Customer feedback policy

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Title	Customer Feedback Policy 2019
Author	Customer and Local Services LF
Document	Policy
Review date	4 February 2022
Version	1.6

Introduction

The Government of Jersey is committed to providing high standards of service to the people of Jersey. We aim to deliver quality services with consistency and to provide the public with easy to use, efficient systems and processes that meet our customer's needs.

Historically departments have adopted different processess for measuring varying levels of success when dealing with feedback from customers on how we are performing. This has resulted in a fragmented and inconsistent response to our customers’ feedback. It has made it difficult to provide joined up responses, resolution and service improvements as a result.

As part of the One Government approach, we are modernising services to meet long-term goals and put customers at the heart of what we do. This Customer Feedback Policy sets out how all customers and members of the public (including children, young people and people that require additional assistance) can express their views about how our services are provided.

We welcome the feedback of all islanders who come into contact with services run by the Government and want to understand the experiences they have. This may be in the form of a complaint, compliment, suggestion or comment.

The Government of Jersey will use all types of feedback to learn about customers’ experiences of the services provided and continually strive to improve them.

Purpose

The purpose of this policy is to:

document the position of the organisation in relation to the management of customer feedback
make it easy for customers to provide feedback
support a simple and consistent approach to complaint handling as part of the One Gov initiative
ensure that complaints are dealt with in a fair, unbiased, timely and confidential manner
enable the organisation to use the insight received to understand the needs of our customers and improve service, satisfaction and performance.

Scope

This policy applies to all customer feedback received across the Government of Jersey. It applies to all employees, agency workers, contractors and volunteers in relation to feedback about services provided to our customers.

This policy covers comments, suggestions, compliments or complaints about:

the standard of service we provide
how we administer services and the processes we use
the advice we have given
the behaviour of our staff
any action or lack of action by staff affecting a customer or group of customers of the department, and
feedback on policy or Law

This policy does not cover:

feedback about services that were provided over 12 months prior to the feedback being received
staff complaints about interviews
whistleblowing
code of conduct complaints
responses to requests for feedback given as part of a consultation process
requests for information made under the Freedom of Information (Jersey) Law 2011
Subject access requests made under the Data Protection (Jersey) Law 2018
matters that are the subject of current or past legal action
disagreements with decisions where a formal right of review and/ or appeal exists
complaints about General Practitioners
complaints about Crown Officers and complaints about the Law Officers Department
complaints about decisions or conduct of the Viscount, the Deputy Viscount or the Judicial Greffier in the performance of their functions
complaints about States Members or, the Greffier or Deputy Greffier of the States
complaints about the decisions made by, and statutory services provided by the Superintendent Registrar
complaints about States of Jersey police officers and organisational complaints about the States of Jersey Police, and
complaints that fall under the remit of the Health and Safety Inspectorate or Trading Standards

Continuous improvement

As a learning organisation, we are committed to improving effectiveness and efficiency. We want to get it right first time. To this end, we will:

ensure that any actual or proposed improvements to services and programs will be followed up and acted upon
implement appropriate system changes that have been identified by analysis of complaints data and continual monitoring of the system
implement best practices in handling customer feedback
recognise and reward exemplary handling of customer feedback by staff
regularly review the complaints management system and complaint data
listen to people going through the feedback process in order to learn how the customer feedback procedures can be improved, and
learn corporately from customer feedback so that improvements can be made across the whole of Government

Customer feedback process

When responding to feedback, staff should act in accordance with departmental procedures as well as any other internal documents providing guidance on the management of feedback.

Staff should also consider any relevant legislation and/or regulations when responding to feedback.

The five key activities required to manage a complaint are:

listen to feedback
acknowledge feedback
access and investigate
provide reasons for decision
options for resolution and close case

The three levels of complaint handling

Stage 1

Frontline complaint handling and early resolution of complaints.

Timescale: up to 5 working days from the point of escalation.

Stage 2

Escalation to team leader of manager for issues that require further investigation or are complex, serious or high risk.

Timescale: up to 10 working days from the point of escalation.

Stage 3

Escalation to Director General if the issue is still not resolved after stage 2. The Director General can include, or refer the complaint to another Director General or an independent third party, if appropriate.

Timescale: up 10 working days from point of escalation.

Three levels of complaint handling

We will encourage our customers to give feedback to departments, at the point of service. We aim to resolve complaints at the initial point of contact. 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 a Stage 1 complaint to Stage 2 to be investigated by a more senior member of staff within the department. This will increase the timescale for investigation to 10 working days from the date the feedback was escalated.

This does not match the pyramid commentary above-also needs to match with the 25 day commitment below as they should be the same.

Should this happen you will be contacted via your chosen preferred contact method to be made aware of this.

This second level of complaint handling will provide for the following internal mechanisms:

assessment and possible investigation of the complaint and decision/s already made, and/or
facilitated resolution process by request of complainant (where a person not connected with the complaint reviews the matter and attempts to find an outcome acceptable to the relevant parties)

Where a person making a complaint is dissatisfied with the outcome of a Stage 2 review of their complaint, they may seek escalation to the Director General.

The Director General can refer the complaint to another Director General or an independent third party, at stage 3 if it is considered to be more appropriate.

We aim to have all complaints resolved as soon as possible within 25 working days (for the purposes of this policy working days are considered to be Monday to Friday excluding Bank Holidays).

Some complaints (for example, medical and/ or social care complaints in Health & Community Services and children’s social care complaints in Children, Young People and Education Services) can be significantly more complex, requiring a more specialist level of investigation at stage 2 or 3 and therefore take longer to conclude. In these cases the customer must be kept informed of any extended timescales and progress throughout. Specifically for medical and/ or social care complaints in Health & Community Services, stage 3 investigations may be reviewed externally, rather than by the Director General.

Specifically for Education, depending on the nature of the complaint, it may be that the school’s governing body is the appropriate avenue at any stage e.g. to avoid conflict of interest if feedback relates to a head teacher. It will still be necessary to ensure communication with the person giving feedback is maintained at all levels.

If the Government of Jersey complaints process above has been completed and issues have not been resolved to the customer’s satisfaction, the next stage is independent external review by the States of Jersey Complaints Panel.

Managing Customer Feedback

Facilitating feedback

Customer Focus

The Government of Jersey values the feedback given by customers and we are committed to making it easier.

People giving feedback will be:

provided with information about our Customer Feedback Policy
provided with information about how we handle feedback
provided with multiple and accessible ways to give feedback
listened to, treated with respect by staff and actively involved in the process where possible and appropriate
kept up to date, and
provided with reasons for our decision/s and any options for redress or review.

No charge is made for the consideration of complaints.

No detriment to people giving feedback

We will give assurance that people giving feedback are not adversely affected because a complaint has been made by them or on their behalf.

Anonymous feedback

We accept anonymous feedback and will carry out an investigation of the issues raised where there is enough information provided, to inform organisational learning and continuous improvement.

Accessibility

We will ensure that information about how and where feedback can be given 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, including children and young people, and people with disabilities.

If a person prefers or needs another person or organisation to assist or represent them in the giving and/ or resolution of their feedback, we will communicate with them through their representative if this is their wish. Anyone may represent a person wishing to give feedback with their consent (for example, advocate, family member, legal or community representative, States member, or another organisation).

Respond to complaints

Early resolution

Where possible, complaints will be resolved at first point of contact. whether in person at the time of the incident, or when the complaint is made after the event.

In all cases customer’s feedback will still be logged to allow for continuous improvement.

Responsiveness

We will assess and prioritise feedback 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.

You can expect to be contacted regarding your complaint for the following:

an acknowledgment of receipt of your feedback within 2 working days from when it’s logged
when a decision has been made to escalate your complaint to a different stage
if we’re unable to meet the agreed timescales provided at previous contact regarding your case
detailed response addressing all points raised in your feedback

We are committed to managing people’s expectations and our complaints handling policy will be published online. We will inform people making a complaint as soon as possible, of the following:

the complaints process
the expected timeframes for our actions
the progress of the complaint and reasons for any delay
their likely involvement in the process, and
the possible or likely outcome of their complaint.

We will advise customers in the acknowledgement communication 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.

Objectivity and fairness

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.

Responding flexibly

Our staff are supported to resolve complaints as quickly and as simply as possible. We will be flexible in our approach 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.

Confidentiality

We will protect the identity of people giving feedback where this is practical and appropriate.

Personal information that identifies individuals will only be disclosed or used by the Government of Jersey as permitted under the Data Protection (Jersey) Law 2018. Information is only disclosed to those with a demonstrable need to know and/or a legal right to access those records.

Where a complaint is raised by someone other than the service user, consent will be required from the data subject, and information will not be disclosed to the third party until an appropriate consent has been received.

Safeguarding

If at any point there is a safeguarding concern it must investigated as per the Safeguarding Partnership Board Managing Allegations Framework. A safeguarding alert must be raised without delay. Where there is a complaint involving a vulnerable adult or child, the appropriate Safeguarding Manager should be informed and the most appropriate route of investigation agreed, this may not be under the Customer Feedback Policy.

Manage the parties to a complaint

Complaints being made on behalf of somebody else

Complaints can be made by a representative if the customer has given their consent.

Consent is not required if a complaint is being made in the name of:

a deceased person
someone who lacks the capacity to make their own decisions
a non-Gillick competent child

Where consent is given by a person who has capacity, the person giving the consent must be informed that:

all records held in the relevant department/s may be accessed in order to find relevant information for the complaint
relevant information from their records will be accessed by people investigating their complaint
where a complaint refers to Health and Community Services, relevant information from their records may be shared with clinicians and others not directly involved in their treatment
information may be shared across the Government of Jersey as part of the process
information relating to the complaint will not be added to their record and there will be no impact on services

Complaints involving multiple departments

Where a complaint involves multiple departments, or areas within a department, we will work to ensure that communication with the person making a complaint and/or their representative is clear and coordinated. The person making the complaint will have a single point of contact, who will manage communications about the complaint.

Subject to privacy and confidentiality considerations, communication and information sharing between the parties will also be organised to facilitate a timely response to the complainant.

Where our services are contracted out, we expect contracted service providers to have an accessible and comprehensive complaint management process. Contractors should be able to demonstrate that they have an appropriate process in place. We take complaints not only about the actions of our staff but also the actions of service providers.

Complaints involving multiple parties

When similar complaints are made by related parties we will try to arrange to communicate with a single representative of the group if possible subject to privacy and confidentiality considerations.

Managing unreasonable conduct by people giving feedback

We are committed to being accessible and responsive to all people who approach us with feedback. At the same time our success depends on:

our ability to do our work and perform our functions in the most effective and efficient way possible
the health, safety and security of our staff, and
our ability to allocate our resources fairly across all the feedback we receive.

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 refer to the relevant department’s procedure arising from this policy.

Unreasonably persistent behaviour

Behaviour may be deemed to be unreasonably persistent where previous or current contact with the complainant shows that they meet two or more of the following criteria:

Refusing to specify the grounds of a complaint, despite offers of help
Refusing to cooperate with the complaint investigation process
Refusing to accept that certain issues are not within the scope of the complaints procedure
Insisting on the complaint being dealt with in ways which are incompatible with the adopted complaints procedure or with good practice
Making unjustified complaints about staff who are trying to deal with the issues, and seeking to have them replaced
Changing the basis of the complaint as the investigation proceeds
Denying or changing statements that were made at an earlier stage
Introducing trivial or irrelevant new information at a later stage
Raising many detailed but unimportant questions, that detract from or delay the complaints resolution process, and insisting they are all answered
Submitting falsified documents from themselves or others
Adopting a 'scatter gun' approach: pursuing parallel complaints on the same issue with various departments or sections
Making excessive demands on the time and resources of staff with lengthy phone calls, emails to numerous government staff, or detailed letters every few days, and expecting immediate responses
Submitting repeat complaints with minor additions/variations where the complainant insists make these 'new' complaints, or
Refusing to accept the decision; repeatedly arguing points with no new evidence.

Before deciding that a behaviour is unreasonably persistent it must be identified that:

the complaint is being or has been investigated properly
any decision reached is the right one
communications with the complainant have been adequate, and
the complainant is not providing any significant new information that might affect the organisation’s view on the complaint.

Where it is recognised that a complaint is vexatious this will be escalated to Director level, and a plan agreed to manage future contacts with the complainant.

Managing complaints about staff behaviour

The Departmental Officer against whom the complaint has been made has the right to:

Assemble sufficient detail about the complaint to enable the officer to properly respond to the complaint
Place all relevant material before the Manager/Director/reviewer investigating the complaint
Provide oral and/or written submissions regarding the complaint
Be informed of the decision and the reason for the decision
Have individual support as appropriate to manage their wellbeing through the process

If the outcome of an investigation means that disciplinary action is required, managers should refer to the Disciplinary and Human Resources Policies for guidance.

Alternative avenues for dealing with complaints

We will inform people who make complaints to or about us, of any internal or external review options available to them, including the process for taking issues to the States of Jersey Complaints Panel.

States of Jersey Complaints Panel

If a complaint has been through all stages of the customer feedback process and the customer is not satisfied with the outcome the customer has the option to request that the complaint is considered by the States of Jersey Complaints Panel.

The Administrative Decisions (Review) (Jersey) Law 1982 established the States of Jersey Complaints Panel. Its role is to review complaints by members of the public. The complaint may be about any matter of administration by any Minister or Government department, or by any person acting on their behalf.

The basic process for submitting a complaint is as follows:

Customer sends the complaint to the Deputy Greffier of the States
The Deputy Greffier requests a summary of the case from the Minister/department
The Deputy Greffier sends the summary to the Chairman to decide if a hearing should be convened
If it is agreed, a public hearing is held – both the complainant and Minister/department present their case
The findings are presented to the States as a Report.
If the complaint is upheld, recommendations may be made to the Minister concerned and they could be asked to reconsider the original decision

Complaints to professional bodies

If your complaint relates to professional misconduct then the relevant Government Department will be responsible for investigating the allegations made. This may lead to an internal disciplinary investigation into the matter and involvement of one of the professional regulatory bodies.

If a customer wishes to raise a concern about an employee of the Government of Jersey directly, they can write to the appropriate professional or regulatory body to make a complaint. It is the decision of the professional or regulatory body whether to progress the complaint and whether to investigate the matter and what level of investigation is required

A complaint to a professional body can be made even if a complaint is made under the GOJ Complaints Policy. If an investigation has already started under the GOJ Complaints Policy, the professional body may wait for the outcome of this before deciding what action it should take, or the professional body may ask that the GOJ waits for the outcome of the professional body’s investigation.

Withdrawal of complaints

Complaints may be withdrawn orally or in writing at any time. A written record of oral requests will be made.

Taking legal action about a complaint

If, at any stage of the complaints process, the complainant indicates a clear intention to bring legal proceedings, or has instructed legal representation, the use of the Customer Feedback Policy is not necessarily precluded. The Department concerned should liaise with the Head of the Civil Division at the Law Officers Department (or the Legal Services Manager at HCS for clinical negligence or personal injury claims) to determine whether progressing the complaint might prejudice subsequent legal proceedings.

If there is no legal reason why the complaint should not be investigated, the complaint can continue to be investigated under the Customer Feedback Policy.

In cases where there are legal reasons why a complaint should not be dealt with under this policy, the complaint investigation will cease, the complainant advised of this fact and advised to ask their legal representative to contact the Law Officers’ Department or the Legal Services Manager. Any issues raised within the complaint that are not part of the claim will continue to be investigated.

Where complaints involve the death of someone, these are referred to the Deputy Viscount, the Head of Clinical Governance and Risk Management at HCS who will lead and co-ordinate the investigation. This ensures clear lines of communication and investigation for both clinicians and families.

Accountability and learning

Analysis and evaluation of customer feedback

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:

the number of each type of feedback received, including volume of cases opened
the outcome of complaints (e.g. upheld, partially upheld, not upheld), including matters
resolved at point of service
% of extensions to timescales - all stages
volume of current cases in each stage
volume of cases closed at each stage
volume by causes of complaints (to monitor service improvements)
volume of cases by area (broken down into type of feedback – compliment, complaint, suggestion)
actionable insights and action taken
the themes for complaints
improvements made in response to customer feedback, and
volume of complaints being made to the States of Jersey Complaints Panel
volume of identified vexatious complaints and instances of unreasonable behaviour

We will also publish reports to the public on Gov.je.

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 the Executive Leadership Team for review on a quarterly basis. The Executive Leasership Team will also be updated as appropriate regarding high risk or high profile cases, as well as any systemic issues that have been identified.

Commitment

This organisation expects staff at all levels to be committed to the fair, effective and efficient handling of customer feedback.

The organisation is committed to:

recognising people’s right to make comment, suggestion, compliment or complaint about the standard and quality of services provided
providing customers with information about the complaint management process
providing assistance to people who may need it in order to provide feedback
fully investigating and responding to all formal complaints
recording and analysing all formal complaints
setting and monitoring response targets for responding to feedback
ensuring complimentary feedback is registered and recognised
ensuring suggestions are appropriately responded to
boosting public confidence in our administrative process
signposting to other offices which deal with redress, such as the States of Jersey Complaints Panel, and
providing information that can be used by us to deliver quality improvements in our services, staff and complaint handling

The following table outlines the nature of the commitment expected and the way that commitment should be implemented. Specific roles and responsibilities for all staff will be further defined within departmental procedures for handling customer feedback.

Who	Commitment	How
Chief Executive Officer	Responsible for ensuring that policy is implemented and customer feedback has been acted upon across departments of the Government of Jersey	Report publicly on the Government of Jersey's handling of customer feedback. Regularly review and respond to reports about customer feedback trends and issues arising from complaints.
Directors General	Promote a culture that values feedback, continuous improvement and the effective resolution of complaints	Provide regular reports to Ministers about customer feedback and the outcomes of customer complaints. Provide adequate support and direction to key staff responsible for handling complaints. Regularly review and respond to reports about customer feedback trends and issues arising from complaints. Encourage all staff to be alert to customer feedback and assist those responsible for handling complaints resolve them promptly. Encourage staff to make recommendations for system improvements. Recognise and reward good complaint handling by staff. Support recommendations for product, service, staff and complaint handling improvements arising from the analysis of complaint data.
Departmental Senior Management Teams	Promote a culture that values feedback, continuous improvement and the effective resolution of complaints	Provide adequate support and direction to key staff responsible for handling complaints. Regularly review and respond to reports about customer feedback trends and issues arising from complaints. Encourage all staff to be alert to customer feedback and assist those responsible for handling complaints to resolve them promptly. Encourage staff to make recommendations for system improvements. Recognise and reward good complaint handling by staff. Support recommendations for product, service, staff and complaint handling improvements arising from the analysis of complaint data.
Group Director Customer Services	Senior Leader with overarching responsibility within the organisation for the management of customer feedback	Receive and review regular reports on customer feedback trends and issues arising from complaints across the organisation. Work with other Senior Managers to review departmental trends and issues arising from complaints within departments. Work with other Senior Managers to recognise potential hot spots and ensure that action is undertaken to improve services. Encourage all staff to be alert to complaints and assist those responsible for handling complaints resolve them promptly.
Customer Feedback Manager	Establish and manage our feedback management system	Provide regular reports to the Group Director Customer Services on customer feedback trends and issues arising from complaints across the organisation. Prepare reports for departmental Senior Management Teams highlighting departmental trends and issues arising from complaints within departments. Work with departments to identify potential hot spots and ensure that action is undertaken to improve services. Recruit, train and empower staff to resolve complaints promptly and in accordance with Government of Jersey’s policies and procedures. Encourage staff managing complaints to provide suggestions on ways to improve the organisation’s complaint management system. Encourage all staff to be alert to complaints and assist those responsible for handling complaints resolve them promptly.
Department Feedback Management	Ensures department compliance to the customer feedback policy	Work with advisors, section feedback managers and senior managers to ensure that customer feedback is handled in accordance with the guidelines set within the customer feedback policy. Promotes the benefits of good complaint handling and shares examples of best practise. Ensure feedback items are appropriately assigned to the correct sections and/or responsible team members. Identify, manage and escalate (where appropriate) feedback cases that have not met prescribed service level agreements. Work with Customer Feedback Manager and section feedback managers to identify and target improvement opportunities and training/quality issues. Ensure teams are aware of mandatory customer feedback handling training.
Section Feedback Management	Ensures section compliance customer feedback policy	Work with advisors and department feedback managers to ensure that customer feedback is handled in accordance with the guidelines set within the customer feedback policy. Ensures timely and appropriate solutions to complaints. Ensures team members complete customer feedback handling training. Works with Advisors and Department Feedback Managers to identify and implement improvement opportunities. Ensure feedback items are appropriately assigned to the correct sections and/or responsible team members. Highlights additional training requirement to Department Feedback Manager and Customer Feedback Manager.
Staff whose duties include handling customer feedback	Demonstrate exemplary practices in handling customer feedback	Treat all people with respect, including people who make complaints. Assist people to give feedback, if needed. Comply with this policy and its associated procedures. Keep informed about best practice in complaint handling. Provide feedback to management on issues arising from complaints. Provide suggestions to management on ways to improve the organisation's feedback management system. Implement changes arising from individual complaints and from the analysis of complaint data as directed by management.
All staff	Understand and comply with the Government of Jersey's practices for handling customer feedback	Treat all people with respect, including people who make complaints. Be aware of the Government of Jersey's complaint handling policies and procedures. Assist people who wish to give feedback access the Government of Jersey's customer feedback process. Be alert to feedback and assist staff handling complaints resolve matters promptly. Provide feedback to management on issues arising from complaints. Implement changes arising from individual complaints and from the analysis and evaluation of customer feedback data as directed by management.

Training and staff development

The organisation will ensure:

all staff are made aware of the Customer Feedback Policy and departmental procedures through the induction process and training sessions
staff handling customer feedback will be trained and given the tools to resolve complaints when received. They should receive effective supervision, guidance and feedback on their work and be supported by their line manager and the leadership team