More complaints please! - Public Administration Committee Contents


2  Principles of good complaints handling

11. The vast majority of our witnesses observed that, when handled well, complaints can make a difference for both the individual complainant and the service concerned. For the individual, it can ensure justice, secure an apology or provide an explanation as to why a decision or action was taken.[10] For the service or organisation, a complaint provides an important source of information and, as suggested to us by the Local Government Ombudsman—which looks at complaints about councils and other authorities and organisations including education admissions appeal panels and adult social care providers—"can make a real difference to the experience that the public have of public services".[11] The Centre for Public Scrutiny, an independent charity that promotes transparent, inclusive and accountable public services, observed that, for a service, complaints can identify a need for improvement that may not be found elsewhere:

    When developing a policy or service model, it is almost impossible to anticipate all potential variables of implementation and impact. This is why complaints should be viewed as a strategic resource providing rich and diverse perspectives. They can illustrate how well goals and standards are being achieved from the point of view of the needs and aspirations of citizens and on any unintended consequences of the way policies are implemented or decisions are made.[12]

What does good complaints handling look like?

12. Several organisations have produced their own visions for good complaints handling, examples of which are provided in Boxes 1, 2 and 3. Of the evidence we heard, three elements of good complaints handling stood out.

a)  Effective and clear process. Jo Causon, Chief Executive of the Institute of Customer Service, an organisation that aims to help other organisations strengthen their business performance by improving their customers' experiences, explained that the process should be "well documented so that people know how to complain through multiple channels".[13] Richard Lloyd, Executive Director of Which?, an independent, not-for-profit consumer organisation, echoed this and told us about the importance of communication within the complaints process:

    Clear processes, including good communication back to people about how their complaint is being handled, so not just submitting a complaint and then you do not hear again until it has been resolved; clear stages to escalate the complaint; and a clear communication of how your complaint will be handled and how you will be taken care of during the process.[14]

b)  A positive attitude to complaints. Both senior and front line staff should regard complaints as a positive indicator of user engagement and they should be valued as a source of information about the quality of the service. Jo Causon told us, for example, that "the fact that anyone is raising a complaint is a good thing in terms of the knowledge and information that it shares".[15]

c)  The ability to use information from complaints to inform plans and strategy, and to deliver practical improvements. The Parliamentary and Health Service Ombudsman (PHSO) suggested that complaints could indicate early symptoms of a problem and could help to identify trends.[16] The Local Government Ombudsman drew attention to the need for complaints to be an integral part of service provision:

    While good complaint handling can have a range of benefits in service provision, this can only be realised if it is properly integrated into service provision. This will include ensuring that all staff learn from complaints and view them as an insight into the consumer's voice and an important tool in service improvement.[17]
    Box 1: Parliamentary and Health Service Ombudsman's principles of good complaint handling.[18]

    ·  Getting it right e.g. acting in accordance with law, having good governance.

    ·  Being customer focused e.g. having clear and simple procedures.

    ·  Being open and accountable e.g. providing clear, accurate and complete information.

    ·  Acting fairly and proportionately e.g. treating the complainant impartially.

    ·  Putting things right e.g. acknowledging mistakes and apologising.

    ·  Seeking continuous improvement e.g. regularly reviewing the lesson learned.

Box 2: Administrative and Justice Tribunals Council (now abolished) Principles for administrative justice.[19]

·  Make users and their needs central, treating them with fairness and respect at all times.

·  Use procedures that are independent, open and appropriate for the matter involved.

·  Keep people fully informed and empower them to resolve problems as quickly and comprehensively as possible.

·  Lead to well-reasoned, lawful and timely outcomes.

·  Be coherent and consistent.

·  Work proportionately and efficiently.

·  Adopt the highest standards of behaviour, seek to learn from experience and continuously improve.

Box 3: Centre for Public Scrutiny (CfPS) and Local Government Ombudsman: Enablers and barriers to using complaints effectively.[20]

Enablers

·  Creating a culture of learning and improvement

·  Providing people with lots of ways to give feedback

·  Leadership in sharing lessons across the organisation

·  A co-ordinated resource that maximises the impact of learning

Barriers

·  Treating complaints as an opportunity to defend practice

·  Poor communication with citizens and complainants

·  Silo approach to complaints, no sharing of lessons across the organisation

·  Little connection between feedback, insight and strategic planning

13. Private sector organisations, particularly the retail sector, provide examples of good practice in complaints handling, and as we heard from some top performing organisations, they pay detailed attention to complaints because they are "cheap market research" and help to build and reinforce customer loyalty.[21] Simon Roberts, Chief Operating Officer of Boots UK, a member of Alliance Boots, an international pharmacy-led health and beauty group, told us that complaints are "a very rich source of helping you understand what customers would like to see us do more of or differently".[22] Good complaints handling is also seen as important in retaining customers and "market-share". Richard Lloyd observed that "in private markets, if you do not listen to complaints, it is the difference between your business succeeding and failing".[23] Some witnesses suggested that there was an equivalent to "market share" for the public sector. Dame Julie Mellor, PHSO, said:

    [...] maybe it would be trust and confidence rather than market share—trust and confidence in the service—which would apply to the Government of the day as well, in terms of whether people are confident that excellent services are being delivered by the Government.[24]

14. Witnesses commented on the differences between the two sectors in terms of complaints handling. The Blue Flash Music Trust, an arts and music charity, said that the private sector approaches a complaint with "a 'make the customer happy quickly' objective" because they are aware of competition and the need for a relationship with the customer, but public sector organisations do not experience this as they often hold the monopoly.[25] Other witnesses were uneasy about making comparisons between the sectors. Claire Murdoch, Chief Executive of the Central and North West London NHS Foundation Trust, told us:

    many of us who are working in the NHS at the moment—I am a registered nurse as well of 30 years now—are cross that there is a broad 'private sector good, NHS bad; private sector open and can-do, NHS closed and defensive'. We can be better and we should be. There are some appalling examples of failure but I believe there are some brilliant examples of openness and a can-do culture that would rival the best of the private sector as well.[26]

15. Mark Mullen, the then Chief Executive Officer of First Direct Bank, an organisation which has consistently high customer satisfaction ratings, suggested to us that the way in which the private sector operates and uses complaints could not be replicated in the public sector, because "the motives of the public and private sector are very different", but accepted that complaints should play an important part in public services:

    You would expect the feedback loop and the way that you re-engineered failures or learnings from failures in life and death businesses—aircraft travel is another one—to be of an order of magnitude where the tolerance for failure was significantly lower. Therefore, the early warning signs that tell you that something might be going wrong would be significantly lower.[27]

CONSEQUENCE OF POOR COMPLAINTS HANDLING: "SILENT SUFFERERS"

16. One consequence of poor complaints handling is the creation of a group of individuals who have a problem, but choose not to complain. PHSO suggested that its research showed a significant number of people do not complain because they believe complaints processes are too complex, involve them having to chase a response and that they fear nothing will change as a result of their complaint.[28] Jo Causon, Chief Executive of the Institute of Customer Service, introduced us to the term "silent sufferers" to describe those who choose not to complain, and she explained to us the extent of the problem:

    In the UKCSI [UK Customer Service Index] research that the Institute undertakes, we ask a question about whether people have had an issue and whether they then decided to do anything about it. So it is those who have had an issue but decided not to do anything about it. [...] In the overall public sector, it is about 28% of people in terms of those who responded to the survey.[29]

17. The organisation Which? highlighted to us its research that suggested fewer people complain about public services than private companies:

    Just 65% of those who had cause to complain about an NHS service in the last year did so, while 69% complained about another government department service [...] By contrast, 90% of those with cause to complain about a high street retailer did so, 89% complained about a bank or tradesperson and 83% complained about an energy supplier.[30]

18. How complaints are handled determines the quality of the relationship between consumers and public services. The best performing organisations welcome and see complaints as a way of engaging consumers. A failure to recognise the importance of complaints leads to insufficient redress for the individual, limits the impact that complaints have in improving services, and alienates the public.

How well are departments handling complaints?

19. Complaints handling across Government remains inconsistent, according to several of those we heard from. Dame Julie Mellor described the progress as "mixed" but said that there were "indications in central Government of beginning to take complaints more seriously".[31] Claire Murdoch told us that, while there is some poor practice, there are also "teams and individuals who are stunning in their practice".[32]

20. Robert Devereux, Permanent Secretary at the Department for Work and Pensions, explained to us the progress he felt has been made in his Department's complaints processes:

    [...] we have been a lot clearer about what a complaint is, so that our staff actually understand what they are supposed to do with it and when. We have simplified the process. [...] We have gone down to having just two tiers of complaints. The percentage of complaints being taken to the second tier has collapsed by 75% over the last two years, as a consequence of doing it better at the first tier. The amount of things that are going off to the Independent Case Examiner has reduced sharply, and the number of times that he actually finds in favour of the Department when he does investigate things has gone up. I would argue that, at least in terms of the actual mechanical handling of complaints, we are getting better than we were previously.[33]

LEARNING FROM COMPLAINTS

21. We also heard of positive examples in which agencies use intelligence gathered from complaints to improve services. Sarah Rapson, the then Interim Director General, UK Visas and Immigration (UKVI), now Director General, UKVI, Home Office, gave the example of the Passport Service, which she previously managed before joining UKVI:

    One of the things that came through was that people do not necessarily want their passport quickly; they want to know how quickly they will get it and if we will give it to them in that time. They want assurances that their application has been received. As a direct consequence of that, we have introduced texting to people on their mobile phones to say, 'We have got your application', and a lot of that noise has fallen away.[34]

22. Mark Grimshaw, Chief Executive of the Rural Payments Agency (RPA), drew attention to the transformational change his service has gone through as a result of a focus on complaints handling. The agency had in the past experienced major difficulties in administering and distributing the Single Payment Scheme: an EU subsidy for farmers in England. Complaints were made and PHSO investigated as a result. Two general findings of maladministration were made in PHSO's report: that the RPA failed to "get it right", or "be customer focused", and failed to respond appropriately when it came to "putting things right"' for individuals.[35] We were told about how the RPA had since undergone significant change and that a recent customer survey found that overall satisfaction with the RPA had reached its highest ever levels. Mark Grimshaw told us that:

    We seek to capture all expressions of dissatisfaction, so that we can actually understand what is causing the problems for our customers and then do something about it. The open approach we have adopted by putting our most capable caseworkers into the complaints resolution space has pretty much transformed the way that we deal with complaints and the experience that our customers have had.[36]

STILL SOME WAY TO GO

23. Despite some promising examples of good complaints handling in Government, we heard evidence, particularly from members of the public, to suggest that some departments and agencies are not consistently meeting good practice principles with regards to complaints handling. One submission suggested that the complaints system was obstructive and "only the most tenacious complainant would get to the end of it".[37] On learning from complaints, one individual said that:

    I can say categorically that no lessons have been learnt by those who are in authority. The same problems come up time and time again.[38]

24. In May 2013 PHSO published data on the number of complaints that it received relating to every UK government department in 2012, in letters sent to permanent secretaries. These letters listed some of the common failures in complaints handling that the PHSO had found through her work, which included:

·  failure to respond to complaints within a reasonable length of time;

·  failure to provide accurate and timely information;

·  poor customer service;

·  grudging apologies;

·  failure to resolve issues;

·  poor record-keeping;

·  poor decision-making;

·  failure to learn from mistakes; and

·  providing incomplete, unhelpful or confusing responses.[39]

25. In some parts of public services, there are encouraging signs of increased attention on good complaints handling. However, Government as a whole cannot be said to be complying with best practice in complaints handling or adapting to the needs and expectations of today's citizen. What the Parliamentary and Health Service Ombudsman referred to as the "toxic cocktail" in respect of complaints handling—a reluctance on the part of citizens "to express their concerns or complaints" and a defensiveness on the part of services "to hear and address concerns"—so often poisons efforts to deliver excellent public services.


10   Parliamentary and Health Service Ombudsman (COM 16) para 1 Back

11   Local Government Ombudsman (COM 06) para 3  Back

12   Centre for Public Scrutiny (COM 15)  Back

13   Q16 Back

14   Q16 Back

15   Q3 Back

16   Parliamentary and Health Service Ombudsman (COM 16) para 10 Back

17   Local Government Ombudsman (COM 06) para 28 Back

18   Parliamentary and Health Service Ombudsman, Principles of Good Complaint Handling (February 2009) p5 Back

19   Administrative and Justice Tribunals Council (COM 11)  Back

20   Centre for Public Scrutiny (COM 15) Back

21   Administrative and Justice Tribunals Council (COM 11) Back

22   Q173 Back

23   Q29 Back

24   Q98 Back

25   Blue Flash Music Trust (COM 05) para 4 Back

26   Q314 Back

27   Q211 Back

28   Parliamentary and Health Service Ombudsman (COM 16) para 2 Back

29   Qq42-43 Back

30   Which? (COM 12) para 3.1 Back

31   Q120 Back

32   Q306 Back

33   Q138 Back

34   Q140 Back

35   Parliamentary and Health Service Ombudsman, Cold Comfort: the Administration of the 2005 Single Payment Scheme by the Rural Payments Agency HC (2009-10) 81 Back

36   Q140 Back

37   Margaret and Janet Brooks (COM 33) Back

38   Brenda Prentice (COM 04) para 12 Back

39   Parliamentary and Health Service Ombudsman, New analysis of complaints by Ombudsman shows government departments need to raise their game, accessed May 2013 Back


 
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© Parliamentary copyright 2014
Prepared 14 April 2014