Complaints Handling Policy and Procedure
WHO IS THIS COMPLAINTS PROCEDURE FOR?
Glasgow Cognitive Therapy Centre (GCTC) is primarily a training institution, but it also hires out consulting rooms to its own directors, tutors and supervisors and other independent therapists.
This complaints procedure is not applicable to clients who may wish to complain about their therapist. If such clients have complaints to make they must make these directly to COSCA, BABCP or to BABCP whichever is the individual therapist regulating body. (addresses supplied). This procedure is for students on courses run by the organization.
Glasgow Cognitive Therapy Centre (GCTC) is committed to providing high quality services to our students from enrolment to graduation. We value complaints and use information from them to help us improve our services. If something goes wrong or you are dissatisfied, as a student, with our services, please tell us. This document describes our complaints procedure and how to make a complaint. It also tells you about how we will handle your complaint, and what you can expect from us. A copy of this document is posted on GCTCs website under the heading ‘Complaints Procedure’.
WHAT IS A COMPLAINT? AND WHAT CAN I COMPLAIN ABOUT?
We regard a complaint as any expression of dissatisfaction about our action or lack of action, or about the standard of service provided by us or on our behalf.
You can complain about things such as:
- The quality and standard of any service we provide whether by members of staff or by volunteers.
- The quality of facilities and learning resources.
- The quality and standards of academic services and personal support services available to you.
- The quality and standards of administrative processes.
- Unfair treatment by a student or staff member.
- Your complaint may involve more than one of GCTC’s services or be about someone working directly on its behalf.
WHAT CAN I NOT COMPLAIN ABOUT?
There are some things we cannot deal with through our complaints handling procedure. These include:
- A routine first-time request for a service
- A request for information or an explanation of policy or practice
- A request under freedom of information or data protection legislation
- Requests for compensation from GCTC.
- Things that are covered by academic appeals, such as academic judgements and decisions.
- An issue which is being, or has been, considered by a court or tribunal.
- An attempt to reopen a previously concluded complaint or to have a complaint reconsidered where we have already given our final decision following an investigation.
If other procedures or rights of appeal can help you resolve your concerns, we will give information and advice to help you.
WHO CAN COMPLAIN?
Anyone who receives, requests or is directly affected by the services of GCTC can make a complaint, including the representative of someone who is dissatisfied with our service. If you are making a complaint on someone else’s behalf you will need their personal written consent.
HOW DO I COMPLAIN?
You can complain in person, by phone, in writing, or by email and it is easier for us to resolve complaints if you make them quickly and directly to the service concerned. So please talk to a member of GCTC who can try to resolve any problems on the spot. If you are not satisfied after that, your complaint can only be formally dealt with when it is made in writing. Assistance with that may be accessed through the administration desk opposite the entrance.
When complaining, tell us:
- Your full name and address.
- As much as you can about the complaint.
- What has gone wrong.
- How you want us to resolve the matter.
THIRD PARTY AND ANONYMOUS COMPLAINTS
Complaints by third parties or representatives will not be accepted unless they have the agreement and written consent of the complainant to lodge them.
‘Anonymous’ complaints cannot be processed unless they are made with full personal details of the complainant to our independent complaints manager.
- If you are unable to present a complaint in writing the external complaints manager should be approached for advice about assistance
- If necessary, the external complaints manager may be able to supply advice about organisations able to offer external advocacy
We are committed to making our service easy to use for all students. In line with our statutory equalities duties, we will always ensure that reasonable adjustments are made to help you access and use our services. If you have trouble putting your complaint in writing, or want this information in another language or format, such as large font, or Braille, please tell us in person, contact us on 0141 332 0229 or email us at email@example.com
HOW LONG DO I HAVE TO MAKE A COMPLAINT?
Normally, you must make your complaint within a year of:
- Finding out that you have a reason to complain
- he event you want to complain about, or claim to be a breach of COSCA’s Statement of Ethics and Code of Practice which can be accessed in COSCA’s website (address supplied)
In exceptional circumstances, we may be able to accept a complaint after the time limit. If you feel that the time limit should not apply to your complaint, please tell us why.
GCTC will endeavour to address all complaints within three years of the event complained about.
INVESTIGATING AND RESOLVING THE COMPLAINT ONCE IT HAS BEEN MADE
What happens when I have complained?
Our complaints procedure has two stages and throughout any process complete confidentiality will, as far as possible be upheld.
Stage one: informal frontline resolution
GCTC encourages complaint resolution as soon as possible and as near to the source as possible, i.e. with the counsellor, supervisor or tutor, trainer or Director involved, and aims to resolve complaints quickly and close to where we provided the service. Advice should first be sought informally, face to face, by phone, in writing or by email with the director Mrs Heather Davis. This could mean a speedy apology and explanation if something has clearly gone wrong, and immediate action to resolve the problem. This could result in resolution within five working days unless there are exceptional circumstances, but you may choose to bypass this stage, in which case the complaint moves on to formal investigation.
Stage two: Formal investigation
The complainant should write to the Director (see details above) to ask for a formal investigation or he or she will be informed that GCTC wishes this to take place.
Investigation of the complaint will usually be undertaken by the Director or by an associate appointed by them, provided that they have no conflict of interest in the process. The investigating director will acknowledge your complaint and discuss your complaint with you within seven working days and following that you will be told what is proposed to be done about it and what the estimated timetable of stages is likely to be.
If the complaint is unusually complex or raises a wider complex problem within GCTC the directors may appoint an ad hoc panel of experienced individuals with no conflicts of interest in the proceedings and assembled for the purpose of investigation and resolution and both you as the complainant and anyone complained about will be notified of this in writing, by telephone or by email.
All parties involved in the stage two process will declare any conflict of interest to the investigators and will ensure that the complainant and the complained against and/or their representative will not come into contact at any time in the process of the investigation. At some point or at several points the complainant or their representative will have the right to access the principal investigator or meet with the complaints panel and be accompanied by a supporter of their choice.
Both the complainant and the complained-against will be informed regularly of progress and of the estimated time of resolution. All efforts will be made to produce a final resolution within 21 days unless the circumstances of the complaint emerge as unusually complex. Throughout we will agree revised time limits with you and keep you updated on progress and if our investigation will take longer than 21 working days, we will tell you. The maximum time to be taken for any investigation or decision will be six months.
It should be noted that the complaints manager (Director) can halt the complaints process at any stage should it emerge that legal action is underway.
Within 28 days or receiving notification of the completion of stage 2, an appeal can be made by any party involved, the complainant, the complained against, any participant in the investigation or any external supporter of these to the GCTCs independent complaints person and it will be his/her decision as to whether and when it will be heard. The independent complaints person will consider the information already gathered and the reported findings; will decide if further investigation is necessary and will report back their findings to the complainant within 21 days. Thereafter a complainant has 28 days
The independent complaints person cannot normally look at:
- A complaint that has not completed our complaints procedure (so please make sure it has done so before advancing complaints to this stage)
- Events that happened, or that you became aware of, more than a year ago.
- A matter that has been or is being considered in a court or tribunal.
CARRYING YOUR COMPLAINT TO AN EXTERNAL PROFESSIONAL BODY
Finally, if this does not meet with satisfaction you are advised that you can submit a complaint to COSCA under its Complaints Procedure.
Whenever there has been a formal complaint an Outcome Report will be sent by GCTC to COSCA and COSCA will verify that the GCTC’s complaints procedure has been followed and that the outcome is lawful, reasonable and properly explained (see 1.22 in COSCA’s complaints procedure, accessible on its website). The Outcome Report will be sent within 28 days.
OUTCOME OF SUCCESSFUL COMPLAINT
Should the complaint be upheld there are various sanctions that can be applied.
If the complaint is about course procedures not being followed then this will be rectified immediately by the Directors who will offer a written apology and take steps to ensure procedures are adhered to. If there are personal complaints re tutors that are upheld the steps taken will reflect the issues complained about. These could range from a written apology to removal of that tutor/supervisor from teaching/ supervision. Such sanctions will be applied by the Directors who will also monitor the implementation of the sanctions by formally putting such sanctions on their regular meeting agendas on a monthly basis. When the sanctions are completed this will be communicated in writing to the complainant, and the complained against.
UNREASONABLE COMPLAINANT BEHAVIOUR
GCTC believes that complainants have a right to be heard, understood and respected.
People may act out of character in times of trouble or distress. There may have been upsetting or distressing circumstances leading up to a complaint coming to GCTC. We do not view behaviour as unreasonable just because a complainant is forceful or determined. However, we do consider behaviour that results in unreasonable demands on GCTC or unreasonable behaviour towards staff to be unacceptable.
Occasionally, the behaviour of individuals using any Complaints Procedure may make it very difficult for the receiving organisation to deal with their complaint. In a very small number of cases, the behaviour becomes unacceptable because it involves abuse of staff or processes. When this happens the organisation complained against may have to take action to protect its staff. We consider the impact of the behaviour on our ability to do our work and provide a service to others.
Aggressive or abusive behaviour
We understand that complainants may be angry about the issues they have raised in their complaint. If that anger escalates into aggression towards GCTC’s staff, we consider that unacceptable. Any violence or abuse towards staff will not be accepted. Violence is not restricted to acts of aggression that may result in physical harm. It also includes behaviour or language, whether verbal or written, that may cause staff to feel afraid, threatened or abused, and may include threats, personal verbal abuse, derogatory remarks or rudeness. We also consider inflammatory statements and unsubstantiated allegations to be abusive behaviour.
A demand becomes unreasonable when complying with the demand starts to, would, or is likely to, impact substantially on the work of staff investigating a complaint. Examples of behaviour under this heading include:
- Repeatedly demanding responses within an unreasonable timescale.
- Insisting on seeing or speaking to a particular member of staff when that is not possible or necessary.
- Repeatedly changing the substance of a complaint or raising unrelated concerns.
- An example of such impact would be that the demand takes up an excessive amount of staff time and, in so doing, disadvantages others.
Unreasonable levels of contact
Sometimes the volume and duration of contact made to complaint investigators by an individual causes problems. This can occur over a short period: for example, a number of calls in one day or one hour. It may occur over the life-span of a complaint when a complainant repeatedly makes long telephone calls to GCTC or inundates GCTC with copies of information that have been sent already or that are irrelevant to the complaint.
We consider that the level of contact has become unreasonable when the amount of time spent talking to a complainant on the telephone, or responding to, reviewing and filing emails or written correspondence impacts on our ability to deal with that complaint, or with requests for support from others.
Unreasonable use of the complaints process
Individuals with complaints about GCTC have the right to pursue their concerns through a range of means. They also have the right to complain more than once about GCTC if subsequent incidents occur. However, this contact becomes unreasonable when the effect of the repeated complaints is to harass, or to prevent GCTC from pursuing a legitimate aim or implementing a legitimate decision. We consider access to GCTC’s complaints system to be important and it would only be in exceptional circumstances that we would consider such repeated use as unreasonable – but we reserve the right to do so in those exceptional cases.
Managing unreasonable complainant behaviour
The threat or use of physical violence, verbal abuse or harassment towards GCTC staff is likely to result in a termination of all direct contact with the complainant. Incidents may be reported to the police. This will always be the case if physical violence is used or threatened. We will not accept any correspondence that is abusive to staff or contains allegations that lack substantive evidence. We will tell the complainant that we consider their language offensive, unnecessary and unhelpful and ask them to stop using such language. We will state that we will not respond to their correspondence if the action or behaviour continues. GCTC staff will end telephone calls if they consider the caller aggressive, abusive or offensive. GCTC staff have the right to make this decision, to tell the caller that their behaviour is unacceptable and end the call if the behaviour persists. In extreme situations, we will tell the complainant in writing that their name has been placed on a ‘no personal contact’ list. This means that we will limit contact with them to either written communication or through a third party.
Where a complainant repeatedly phones, visits, raises repeated issues, or sends large numbers of documents where their relevance is not clear, we may decide to:
- Limit contact to telephone calls from the complainant at set times on set days.
- Restrict contact to a nominated member of staff who will deal with future calls or correspondence from the complainant.
- See the complainant by appointment only.
- Restrict contact from the complainant to writing only.
- Return any documents to the complainant or, in extreme cases, advise the complainant that further irrelevant documents will be destroyed.
- Take any other action that we consider appropriate.
Where we consider continued correspondence on a wide range of issues to be excessive, we may tell the complainant that only a certain number of issues will be considered in a given period and we may ask them to limit or focus their requests accordingly. In exceptional cases, we reserve the right to refuse to consider a complaint or future complaints from an individual. We will take into account the impact on the individual and also whether there would be a broader public interest in considering the complaint further.
We will always tell the complainant what action we are taking and why.
Any member of staff who directly experiences aggressive or abusive behaviour from a complainant has the authority to deal immediately with that behaviour in a manner they consider appropriate to the situation and in line with this policy. With the exception of such immediate decisions taken at the time of an incident, decisions to restrict contact with GCTC are only taken after careful consideration of the situation and evidence by one of the Directors. Wherever possible, we will give a complainant the opportunity to change their behaviour or action before a decision is taken.
Informing the complainant
When a staff member makes an immediate decision in response to aggressive or abusive behaviour, the complainant is advised at the time of the incident. When a decision has been made by the relevant Director or Complaints Officer, a complainant will be told in writing why a decision has been made to restrict future contact, the restricted contact arrangements and, if relevant, the length of time that these restrictions will be in place. This ensures that the complainant has a record of the decision.
Recording and reviewing decisions
We record all incidents of unacceptable actions by complainants. Where it is decided to restrict complainant contact, an entry noting this is made in the relevant file. A decision to restrict complainant contact as described above may be reconsidered if the complainant demonstrates a more acceptable approach. The relevant Director will review the status of all complainants with restricted contact arrangements on a regular basis.
If you remain dissatisfied with the resolution offered to you after completion of the second stage of our complaints procedure a different director (who was no part of the conduct of the second stage) will discuss your complaint with you to understand why you remain dissatisfied and what outcome you are looking for.
VARIATIONS TO THIS POLICY
GCTC reserves the right to terminate, replace, or vary this procedure.
The Complaints Handling Policy will be included in the student handbook and will be communicated to students as part of the induction process.
COSCA’S COMPLAINT PROCEDURE
A copy of COSCA’S complaint procedure can be provided on request and found on the COSCA website via the following link:
The Independent Complaints Officer is
16 Melville Terrace
t: 01786 475 140 f: 01786 446 207
15 St John’s Business Park