appropriate medium, taking into consideration their needs and preferences where possible.
• The complaints officer will monitor and document any unreasonable conduct by the complainant and, if necessary, apply the Managing unreasonable complainant conduct procedure.
• The complaint officer will keep and store appropriate records of all communication with the complainant. This includes recording supporting documentation if a complainant withdraws their complaint.
• The complaints officer must aim to resolve:
  • the customer complaint within 30 days, where possible. If these timeframes cannot be met (e.g. due to school holidays for school-related complaints), the complaint officer should contact the complainant to advise them of a new expected timeframe and a contact officer.
  • complaints involving privacy or human rights issues - within 45 business days.
• The complaints officer should assess whether the urgency of the issues raised requires the complaint be completed in shorter timeframes than those outlined above. 
• When a complaint involves multiple organisations, or multiple areas of the department, where privacy and confidentiality obligations permit, communication with the complainant should be co-ordinated between all parties involved.
• Options for resolving the customer complaint should be tailored to the circumstances of the complaint and may include:
  • providing an explanation to the complainant about the decision, action, etc that is the subject of the complaint and reasons for the decision, if not previously provided
  • finding the customer complaint to be unsubstantiated (for example, the events did not happen as described)
  • reaching a compromise solution (for example, through alternative dispute resolution)
  • concluding the customer complaint be substantiated and implementing specific action, such as overturning a decision, apologising, or providing a service not previously provided
  • addressing or referring the issue for system improvement.
• The complaints officer must record appropriate notes in the register throughout the assessment and resolution phase.
• Procedural fairness must be afforded to a person who is the subject of the customer complaint and the complainant.

Communicate outcome

• The complaints officer must advise the complainant of the outcome of the assessment and resolution process, including:
  • a clear explanation of the final decision, including reasons
  • any recommendations, steps taken to address the complaint and undertakings or follow up actions
  • any internal or external review options available to the complainant
  • the option to provide feedback on the complaint process via the department's customer satisfaction survey.
• An outcome can be provided verbally, in writing (DoE employees only), or in any other form of communication most suitable to the complainant.
• The complaints officer should consider whether privacy obligations to a particular staff member or student impact the information that can be given to the complainant.
• The complaints officer must keep appropriate records about the information provided to the complainant in the register and/or department’s records management system.

Close complaint

• The complaints officer will close the complaint and record information in the register about the complaint outcome and any further activities that need to occur.
• If further activities are recommended, the complaints officer is responsible for implementing and monitoring the recommended action, or referring the matter to the responsible area for attention. The register should be updated once all outstanding actions are completed.

2. Internal review

• If the complainant is dissatisfied with the way the customer complaint was handled by the department or if they believe the outcome to be unreasonable, the complainant can request an internal review. This request should be submitted within 20 days of receiving the complaint outcome.
  • The internal review must be completed in accordance with the Internal review procedure.

3. External review

• If an internal review is completed, and the complainant remains dissatisfied, they can seek an external review.
• The complaints officer must provide the complainant with details of external review agencies (such as the Queensland Ombudsman, Office of the Information Commissioner or Queensland Human Rights Commission) to assist the complainant to seek an external review.
• If an external review agency accepts the request and requests information from the department to enable an external review to be conducted, the complaints or internal review officer must respond to the request and record the external review request in the register.

Definitions

Legislation

• Public Sector Act 2022 (Qld) section 264
• Education (General Provisions) Act 2006 (Qld) section 46
• Human Rights Act 2019 (Qld) part 2 and sections 58(1), 63, 97

Delegations/Authorisations

• Delegation of Director-General’s powers under Education (General Provisions) Act 2006 section 46

Other resources

• AS/NZS ISO 10002:2022 – Guideline for complaint management in organisations
• Queensland Public Service Customer Complaint Management Framework 
• Queensland Public Service Customer Complaint Management Guideline
• Compliments, suggestions and customer complaints 
• Customer complaints management (DoE employees only)
• Customer complaints outcome report template (DoE employees only)
• School complaints resources (DoE employees only)
• Child friendly complaint form
• Creating a child-friendly complaints process (DoE employees only)
• Request for internal review form
• Internal review information sheet
• Complaints lifecycle guide – CCMS guide (DoE employees only)

Superseded versions

Previous seven years shown. Minor version updates not included.

2.0 Customer complaints management

1.0 Customer complaints management