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Internal COMPLAINTS HANDLING PROCEDURE

1. Introduction

CfA recognises the importance and value of listening and responding to concerns and complaints.  CfA is committed to achieving the highest standard we can in every area of our work and to continuous improvement.  This applies especially to delivery of services, seeking donations and accountability to stakeholders generally.  CfA is committed to working according to or above the standard required by the Code of Conduct of the Australian Council for International Development (ACFID).  Receiving concerns and complaints is one of the most important ways of learning what we need to do to improve our work.

We make clear the value we place on receiving concerns and complaints in all relevant communications.  This Complaints Handling Procedure is underpinned by the Complaints Handling Policy (available via the CfA website).

2. Scope

This Procedure is intended to apply to any internal complaint, regardless of who makes it and does not apply to the Complaints Policy for more serious matters.  

Complaints which include safeguarding complaints or sexual harassment matters and matters involving Professional conduct and ethics  are dealt with by the CfA Complaints Policy, this procedure addresses internal grievances, and complaints made by CfA office bearers, staff, in-country partners, volunteers, donors and primary stakeholders.

We will accept complaints relating to all CfA office bearers, staff, in-country partners, volunteers, donors and primary stakeholders and to any person that has a grievance or expression of dissatisfaction about the standards of service, actions or lack of action and conduct of a representative of CfA.

Anonymous complaints can be made, but obviously our ability to investigate them may be limited because of this.

3. Distribution and Publicity

This procedure is published on the CfA website.  The Procedure is accessible to our program recipients through our visiting medical volunteers, our regular medical visits, in country clinics, staff and service partners, who all easy access to the complaints management procedures of CfA via the website.

Where literacy is a constraint CfA representatives invite expressions of concern and complaint to be given orally.  Care is taken to give this invitation in a way that is culturally appropriate recognizing that in some cultures people require greater encouragement to make a complaint.  CfA representatives take special care to facilitate complaints from vulnerable populations including children and marginalised groups.

4. Where and How Complaints May Be Made

It is hoped that most complaints or concerns about CfA’s work or behavior can and will be dealt with informally by staff or volunteers at a local level.

CfA is able to receive complaints orally in person or by telephone and in writing by post or email.  Where complaints are made orally we will ensure our write up of the complaint contains all the information the complainant wishes to provide.

A friend or advocate of the complainant on their behalf may make complaints.

Where appropriate we may establish complaint committees involving representatives from partner organisations and members of communities CfA is serving.

Where appropriate we may utilize complaint/suggestion boxes.  We recognize that in some circumstances complainants may wish to remain anonymous.  Because such complaints can alert us to problems that need fixing we will accept them tough clearly it may not be possible to provide a remedy to an individual.

Formal complaints should be made in writing either directly from the individual or organisation making the complaint or via someone acting on their behalf.

A complaint may be made via email (diana@careforafrica.org.au) or in writing to

Chief Executive Officer (or other members of the Board of Management)

5. How Complaints Will Be Handled

When we take an oral complaint we will:

  • Identify ourselves, listen, record details, and determine what the complainant wants;
  • Confirm that we have understood and received the details;
  • Show empathy for the complainant, but not attempt to take sides, lay blame, or become defensive.

For all complaints we will:

  • Seek from the complainant the outcome/s they are expecting;
  • Make an initial assessment of the severity of the complaint and the urgency of action;
  • Clearly explain to the complainant the course of action that will follow:

if the complaint is out of our jurisdiction;

if we may exercise a discretion not to investigate;

if preliminary enquiries need to be made, or further consideration needs to be given; or

if the complaint is to be investigated.

  • We will not create false expectations, but assure the complainant that the complaint will receive full attention;
  • Give an estimated timeframe or, if that is not possible, a date by which we will contact them again;
  • Check whether the complainant is satisfied with the proposed action and, if not, advise them of alternatives;
  • Ensure that the complaint is appropriately acknowledged;
  • Follow up where necessary, and monitor whether the complainant is satisfied;
  • We will register all complaints (in an electronic Complaints File).

Where appropriate we will ensure that the personnel working in communities we serve have all necessary training to encourage and handle inquiries, expressions of concern and making of complaints so as to take account of cultural and gender sensitivities and to ensure that cases involving children are appropriately handled.

We will ensure that a complainant is not required to express their complaint to a person implicated in their complaint.  We will also ensure that a person implicated in a complaint is not involved in any way with the handling of that complaint.

6. Initial Assessment of Complaint

We will first assess whether there is more than one issue raised in the complaint and whether each needs to be separately addressed.

To determine how a complaint should be managed, we will assess it in terms of the following criteria:

  • severity;
  • health (including mental health) and safety implications;
  • financial implications for the complainant or others;
  • complexity;
  • impact on the individual, public and organisation;
  • potential to escalate;
  • systemic implications; and
  • the need for, and possibility of immediate action.

If we assess the complaint as significant in terms of one or more of the above criteria we will classify the complaint accordingly.

7. Inquiries, Minor Complaints, Proper Complaints and Jurisdiction

Determining whether or note a complaint should be investigated is often not easy.  It could be:

  • Based on a misunderstanding or insufficient information it might be that provision of information immediately satisfies the complainant and thus the complainant becomes an inquirer and the complaint can be recorded as an inquiry.
  • Frivolous or capricious.  With care it ought to be possible to negotiate its early withdrawal.
  • Vexatious, that is it is made without sufficient grounds or it is not necessary for the pursuit of a legitimate end, but is made with the intention, or inevitable effect, of causing distress trouble and annoyance to the person or body who has to deal with it.  Again careful negotiation at the outset might achieve withdrawal, but often it will be necessary to take the matter further and ultimately refer it to the external complaint entity that is the ACFID’s Code Committee (https://acfid.asn.au/about/_code-conduct-commmittee)
  • Outside the jurisdiction of CfA perhaps because it relates to the actions of another organisation or an individual who is unconnected with CfA.  It might concern a matter that must be dealt with by the police or other authority of the relevant state and thus the obligation is to notify the police or relevant authority.  Such notifiable matters include those that appear to involve criminal offences eg assault, sexual or otherwise, theft and severe damage to property.  Civil matters such as defamation may also be outside jurisdiction.

7.1 Inquiries, Minor Complaints and Jurisdiction

We will endeavour to deal immediately with inquiries and minor complaints that are made orally by telephone or in person, that is during the initial phone call or meeting.  However, as fare as possible, we will ensure that the inquirer or complainant is completely satisfied with the information and or resolution provided.

On receipt of a complaint we will also attempt to determine expeditiously whether investigation is required or not depending on jurisdictional questions and whether the complaint is ill conceived.

If the complainant disputes an assessment that a complain should not be investigated the CfA representative handling the complaint will refer it to the CEO or Chair of the Board of Management.  If such a dispute is unresolvable we will refer the complainant to Code Committee of the Australian Council for International Development (ACFID).

8. How We Will Investigate Complaints

We will make ever reasonable effort to investigate all the relevant circumstances and information surrounding a complaint.  The level of investigation will be commensurate with the seriousness and frequency of the complaint.

9. Our Timeframes

We will acknowledge written complaints within 2 days and will acknowledge oral complaints immediately.

We will aim to resolve complaints as quickly as possible and within 7 days unless there are exceptional circumstances.  If a complaint is not resolved within 14 days we will inform the complainant of progress and keep them informed of progress every two weeks.

10. How We Will Respond To and Close a Complaint

Our CEO or delegate (eg medical trip team leader) will normally make the decision on a complaint that has required investigation (that is not a minor complaint).  Decisions on serious complaints may be referred to our Board of Management.

We will communicate our decision on a complaint as soon as is practical.  Our communication will be in writing by email/or post.  However, where appropriate such as in the case of a complaint being made by a local community member (in the field) we will also communicate our decision orally in the appropriate language.

We will encourage the complainant to respond and advise whether or not they are satisfied with our decision.  In our decision we will advise that if a complainant is not satisfied we will be prepared to consider any additional information they may provide and to review our decision.

I all cases we will advise that the complaint may be referred to the Code Committee of ACFID.

We will provide all necessary information for referral to the Code Committee and offer to assist in referral

11. How We Will Learn From Complaints

We will ensure that all relevant personnel are informed of the outcomes of complaints and the implications for our services, goods, procedures and processes.

We will take all required remedial action.  We will be prepared to change the way in which we operate and improve or undertake further training of staff.  Where needed we will counsel or discipline staff or volunteers.

Where appropriate we will consult and take advice from ACFID and/or other relevant regulatory/enforcement authorities.

12. Confidentiality

Good record keeping is essential to effective handling of complaints, but also to gather information for good management of the organisation generally especially so as to indicate where systemic problems might be occurring.

We will not reveal a complainant’s name or personal details to anyone in or outside our organisation other than CEO or delegate involved in handling the complaint without obtaining the complainant’s permission.

13. Complaint Data

We will register all inquiries and complaints.  We will ensure that the following information is contained in written complaints and if not, and in the case of oral complaints, record this information ourselves:

  • date of receipt
  • a description of the complaint and relevant supporting data
  • the requested remedy
  • the service(s) and/or good(s) and/or practice or procedure complained about; and
  • the due date for a response or immediate action taken, if any, to resolve the complaint.

14. Reporting about Complaints

All complaints will be reported at our monthly Board of Management meetings.

Minor complaints will be reported in summary form.  Major complaints will be reported in detail.  An analysis will be included in the complaints report provided with the complaints data.

Our Annual Report will provide de-identified information on complaints.

15. Continuous Improvement

On a continuing basis we will monitor the effectiveness of our complaint handling and make improvements as appropriate.  We will:

  • maintain data collection on complaints for the purpose of identifying trends for the purpose of enhancing information management and service provided;
  • keep abreast of best practices (both locally and overseas) regarding complaint handling;
  • undertake specific training and retraining of staff and volunteers to foster better complaint handling practices;
  • encourage innovation in complaint handling development; and
  • recognize and reward exemplary complaint handling behavior.

We will conduct an internal review of the effectiveness of our complaint handling every year.

We will commission an independent review of the effectiveness of our complaint handling processes as part of overall compliance reviews every 3 years.

16. References

https://acfid.asn.au/sites/site/acfid/files/resource_document/Complaints-Handling-Policy-Guidelines-and-Template.pdf

17. Associated documents

CFA-P5.V2  Internal Complaints Handling Procedure –
Effective Date: 7 August 2020 Document

Approved By: Board of Management.

Controlled Document — Printed Versions are not controlled. CFA