Managing complaints and feedback 104-02000000

Services Australia Customer Complaint and Feedback Management Guidelines

Table 1

Category	Description
Overview	These guidelines provide support for the application of the Customer Complaint and Feedback Policy and detail the major aspects of receiving, assessing, managing and finalising complaints and feedback. Complaints and feedback are everyone's responsibility, and everyone within the agency is authorised to finalise them. Any staff member receiving a complaint should try to finalise it at the first point of contact. If the complaint cannot be immediately finalised, staff should retain ownership of the complaint until it is either finalised or further escalated to Level 2. This includes if assistance is required from senior staff or Subject Matter Experts (SMEs). Complaints, compliments and suggestions lodged via the agency's official complaints and feedback channels will be received by staff with a skill set in complaints and feedback handling in each of the service delivery brands. The agency's Multicultural and Tailored Services Branch is responsible for all policy and procedures related to customer complaints and feedback, and the management of all Level 2 complaints. Complaints alleging unauthorised access and/or disclosure of information or internal fraud will be referred to the Internal Fraud Control and Investigations Branch. Complaints alleging customer fraud will be referred to the Serious Non-Compliance Branch. The allegations will then be managed under the fraud investigation procedures for these Branches. Where a complaint is considered urgent or high profile, it may need to be escalated to the Secretary, Executive and Minister's Office. This escalation will occur within the Level 2 Complaints Team in accordance with the agency's Escalation Coordination Policy. See the Escalation Coordination Team homepage for information about the policy.
Receiving a complaint, compliment or suggestion	Using the definitions contained within this policy, staff are expected to determine whether the customer is making a complaint or general enquiry, or providing a compliment or suggestion In making a determination, staff should also consider the following criteria to assess whether a customer is making a complaint or a general enquiry: The manner in which the customer communicates or expresses the issue/s, The urgency of the issue/s raised, The potential or actual impact of the identified issue/s on the customer, and Prior or ongoing attempts at resolution through regular business processes Customers are entitled to make complaints or provide feedback anonymously. Staff will not record identifying details of customers who wish to remain anonymous. Where possible, staff will confirm with the customer if and how they want to be advised of the complaint outcome. Customers who lodge anonymous complaints will be advised that it may be difficult to conduct a full investigation without knowing the identity of a complainant Staff will be alert and flexible to the needs of vulnerable customers. This includes allowing authorised third parties to make complaints and act on behalf of others All compliments and suggestions provided to the agency via phone or in person should be acknowledged by the staff member who receives them and the customer informed their feedback will be shared with the relevant staff and business owners. Compliments and suggestions provided online are acknowledged at the time of lodgement. Compliments and suggestions provided online or in writing from customers will be shared with relevant staff and business owners When a complainant expresses intent to go approach the media about their complaint, staff must alert the agency's media section. If the customer advises they have been to the media the case should be escalated to specialist complaints staff Customers who provide complaints and suggestions via the agency's social media channels will be responded to and encouraged to provide details so we can provide a tailored response to finalise their complaint. In the absence of personal details, a social media complainant will be provided with a general response If a complaint is provided to the agency via phone or in person, staff are expected to acknowledge receipt of the complaint during the initial contact and attempt to finalise it If a complaint is received via a written or an online channel, including social media, where automatic acknowledgement is not available, the staff member who receives the complaint must contact the customer to acknowledge receipt of the complaint within five working days and attempt to finalise it During any initial contact with a customer, including when the customer first provides their complaint or feedback, staff are expected to manage the customer's expectations. This includes providing details about the complaints and feedback management process, timeframes for investigating a complaint, asking about the remedy the customer is seeking and advising what can and cannot be done Staff should take the time to record all complaints and feedback as a method of highlighting weakness and improving service to customers. All customer complaints and feedback must be recorded in the agency's central database for customer feedback
Complaint assessment	Staff should take a holistic approach to complaint assessment and consider the complainant's issues as well as any other relevant concerns the staff member identifies. This includes any issues that have not been identified by the customer but could impact on or contribute to their dissatisfaction Staff will assess complaints for priority or complexity by referring to the complaint escalation reasons, and then decide whether the complaint can be finalised at first contact or if it needs to be escalated to a specialist Complaints Officer (for contact details, see Warm transfer customers to Level 2 - Escalated Complaints and Feedback team in Complaints). Staff should also assess if complaint issues require investigation after the first contact, and manage the customer's expectations regarding what will happen and when Any complaints originating from the Commonwealth Ombudsman, the Minister, Members of Parliament, directed to the agency's Executive branch, should be escalated for management by specialist complaints staff If a complaint is about the age, gender, religion, race, sexual orientation, gender identity, intersex status, marital or any other personal characteristic (perceived or known) of agency staff, staff must treat it with sensitivity and with regard to anti-discrimination principles Complaints about the actions, management, or conduct of a staff member handling a complaint must be escalated for independent investigation. If the complaint is about a staff member the complaint should be escalated to the staff member's manager or a specialist complaints staff member
Planning	When a complaint cannot be finalised at the first point of contact, staff should document what needs to be done to finalise the complaint. This includes, but is not limited to, the issue to be investigated, any steps involved, whether more information is required, the remedy the customer is seeking, and any special considerations Staff must document all details of their plans for investigation on the complaint record in the agency's central customer feedback database including any commitments provided to customers Staff should update their plans when an investigation progresses, and new information becomes available
Investigation	Staff must treat a complaint on its merits and undertake an investigation proportionate to the assessment of the complaint and the severity of the issues presented Staff should use all resources available to them in an attempt to finalise a customer's complaint. This includes reference material and assistance from Subject Matter Experts (SMEs) and/or a Team Leader During an investigation, staff should contact a complainant to update them about the progress and status of their complaint, where additional information is required, or when adverse or conflicting information is presented Staff must document all details of their investigation and any related decisions on the complaint record in the agency's central customer feedback database
Response	Staff should inform complainants of any findings in relation to the issues raised in a complaint and advise when a complaint is finalised. This advice should be provided in accordance with agency guidelines on disclosure of information. See the link to details on disclosure of information on the Your right to privacy website page Staff should tailor responses to meet the needs of individual complainants, and offer a remedy to complaint issues that is appropriate in the circumstances In instances where a mistake is made, or service standards are not met, staff should offer an apology Staff should clearly explain any remedies provided or offered to the customer, including information or an apology. If no remedy is appropriate or available, the staff member will explain this to the customer If a customer remains dissatisfied with the response or the remedy provided or offered to finalise their complaint, staff should advise them of their further escalation options within the agency and external such as the Commonwealth Ombudsman. For contact details, see Warm transfer customers to Level 2 - Escalated Complaints and Feedback team in Complaints Complaints about the actions, management, or conduct of a staff member handling a complaint should be escalated to specialist complaints staff or the staff member's manager if the initial response does not resolve the complaint. Customers should be informed that we cannot advise them of the outcome of these investigations but that we value feedback provided by customers
Business improvement	Staff should proactively identify systemic issues and complaint trends affecting the service the agency provides to customers. Staff are expected to report systemic issues at the earliest opportunity Staff will record information about complaints and feedback in a centralised database for customer feedback. Reports from this database will be provided to business owners to enable them to identify complaint trends, consider suggestions, and review all compliments When there is evidence that a service or policy affecting a customer could be improved as the result of a complaint, the person managing the complaint should provide constructive and respectful feedback about the issues identified to increase individual and organisational capability and improve customer service
Responsibility	All staff responsibility Staff are expected to adhere to this policy and follow any procedural and process instructions related to complaints and feedback management Staff are expected to explain to customers how they can make a complaint or provide feedback, acknowledge and record all complaints and feedback when they are received, and ensure that responses are provided in a timely manner Staff are responsible for attempting to finalise complaints and feedback at the first point of contact. This includes seeking technical and/or leadership assistance where necessary, being aware of guidelines for escalating more complex or sensitive issues, acknowledging and responding to complaints and feedback and apologising when appropriate to complainants Staff are expected to provide relevant and timely business feedback about behavioural complaints, systemic issues and opportunities to improve service to customers Staff will treat complaints about the behaviour of other staff or contractors in the strictest of confidence Management responsibility Managers are expected to promote a positive and transparent complaint and feedback culture, actively discussing complaint reports with individual staff and in the team environment and support staff to prioritise complaint resolution Managers are responsible for evaluating business feedback about behavioural complaints and working with staff to develop their skills in service delivery Managers are expected to be actively involved in the ongoing review and evaluation of the complaint management process, applying their knowledge, skills and experience to enhance service delivery by escalating potential systemic issues and opportunities for improvement Executive responsibility The Executive will make complaint handling a priority, and be accountable under the Quality Framework for promoting and maintaining a customer centric focus in an environment of continuous improvement The Executive will lead by example, collaborate on and be responsible for systemic issues, drive improvement initiatives, apologise when appropriate, encourage innovation and the discussion of ideas, and provide clarity around business ownership of products and services The Executive will ensure that processes for management of external complaints and Executive correspondence are observed, and ensure that responses are provided in a timely manner Customer and complainant responsibility Complainants are expected to use respectful and courteous language, free from abusive, offensive and threatening comments in the complaints or feedback they provide Customers and complainants are expected to provide the agency with all relevant information about their feedback or complaint to assist with resolution of their issues

Complaint escalation reasons used to assess a complaint for its priority and complexity

Table 2

Escalation reason	Description
1	Ombudsman complaint The complaint comes through contact from the Commonwealth Ombudsman. This includes both warm-transferred complaints and investigations under to section 8 of the Ombudsman Act 1976.
2	Member of Parliament/Ministerial and Executive correspondence The complaint is either verbal or in writing. It comes into the agency from either a: Member of Parliament (MP) the Minister or the agency's Executive branch
3	Complaint is fundamentally sensitive The complaint involves an urgent or high profile issue that could: affect the reputation of the agency or the agency's actions may have or could harm a vulnerable customer Complaints of this kind will require detailed investigation Examples include: allegations that the agency’s actions have caused harm to a person, or a person to harm themselves or another person a complaint from a customer taking legal action against the agency a complaint about service received from or actions taken by the agency following a bereavement a complaint from a customer with a terminal illness a complaint about a decision impacting on a vulnerable customer a complaint about the recording of gender identity or a transgender, intersex or non-binary issue a complaint from a customer receiving Farm Household Allowance (FHA) The Level 2 Complaints Team will manage these complaints and escalate in accordance with the agency's Escalation Coordination Policy.
4	Potential serious breach of APS Code of Conduct or allegations of fraud, unauthorised access or disclosure of information The complaint includes allegations of a breach of the APS Code of Conduct, including: threats of retribution discrimination or other serious staff misconduct The complaint may include: staff allegedly accessing or disclosing information without authority committing fraud and/or fraud allegedly committed by a staff member Complaints of this type need impartial investigation by qualified staff. Investigation may take extended time. The Level 2 Complaints Team will escalate these complaints in line with the agency's code of conduct investigation procedures.
5	Complex, cross programme or multiple issues The complaint needs investigation and liaison beyond merely seeking technical support or guidance from a Team Leader. The complaint may involve several of the agency's service brands or programmes or another agency. Achieving an outcome will require investigation and liaison within and between service brands. It includes complaints with cross agency issues.
6	Evidence of media involvement The complainant has advised that they have been in contact with: a media outlet about their complaint or the media outlet contacts the agency directly about a customer complaint The agency has protocols for managing media escalations and enquiries, requiring co-ordination and intensive management. See Media protocols homepage.
7	Persistent unreasonable complainant behaviour The complainant displays behaviour that requires more intensive managing in order to progress and resolve the complaint. Complainant behaviour includes unreasonable: persistence demands lack of cooperation arguments behaviour Before using this complaint escalation reason apply: Customer aggression guidelines and referrals to social workers for vulnerable customers Talk to a Manager or Team Leader about any incidents of customer aggression and for advice about reporting and support. See the Customer aggression homepage.
8	Refusal to accept first contact outcome The Level 1 complaint owner has investigated the complaint and has provided an outcome. However, the complainant continues to disagree with the outcome and requests complaint escalation.

Differences between a complaint and a formal review or objection

Table 3

Scenario	Complaint or formal review/objection?	Indicators keywords or factors
A customer disagrees with a decision. They ask for a review of the decision.	Formal review/objection	disagree, decision, review, appeal, objection
A customer is dissatisfied with the decision and the length of time taken to decide. The customer understands/agrees with the decision but is dissatisfied with the outcome and/ or process, including service provided by staff or delays in formal review.	Complaint	understands/agrees (decision), dissatisfied, outcome, process, rude, delayed, etc.
A customer is dissatisfied with a decision. The customer believes the agency has made a mistake. The customer does not understand the decision making. The customer: feels there was a lack of explanation the service provided was rude and judgemental details were not considered The customer disagrees with the decision.	Both formal review/objection and complaint.	dissatisfied, decision, mistake, information not considered, disagrees
A customer has a formal review/objection in progress. They are dissatisfied with the length of time it is taking to complete the review. The customer is upset about: the content of a letter received the review the manner of the staff member when contacted to discuss the letter	Complaint	review/objection in progress, dissatisfied, length of time taken, up

Questioning techniques to identify the details of a behavioural complaint

Table 4

Customer complaint

Questions to help clarify details of the complaint

The staff member did not listen to me

Ask the customer:

What were you telling the staff member when you felt like this?
What made you feel like they were not listening?
Did you say something that would change the decision that was not heard?

The staff member has made an error

Ask the customer:

What is the error?
What were your expectations of the decision/process/outcome before this error occurred?

I didn't understand what the staff member was telling me. They used too much jargon

Ask the customer:

What had you asked the staff member when they provided a response?
Did you ask the staff member to explain it again?
Was it the words of the staff member used that you did not understand?

To clarify the outcome the customer was expecting, ask the customer:

What response were you expecting from the staff member?
What question do you need an answer to?
Can I give these details to you now?

The staff member did not take into account my literacy issues/ special needs

Ask the customer:

Did you advise the staff member of your concerns?
Did the staff member discuss with you alternatives to receive a service or details?
How would you like to have details provided to you in the future?

The staff member was biased/ discriminating towards me

Ask the customer:

What was occurring when you felt this?
What was said to make you feel this way?
Was it how it was said that made you feel this way?
Did you raise this with the staff member? What was the staff member's response?

I just wanted my question answered, I was transferred to the wrong area

Ask the customer:

What had you asked the staff member before they transferred the call?
Did the staff member explain why you needed to be transferred?
Would you be happy to give me the details of your enquiry and I will take ownership of this for you?

The staff member lacked empathy or sensitivity towards culture or bereavement

Ask the customer:

What circumstances did you expect the staff to be sensitive about?
Have you got support for this right now?
Would you like me to refer you to (relevant section) for support?

Give the customer support or relevant referrals. Then discuss complaint:

What were you discussing with the staff member when you felt there was no empathy/ sensitivity displayed?
What did the staff member say that upset you?
Do you think the staff member was appropriately aware of your situation?
Did you explain to the staff member you felt this way?
How did the staff member respond?

The staff member threatened me

Ask the customer:

What was occurring when you felt threatened?
What was said to make you feel this way?
Did you raise this with the staff member?
What was the staff member's response?

The staff member continually spoke over the top of me/ cut me off

It can be difficult to convey details:

if a decision has been made which the customer does not agree with, or
a customer needs to take action which they do not believe is their responsibility

Customers and staff members may speak over each other in their attempts to be heard.

Ask the customer:

What were you trying to convey when the staff member spoke over the top of you/ cut you off?
What was the staff member trying to say when this happened?

I wanted to speak to a manager and I was not allowed to

Ask the customer:

Did the staff member explain why a manager was not available?
Why did you want to talk to a manager?
Did the staff member try to resolve your complaint?

They/ you didn't do what you said you would do

Ask the customer:

When did this happen (date/ time)?
What was the name of the staff member you were speaking to?
Was the call initiated by you or did the agency call you?
Was it on your mobile or landline?
Do you think it could have been your mobile reception or battery?

Review any notes from the call or interview. Notes may give reasons why it ended. Ask the customer:

What were you discussing prior to the call ending?
Were either you or the staff member expressing yourselves emotionally?
Did the staff member tell you they would be ending the call?
What details did you need to pass on that you were unable to before the call/ interview ending?

Customer feedback documentation

Table 5

Item

Description

Include in customer feedback documentation

The reason for the complaint or feedback and the outcome sought
Details of the investigation
All successful and unsuccessful customer contacts. This includes the phone number called, date and time of the call, and if a message was left
An exact summary of the conversation, including referrals, explanations, decisions and/or resolution offered. Include whether the customer was satisfied with the resolution provided
References to Operational Blueprint files and/or other official reference material, such as legislation used to make a decision
Details of any further action to be taken, including next agreed customer contact date/time
An apology, if provided
If sending an email or letter to the customer, document which email/letter template was used
If escalating a complaint to Level 2, a full explanation of why the complaint has been escalated and the customer’s expectation

Do not include in customer feedback documentation

Judgemental statements or personal opinions about the customer or their situation
Information that is not relevant to the complainant, activity or decision, that is, commenting about availability, agency’s internal processes
Information of a sensitive or personal nature, for example sensitive information of a medical or personal nature (unless it directly relates to the feedback or complaint issue), including medical abbreviations
Abusive or offensive language. Be factual and verbatim, where possible so the information reflects the customer’s feedback, but do not include obscene or offensive content
Smart Centre Acronyms and Abbreviations including use of text language
Jargon or abbreviations. For example, when referring to the customer, use the word ‘customer’, not ‘cus’
Only include acronyms once the full term has been used. For example, ‘Australian Immunisation Register (AIR)’ in the first instance, then ‘AIR’ throughout the rest of the notes
Do not include a surname or other personal information regarding a staff member. A first name and logon only should be recorded. Note: staff logons or surnames must not be provided to customers
Avoid emotive language. For example, instead of ‘The customer was very angry’, use ‘The customer said they were angry about…’ or ‘The customer expressed their anger about…’

Note:

all information recorded is subject to the provision of the Freedom of information (FOI) Act
if notes are recorded in the Customer Feedback Tool (CFT) in error, they cannot be deleted. The CFT record must be: