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
Ombudsmanwhich 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.
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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.
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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
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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 sharetrust and confidence in the servicewhich
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
momentI am a registered nurse as well of 30 years noware
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 businessesaircraft travel is another oneto
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 handlinga 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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