This policy is intended to ensure that we handle complaints fairly, efficiently and effectively. Our complaint management system is intended to:
This policy provides guidance to our staff and people who wish to make a complaint on the key principles and concepts of our complaint management system.
This policy applies to all staff receiving or managing complaints from the public made to or aboutus, regarding our products, services, staff and complaint handling.
Staff grievances, code of conduct complaints (for local councils) and public interest disclosures are dealt with through separate mechanisms.
This organization expects staff at all levels to be committed to fair, effective and efficient complaint handling. The following table outlines the nature of the commitment expected from staff and the way that commitment should be implemented.
|Promote a culture that values complaints and their effective resolution
|Manager responsible for complaint handling
|Establish and manage our complaint management system.
|Staff whose duties include complaint handling
|Demonstrate exemplary complaint handling practices
|Understand and comply with Kuga complaint handling practices.
Expression of dissatisfaction made to or about us, our products (where relevant) services, staff or the handling of a complaint where a response or resolution is explicitly or implicitly expected or legally required.
A complaint covered by this Policy can be distinguished from:
All policies, procedures, practices, staff, hardware and software used by us in the management of complaints.
An unresolved complaint escalated either within or outside of our organization.
Opinions, comments and expressions of interest or concern, made directly or indirectly, explicitly or implicitly, to or about us, about our products, services or complaint handling where a response is not explicitly or implicitly expected or legally required.
A clear, formal written statement by an individual staff member about another staff member or a work related problem.
A statement of instruction that sets out how we should fulfill our vision, mission and goals.
A statement or instruction that sets out how our policies will be implemented and by whom.
A report about wrong doing made by a public official in Australia that meets the requirements of the Public Interest Disclosures Act 2013
We are committed to seeking and receiving feedback and complaints about our services, systems, practices, procedures, products and complaint handling.
Any concerns raised in feedback or complaints will be dealt with within a reasonable time frame. People making complaints will be:
We will take all reasonable steps to ensure that people making complaints are not adversely affected because a complaint has been made by them or on their behalf.
We accept anonymous complaints and will carry out an investigation of the issues raised where there is enough information provided.
We will ensure that information about how and where complaints may be made to or about us is well publicised. We will ensure that our systems to manage complaints are easily understood and accessible to everyone, particularly people who may require assistance.
If a person prefers or needs another person or organisation to assist or represent them in the making and/ or resolution of their complaint, we will communicate with them through their representative if this is their wish. Anyone may represent a person wishing to make a complaint with their consent (e.g. advocate, family member, legal or community representative, member of Parliament, another organisation).
Complaining to us is free.
Where possible, complaints will be resolved at first contact with Kuga
We will promptly acknowledge receipt of complaints
We will assess and prioritise complaints in accordance with the urgency and/or seriousness of the issues raised. If a matter concerns an immediate risk to safety or security the response will be immediate and will be escalated appropriately.
We are committed to managing people’s expectations, and will inform them as soon as possible, of the following:
We will advise people as soon as possible when we are unable to deal with any part of their complaint and provide advice about where such issues and/or complaints may be directed (if known and appropriate). We will also advise people as soon as possible when we are unable to meet our time frames for responding to their complaint and the reason for our delay.
We will address each complaint with integrity and in an equitable, objective and unbiased manner. We will ensure that the person handling a complaint is different from any staff member whose conduct or service is being complained about.
Conflicts of interests, whether actual or perceived, will be managed responsibly. In particular, internal reviews of how a complaint was managed will be conducted by a person other than the original decision maker.
Our staff are empowered to resolve complaints promptly and with as little formality as possible. We will adopt flexible approaches to service delivery and problem solving to enhance accessibility for people making complaints and/or their representatives.
We will assess each complaint on its merits and involve people making complaints and/or their representative in the process as far as possible.
We will protect the identity of people making complaints where this is practical and appropriate. Personal information that identifies individuals will only be disclosed or used by Kuga as permitted under the relevant privacy laws, secrecy provisions and any relevant confidentiality obligations.
Where a complaint involves multiple organisations, we will work with the other organisation/s where possible, to ensure that communication with the person making a complaint and/or their representative is clear and coordinated.
Subject to privacy and confidentiality considerations, communication and information sharing between the parties will also be organised to facilitate a timely response to the complaint.
Where a complaint involves multiple areas within our organisation, responsibility for communicating with the person making the complaint and/or their representative will also be coordinated.
Where our services are contracted out, we expect contracted service providers to have an accessible and comprehensive complaint management system. We take complaints not only about the actions of our staff but also the actions of service providers.
When similar complaints are made by related parties we will try to arrange to communicate with a single representative of the group.
All staff managing complaints are empowered to implement our complaint management system as relevant to their role and responsibilities.
Staff are encouraged to provide feedback on the effectiveness and efficiency of all aspects of our complaint management system.
We are committed to being accessible and responsive to all people who approach us with feedback or complaints. At the same time our success depends on:
When people behave unreasonably in their dealings with us, their conduct can significantly affect the progress and efficiency of our work. As a result, we will take proactive and decisive action to manage any conduct that negatively and unreasonably affects us and will support our staff to do the same in accordance with this policy.
For further information on managing unreasonable conduct by people making complaints please see [either our policy on managing unreasonable conduct by people making complaints OR the Ombudsman’s Managing Unreasonable Complainant Conduct Model Policy 2012].
When responding to complaints, staff should act in accordance with our complaint handling procedures as well as any other internal documents providing guidance on the management of complaints.
Staff should also consider any relevant legislation and/or regulations when responding to complaints and feedback.
The five key stages in our complaint management system are set out below.
Unless the complaint has been resolved at the outset, we will record the complaint and its supporting
information. We will also assign a unique identifier to the complaint file.
The record of the complaint will document:
We will acknowledge receipt of each complaint promptly, and communicate our acknowledgement to the person preferably within 21 working days.
Consideration will be given to the most appropriate medium (e.g. email, letter) for communicating with the person making a complaint.
After acknowledging receipt of the complaint, we will confirm whether the issue/s raised in the
complaint is/are within our control. We will also consider the outcome/s sought by the person making a complaint and, where there is more than one issue raised, determine whether each issue needs to be separately addressed.
When determining how a complaint will be managed, we will consider:
After assessing the complaint, we will consider how to manage it. To manage a complaint we may:
We will keep the person making the complaint up to date on our progress, particularly if there are any delays. We will also communicate the outcome of the complaint using the most appropriate medium. Which actions we decide to take will be tailored to each case and take into account any statutory requirements.
Following consideration of the complaint and any investigation into the issues raised, we will contact
person making the complaint and advise them:
If in the course of investigation, we make any adverse findings about a particular individual, we will consider
any applicable privacy obligations under the Privacy and Personal Information Protection Act 1998 and any
applicable exemptions in or made pursuant to that Act, before sharing our findings with the person
making the complaint.
We will keep comprehensive records about:
We will ensure that outcomes are properly implemented, monitored and reported to the complaint handling manager and/or senior management.
We will inform people who make complaints to or about us about any internal or external review options available to them (including any relevant Ombudsman or oversight bodies).
We aim to resolve complaints at the first level, the frontline. Wherever possible staff will be adequately equipped to respond to complaints, including being given appropriate authority, training and supervision.
Where this is not possible, we may decide to escalate the complaint to a more senior officer within Kuga. This second level of complaint handling will provide for the following internal mechanisms:
Where a person making a complaint is dissatisfied with the outcome of Kuga review of their complaint, they may seek an external review of our decision (by the Ombudsman for example).
We will ensure that complaints are recorded in a systematic way so that information can be easily retrieved for reporting and analysis.
Regular reports will be run on:
Regular analysis of these reports will be undertaken to monitor trends, measure the quality of our customer service and make improvements.
Both reports and their analysis will be provided to Kuga CEO and senior management for review.
We will continually monitor our complaint management system to:
We are committed to improving the effectiveness and efficiency of our complaint management system. To this end, we will: