Supplementary memorandum from Dr Susan
Atkins, Service Complaints Commissioner
MANAGEMENT INFORMATION
(JPA)
Do you think the reduction of "super-users"
to restrict access to the JPA system records has remedied the
concerns of personnel having complaints "on the record"?
Answer: Last year the MoD and Services took
action to reduce the numbers of "super- users" who had
access to JPA records after I had highlighted concerns about widespread
access as a potential barrier to use of the service complaints
system. It hasn't been raised with me as an issue since.
Has the MoD agreed to include the recording
of general complaints, similar to those provided for Equality
and Diversity cases, on the JPA system in future?
Answer: Yes. A JPA service complaints module
is already in operation for non equality and diversity complaints,
although the DIA audit found its use to be imperfect and inconsistent.
Because of concerns about confidentiality, particularly from the
Navy, there is an agreement that equality and diversity complaints
will not have to be recorded on JPA until there is an equality
and diversity module. The MoD and the Services are developing
the general complaints module, in the light of the DIA findings,
and the equality and diversity module in tandem. I have asked
them to explore whether one module can be developed that meets
all concerns. The intention is that the new module(s) will provide
full information about all types of complaints and will be easy
to use.
ACCESSIBILITY AND
COMMUNICATION
Do you think there has been any complacency in
distributing information about your role within certain establishments?
Answer: Last year the MoD distributed the Joint
Service Publication 831 and an explanatory leaflet on the service
complaints system, both of which covered my role, as well as arranging
for a note about the SCC to be included on the pay packet of every
member of the Armed Forces and assisting me to distribute to Units
my leaflet on the Service Complaints Commissioner role. I do know
that attention has been drawn to the role by my visits- for example
soldiers have told me that leaflets went up on Notice boards the
day before I arrived.
Following the recommendations in my Annual report,
the Chief of Defence Staff is asking Service Chiefs to ensure
that information about my role is cascaded to all Service personnel
through the regular channels and attention drawn to the need to
ensure that any information, for example the new leaflet that
is designed for trainees and junior ranks, reaches its intended
audience.
What are the rules on media contact with a complainant
or those who are the subject of a complaint?
Answer: I treat any approach to my office as
confidential. I make it clear to the media that I do not and will
not talk about individual cases in the system. The case studies
included in my Annual Report had the consent of the complainant,
were based on completed cases and were anonymised.
As far as my role is concerned I make no requirements
on the complainant not to go to media. I cannot speak for any
requirements the Services may impose.
SERVICE COMPLAINTS
PANELS
In the event that a future SCP requires an independent
member, how is that person chosen?
Answer: In 2008 the MoD ran an open competition,
following which four independent members were appointed by the
Secretary of State. An Independent panel member is required for
any Service Complaints Panel hearing complaints of bullying, harassment
and other prescribed behaviour, made since 1 January 2008. I understand
that a number of such cases are due to be heard over the next
few months. The central secretariat in the MoD will contact independent
members and assign a member to a particular panel.
THE COMMISSIONER'S
PRIORITIES (VISITS)
(a) During your visits, did you notice significant
differences in attitudes towards the complaints process amongst
the Services?
Answer: I have noticed a difference between
Services as regards the complaints process in my dealings with
them generally, not just on visits. These relate to the organisational
structures and procedures, for example for handling any personnel
matters, the volume and frequency of Service complaints and the
Service culture of how general business is undertaken. There are
differences too in the Services' perceptions of the extent to
which they have problems with bullying and harassment. My Annual
Report shows that it is not just an issue for the Army. However,
most of the attitudes and barriers I highlight in my Annual Report
are common across the Services, eg the attitude towards complainants
which creates barriers to making a complaint.
(b) For what particular reasons do you think
such differences (if any) exist?
Answer: They relate to the culture of the Service
which in turn relates to the operational requirements. For example,
the Army, which is large and structured around a clear pyramidal
hierarchy, provides written notification to complainants on the
progress of a complaint: the smaller flatter structured RAF, with
a higher percentage of officers and professionals, prefers to
update complainants orally. Whilst I have recommended written
updates for all Services in future (to avoid the risk of misunderstandings
or oversight which have occurred in the RAF) care needs to be
taken to ensure that such written communication is meaningful
and reduces rather than exacerbates the stress involved in bringing
a complaint. The Navy's particular concerns about confidentiality
link to operational life in confined quarters for long period
of time. These operational, cultural and structural differences
also seem to me to account for the different levels of information
about Service complaints system, (the Navy with its strong divisional
officer system of briefing having the highest awareness) and the
roles the Service secretariats play in relation to Service complaints.
RELATIONS WITH
KEY MOD
AND MILITARY
PERSONNEL
(a) Are you satisfied with the initial induction
provided for you by the MoD?
Answer: Yes. The MoD arranged for me to meet
key personnel early in 2008, individually and by arranging visits
across the Services. Those I met were generous with their time,
information and advice.
(b) Have changes of senior Service personnel
affected your relationship with the MoD or the Services?
Answer: No. Like me, the MoD and Services have
made it a priority to ensure that I meet new post holders as personnel
change. That my induction involved a wide range of Service Chiefs
has meant that I have established good working relationships with
incoming post holders. However this will remain a priority for
me.
RESOURCES
Has the delay in recruiting the extra staff you
feel you need seriously affected your work during the year?
Answer: The impact has mainly been felt this
year. Towards the end of 2008 and the first quarter of 2009, I
did not have the resources to manage my statutory responsibility
to report to Ministers and Parliament on the service complaints
system and sustain good levels of customer service with an increasing
workload. I have had to prioritise new referrals and the Annual
Report. It will take a while and the agreed additional resources
to get our customer service performance back on track. One new
member of staff will join my office at the end of April and the
MoD has agreed that the temporary caseworker, who has been in
place since the beginning of March 2009, can stay until the fourth
member of staff arrives.
During 2008 I had to shelve plans for auditing
sample completed cases. Unless that fourth post, which will support
me on the audit work and Annual report, is recruited soon, my
plans for audit for 2009 may be in jeopardy. The MoD is aware
and supportive of the fact that more resources are required and
is looking to provide other assistance to minimize the impact
of delay.
ADDITIONAL INFORMATION
In your response to Dai Havard's question (Q8)
on Coroners' practices and your relationship with the Coroners'
Service, you mentioned that you would reflect on the matter and
come back to us.
Answer: This is an evolving area and one on
which I will continue to reflect. I now have a role in relation
to notifications of unexplained deaths, as explained in more detail
in my response to Q44. This system started in December 2008 and
my role is still developing. My initial thoughts are that the
information I receive will enable me to ask questions about wider
issues and systemic concerns, which will be complementary to,
but separate from, the work done by the Coroners' service. The
issues I consider will also include the involvement of and communication
with families. I will keep this aspect under review as my role
develops.
1 April 2009
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