Complaints Handling Policy

1. Policy Statement

  1. This policy is to ensure Camp Quality handles complaints fairly, efficiently and effectively, to prevent or reduce harm to personnel and stakeholders, including children and young people.
  2. This policy also provides guidance to employees, volunteers and people wanting to make a complaint, about the key principles and concepts of Camp Quality’s complaint management systems.
  3. The effective handling of complaints and includes:
    1. responding to the immediate needs of individuals involved (including the complainant) and taking any immediate action necessary;
    2. communicating with the complainant, clients, employees, volunteers, carers, advocates, service providers and others, as appropriate, and in a timely manner;
    3. reviewing relevant information arising from complaints to identify any trends, lessons and opportunities for process improvement;
    4. undertaking any investigations in a timely and efficient manner;
    5. notifying external authorities, where required;
    6. generating and implementing improvement strategies and action plans; and
    7. monitoring and reviewing the effectiveness of actions taken.

2. Definitions

  1. Complaint: an expression of dissatisfaction made to or about Camp Quality, its services, events, employees, volunteers or the handling of a complaint; where a response or resolution is explicitly or implicitly expected or legally required. Complaints may be made directly to Camp Quality and include complaints or negative comments made on social media.
  2. Complaint handling/management system: all policies, procedures, practices, personnel, and software / platforms used by Camp Quality to handle complaints.
  3. Dispute: an unresolved complaint escalated internally or externally.
  4. Feedback: opinions, comments and expressions of interest or concern, made directly or indirectly, explicitly or implicitly, to or about Camp Quality, regarding our services or complaint handling system; where a response is not explicitly or implicitly expected or legally required.
  5. Grievance: any expression of a problem or concern related to an employee’s or volunteer’s work, or the work environment. A personal complaint or grievance can be about any act, behaviour, omission, situation or decision impacting an individual, who thinks it is unfair or unjustified. It can relate to any aspect of:
    1. the working environment;
    2. employment or engagement conditions;
    3. treatment by peers / colleagues; or
    4. any other workplace related issue.
  6. Risk Register: a record of identified risks through a process of identification, assessment and rating.

3. Roles and Responsibilities

  1. Executive/General Managers
    • Support the reporting, investigation, and management of complaints.
  2. General Manager – Finance and Operations
    • Oversee the Complaint Management Policy and process.
  3. Risk, Safety and Compliance Manager
    • Oversee any related complaints and investigations.
    • Supports the notification of any external authorities.
    • Reports internally all complaints as appropriate.
  4. Direct Line Manager
    • Support all employees and volunteers in reporting complaints
  5. Employees and Volunteers
    • Reads and understands the Policy.
    • Completes any training offered in relation to the Policy.
    • Supports any investigations resulting from the application of this Policy.

4. Policy Practice and Procedure

  1. Prevention and preparedness
    1. Identified managers will undertake a risk assessment to identify and assess potential risks in programs, events and other activities and to develop and implement risk mitigation strategies addressing those risks to decrease the likelihood of complaints.
  2. Facilitate Complaints
    1. Camp Quality is committed to seeking and receiving feedback and complaints about its services, systems, practices, procedures, products, complaint handling or any incident pertaining to same.
    2. Any identified incidents, concerns raised in feedback or complaints will be reviewed and responded to within a reasonable time frame.
    3. Complainants will be:
      • provided with a copy of this policy;
      • listened to, treated with respect and involved in the complaint process, where appropriate; and
      • provided with reasons for the decision(s) and any options for review or redress.
    4. All reasonable steps will be taken to ensure complainants are not adversely affected because a complaint has been made by them, or on their behalf.
  3. Anonymous Complaints
    1. Anonymous complaints are accepted and investigated where there is a compelling reason and enough information available.
    2. We will ensure that information about how and where complaints may be made to or about us, is well publicised.
    3. We will ensure that our systems to manage complaints are easily understood and accessible to everyone, particularly people who may require assistance.
    4. If a complainant 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. Anyone may represent a complainant, with their consent.
  4. Immediate Response
    1. Immediate responses include the care, support and communication actions that may take place immediately following a complaint to mitigate harm and ensure the safety of service users, families and personnel.
  5. Reduce harm / risk of harm
    1. Camp Quality will reduce the harm and / or risk of harm to those impacted by the complaint including, if necessary, by:
      • making the environment safe to prevent an immediate recurrence of the complaint, including but not limited to:
      • removing malfunctioning equipment or supplies; and
      • removing potentially harmful person(s); and
      • alerting others to risks that extend beyond the local environment, e.g. other areas within the organisation.
    2. Provide immediate care and support to service users, families, personnel and others involved in the complaint, including addressing emotional wellbeing e.g. arranging coverage of duties and facilitating counselling, debriefing and peer support:
  6. Preliminary assessment and reporting
    • Complaints made during an event, recreation program or service are escalated to the Risk, Safety & Compliance Manager and other appropriate senior managers via the CQ Safe incident management system.
  7. Complaints involving the safety of children and young people
    1. When a complaint involves the safety of children and / or young people, the appropriate manager(s) must:
      • assess and categorise the complaint as insignificant minor, moderate, major or extreme;
      • determine and initiate any immediate response required;
      • place a call to the CQ-Safe hotline (1800 CQsafe) and determine if an external mandatory report is required under the applicable legislation; and
      • follow the further procedure as detailed in the Safeguarding Children and Young People Policy.
    2. External notifications required by organisational policy and / or governing legislation must be initiated in consultation with the Risk, Safety & Compliance Manager. Reports may be required externally to authorities including police, child protection agencies, state-based work health and safety bodies and other state and / or territory departments (see Responding to Suspected Child Abuse Policy for guidance on external notifications).
    3. All complaints requiring external authority notification must be reported to the CEO.
    4. In making the decision to disclose information, the Risk, Safety & Compliance Manager will consider:
      • whether the ongoing safety of those involved in / impacted by the subject matter of the complaint, is compromised by the disclosure or non-disclosure of information;
      • the advice of police and the child protection agency (care will be taken not to compromise their investigations);
      • the rights of those impacted by the subject matter of the complaint, to privacy, confidentiality, procedural fairness and a presumption of innocence in accordance with organisational policies. See Camp Quality’s Privacy Policy, and Safeguarding Children and Young People Policy; and
      • the need of those potentially impacted by the subject matter of the complaint to know of the incident.
  8. Making or recording of a complaint
    1. Complaints regarding employees
      • Discuss the complaint with People and Culture.
      • Do not discuss the complaint with any other party, unless otherwise directed by People and Culture.
    2. complaints regarding non-employees
      • If an employee member receives a complaint, from someone other than an employee, they should enter it into Camp Quality’s CQ Safe Incident Management System as soon as possible.
      • The Incident Management System is maintained by the Risk, Safety & Compliance Manager who is responsible for reporting to the CEO, The Risk & Safety Committee and the Board (where appropriate) concerning all entries in the system.
      • Where appropriate, details of the matter / the subject of the complaint should also be recorded in the appropriate volunteer, contractor or family file.
    3. complaints made by external parties
      • People external to Camp Quality can make a complaint using Camp Quality’s online form at www.campquality.org.au/contact
  9. Responsiveness
    1. we will promptly acknowledge receipt of complaints
    2. We will assess and prioritise complaints according to their urgency and/or seriousness of the issues raised. If there is an immediate risk to safety or security the response will be immediate and will be escalated appropriately.
    3. We are committed to managing complainants’ expectations, and will inform them as soon as possible, of the complaints process; the expected process time frames; the
      progress of the complaint, including reasons for any delay; their involvement in the process; and the potential outcomes of their complaint.
    4. We will advise complainants as soon as possible when Camp Quality is 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).
  10. Objectivity and fairness
    1. We will address each complaint with integrity and in an equitable, objective and unbiased manner ensuring that the person handling a complaint is different from any staff member whose conduct or service is being complained about. Conflicts of interest, whether actual or perceived, will be managed responsibly.
  11. Responding early and flexibly
    1. Our employees are empowered to resolve smaller, simpler complaints promptly and with as little formality as possible. Camp Quality assesses complaints on its merits and involves complainants and / or their representatives in the process where possible.
    2. Where possible, complaints will be resolved at first contact with Camp Quality. When appropriate Camp Quality may offer an explanation, or apology to the complainant.
  12. Confidentiality
    1. Camp Quality protects the identity of complainants where this is practical and appropriate.
    2. Personal information identifying individuals will only be disclosed, or used by Camp Quality, as permitted under the relevant privacy laws, secrecy provisions and any relevant confidentiality obligations in accordance with Camp Quality’s Privacy Policy.
  13. Manage the parties to a complaint
    1. Complaints involving multiple agencies
      • Where a complaint involves multiple organisations, we will work with the other organisation/ s where possible, to ensure that communication with the complainant 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 Camp Quality, responsibility for communicating with the complainant and / or their representative will also be coordinated.
      • Where Camp Quality’s services are contracted out, contracted service providers must have an accessible and comprehensive complaint management system.
    2. Empowerment of employees
      • All employees f managing complaints are empowered to implement our complaint management system as relevant to their role and responsibilities.
      • Employees are encouraged to provide feedback on the effectiveness and efficiency of all aspects of our complaint management system.
    3. Managing unreasonable conduct by people making complaints
      • Camp Quality is committed to being accessible and responsive to all people who provide feedback or complaints.
        When complainants behave unreasonably, Camp Quality will take proactive and decisive action to manage any negative or unreasonable conduct. This includes supporting Camp Quality personnel to do the same in accordance with this policy.
    4. Alternative avenues for dealing with complaints
      • Camp Quality will inform complainants about any internal or external review options available to them (including any relevant Ombudsman or oversight regulatory bodies).
    5. Criminal acts and serious misconduct
      • Suspected criminal activity and serious misconduct of personnel is reported immediately to Camp Quality’s CEO.
      • If, while categorising or reviewing the matter, the subject of the complaint is suspected to be: involved with criminal acts, the Risk, Safety and Compliance Manger will refer the matter to the appropriate external body (i.e. police / child protection agency). The investigation of the matter may continue separately to any criminal / child protection investigation. however it may be appropriate to suspend the investigation
      • If the matter contains elements of misconduct, the Risk, Safety and Compliance Manager should refer the matter to the General Manager – People and Culture, so it can be addressed using the appropriate processes.
  14. Accountability
    1. Analysis and evaluation of complaints
      • Camp Quality ensures complaints are recorded in a systematic way so that information can be easily retrieved for reporting and analysis by management and the Board.
      • Regular analysis of these reports will be undertaken to monitor trends, measure the quality of our customer service and make improvements with both the reports and their analysis provided to the CEO, senior management and to our Board for review, at least annually.
    2. Monitoring of the complaint management system
      • Camp Quality continually monitors its complaint management system to ensure effectiveness in responding to and resolving complaints and to identify and correct deficiencies in the operation of the system.
      • All complaints recorded in the CQ Safe Incident Management System are reviewed weekly by the Incident Management team to ensure the effectiveness of actions taken and to identify areas for improvement.
      • Complaints are not closed until actions have been reviewed by the Incident Management Team and persons reporting the incident have been informed of the outcome.
    3. Communication
      • The Complaint Handling Policy is communicated to and accessible by all employees. Any significant alterations to the complaint handling requirements and resources will be communicated to all personnel.
    4. Monitoring and review
      • This policy is reviewed every three years, some circumstances may trigger an early review, this includes but not limited to legislative changes, organisational changes, incident outcomes and other matters deemed appropriate by the CEO.
      • Records are retained to document each review undertaken. Such records may include minutes of meetings and documentation of changes to policies and procedures that result from a review.

 

Updated July 2024