DESIGN

Eight design principles

Every organisation should choose a complaint handling model that is best suited to the work, structure and size of the organisation and the needs of its users.

Whether you are designing a new complaints handling system or reviewing an existing system, there are a number of key design principles you should apply.

  1. The system should be user-centred, simple to access and easy to use.

  2. The system should support early resolution of complaints.

  3. The system should be integrated within the overall corporate structure.

  4. Complaints should be recorded in an electronic system capable of producing complaint insights.

  5. Complaint handling should be supported by clear process guidance.

  6. All staff should have the skills and support they need to deliver better practice.

  7. The system should have robust quality assurance and review processes.

  8. The system should be adequately resourced.

Your system design should foster a culture that is open to feedback.

1. The system should be user-centred, simple to access and easy to use

Put complainants at the centre of your complaint handling process by applying a user-centred design process.

There are four key guiding principles for a user-centred system:

  1. listen to users first when designing the system

  2. allow complaints to be raised through multiple channels

  3. create and apply user-centred service standards

  4. listen to users first when critiquing and seeking to improve the system.

Features of a user-centred system

An organisation with a user-centred complaint handling system

  • actively seeks to identify and understand what its users need, expect and prefer

  • designs its complaint handling system with the needs, expectations and preferences of its users in front of mind

  • knows that user experiences may change over time and will

    • regularly test or assess user experience

    • is open to making changes to its system based on user experience

  • encourages and allows the user to be engaged with the complaint system and doesn't make assumptions about how its users will respond to a particular system

  • engages with the particulars of each individual complaint and has sufficient flexibility in its processes to accommodate specific needs.

Use behavioural insights to inform your system design. Take time to map complaint journeys and learn where the pain points are for both your customers and staff. Work out what they will need to access and use the complaints system effectively.

Where possible, users test key features of your system.

For any digital complaint handling channels and services, ensure you comply with the DTA's Digital Service Standards.

Some pain points for complainants

  • having trouble accessing complaint services, for example, because of phone wait times or opening hours, or because of a disability

  • getting ‘stuck’

    • if staff don’t recognise an implied complaint (such as if they didn’t use the word ‘complaint’)
    • on the ‘referral roundabout’ after being referred elsewhere to complain
  • not knowing the next steps or when to expect responses.

Understanding expectations

Some complainant expectations are not reasonable for the organisation to meet. Insight into unreasonable user expectations and preferences can help you enhance your system with resources to manage user expectations.

Accessible and easy to use

Your system should be accessible to everyone in the diverse Australian community. This means taking active steps to understand and reduce any barriers to accessing your system.

Pay particular attention to the needs of people who may be vulnerable due to age, disability, language, geographical, health, financial or cultural reasons.

Keep it simple

Make your system simple, with as few steps as possible. Systems with complex steps risk complainant fatigue and the exclusion of legitimate complaints.

Provide multiple access points

Allow complaints from multiple channels so users can choose one that meets their specific needs. Better practice is to allow complaints to be raised by phone, email, online form, post and face to face.

It is fine to encourage people to use digital channels but take care to keep alternative channels open and well maintained. Complainants should be asked their preferred method of contact and if there is a particular channel that would help them make their complaint more effectively.

Publicise your system

Publish clear information about how to submit complaints and your complaints process in multiple formats—online, in decision letters and other applicable correspondence such as information pamphlets, posters, and on call-through information.

Where possible, include information in multiple languages and provide information about interpreting and translation services.

Make your complaint pages readily accessible from your home page so that people can reach it in one or two clicks. Publish your complaints handling service commitment and policy on your website.

Staff should also tell dissatisfied customers about the option to complain.

The more accessible your system is, the more representative and valuable the complaint data will be.

Accessible systems improve the user experience and decrease the risk that people are made frustrated or angry by the complaints process itself.

Look for barriers

Work out what barriers people face and what can be done to address these. Examples of barriers include:

  • time and effort involved

  • fear of retribution

  • complainant 'fatigue' (such as giving up after multiple referrals)

  • previous negative experiences or lack of confidence or trust

  • known barriers such as those relating to culture, financial hardship, education, health, age, disability or homelessness

  • emerging barriers such as COVID-19 related accessibility issues.

Encourage complaints

Your publications and your staff should actively encourage complaints by making it clear that:

  • complaints are welcomed and free

  • complaint handling is confidential

  • there is no penalty for complaining

  • complaints are valued by the organisation as a way to improve its service

  • complaints can be made anonymously.

Be clear about your role and any limits on your jurisdiction to handle particular complaints. Where appropriate include referral (and time limit) information for other relevant complaint bodies. If possible, practice a ' no wrong door' approach.

Train your staff in accessibility awareness

Ensure staff are well trained in how to support people to complain, and adequate mechanisms are in place to allow sufficient flexibility and guidance to respond to particular complainant groups.

Outreach

Outreach can improve accessibility and visibility of your agency, particularly if you provide services to vulnerable groups with significant access barriers.

Other specialist guidance

There are a number of other complaint handling guides that will help you provide a better service to particular groups. These include:

Children and young people: Complaint Handling Guide: upholding the rights of children and young people

Aged: Better Practice Guide to Complaint Handling in Aged Care

People with disability: Effective complaint handling guidelines for NDIS providers

2. The system should support early resolution of complaints

Early resolution provides a better experience for your complainants and more efficient complaint handling.

The best systems:

  • empower frontline staff to action and finalise complaints

  • triage complaints so that simple complaints can be resolved quickly—freeing up resources for thorough investigation of more complex complaints.

Some guiding principles for triage design are:

  • triage early and effectively

  • develop appropriate KPIs for each triage group

  • resolve straightforward and urgent complaints quickly

  • allow more time for complex and sensitive complaints

  • aim for end-to-end complaint handling by a single complaint handler, but retain flexibility to reallocate complaints where needed so that:

    - complaints are managed by staff with the appropriate skill level and function

    - complaint resolution is not delayed by staff absences.

While triage occurs early in the process, your system will need to be able to reclassify if necessary.

For example, a complaint that may originally appear simple may need to be reprioritised as complex, or a complex complaint may become urgent.

This is often best achieved using a tiered system that suits your needs. A good example is as follows:

3. The system should be integrated within the overall corporate structure

Resolving and learning from complaints often requires direct involvement of program and policy areas and in some cases external organisations, contractors or third parties. This means the complaint system must be integrated with the agency's internal and external activities.

Internal integration

Treat enquiries and complaints as core business. Ensuring that all agency staff are available to assist complaint handlers will result in more efficient and effective complaint resolution.

The complaint system should include a dedicated unit or branch shown on the organisational chart. It should be headed by, or report directly to a senior manager.

Set complaint handling KPIs and include complaint handling performance, trends and insights as a regular item on executive meeting agendas.

Develop workflow and information sharing processes that ensure:

  • prompt internal complaint transfers and responses

  • complaint managers know about changes to program delivery

  • program delivery areas receive complaint handling feedback.

External Integration

Few agencies work independently of other organisations. Some agencies deliver services jointly with other government agencies or in partnership with private sector organisations.

Some agency decisions can depend on information from another agency or organisation.

Many people will not understand the division of functions or responsibility between organisations and may be confused about where to complain. Complaint outcomes will be better if complaint handlers are aware of this and can help the person to the right complaint pathway.

Consider how your agency can integrate with other complaint handling systems:

  • train staff to understand how your agency's activities interact with those of other organisations

  • exchange information with other agencies about complaint pathways and processes

  • consider establishing a formal procedure for referring complaints to other organisations you work closely with

  • cooperate in dealing promptly with complaints from external bodies.

Complaints can cast light on things not apparent to complaint handling staff. Often, business areas developing or administering programs are best placed to resolve a grievance or identify an opportunity for systemic improvement.

1*For smaller agencies that do not deliver services directly to the public this may be a single person.

The best systems have a 'no wrong door' policy, where staff help connect people who come to the wrong business area (or the wrong agency) with the right person, or agency, to handle their complaint.

Case study: Michael contacted an agency to complaint about a problem he was having receiving a service. The complaint handler identified that the reason for the problem was the agency was using a third party service provider to deliver the service. The complaint handler explained that he would take the details of Michael's complaint and provide them to the service provider.

Case study: Jenny contacted an agency to complain about the length of time she had been waiting to receive a particular service. The complaint handler was able to explain to Jenny that the reason for the apparent delay was the agency was waiting for information to be provided by another agency before a decision could be made.

4. Complaints should be recorded in an electronic system capable of producing complaint data

All agencies should have a complaints database that records:

  • when and how the complaint was made

  • the complainant's personal details

  • what the complaint was about

  • how it was resolved

  • all actions, decisions and interactions.

Your database should record information with sufficient granularity and functionality to produce reliable data about complaint trends and issues, including:

Complainant information

  • unique complaint identification number

  • personal information

  • demographics, (such as age, gender, language, location)

  • vulnerability or accessibility considerations (such as homelessness, domestic violence, interpreter, remoteness or isolation).

Complaint information

  • causes (such as agency delay, inaction, rudeness)

  • outcomes (such as complaint upheld, not upheld or inconclusive)

  • remedies (such as better explanation, decision varied or set aside, specific action, apology)

  • further steps (and when implemented)

  • systemic issues.

Complaints data can provide information to help you improve the programs you administer.

It also provides valuable insights into the concerns and needs of the people interacting with your agency. You can use this to transition to more customer centric services.

In some cases it may be appropriate to share complaint data with policy makers.

Customised systems

Your agency should have an electronic system for end-to-end complaint management, if it delivers services direct to the public, or if it funds or contracts third parties to provide services to the public.

Such systems can:

  • guide staff with built in workflows and procedural guidance

  • record all steps and decisions in the complaint handling process

  • hold all correspondence and evidence documents supplied

  • integrate with any future online complaints channels

  • produce granular data for analysing complaint trends, systemic issues and identification of continuous improvement opportunities.

Other electronic systems

Agencies with minimal contact with the public, or those without customised end-to-end case management software, should:

  • assign individual complaint reference numbers and ensure records of decisions, correspondence and related documents are held in a separate file

  • ensure the complaints database includes complaint reference numbers. This enables manual qualitative analysis of individual complaints (for example, if possible trends or systemic issues require further analysis, or for quality assurance purposes).

Third party providers

If you fund or contract third parties to provide services, make sure your contract requires them to provide a better practice complaint handling service and report complaint data and trends to you.

When developing your electronic systems, try to ensure maximum possible integration of your complaints data with complaints data of organisations you fund or contract. This will help you monitor contract compliance and broader trends and issues.

5. Complaint handling should be supported by clear process guidance

Develop a clear complaint handling policy. Make sure it includes complaint handling channels, processes, responsibilities, quality assurance processes and performance indicators.

Clearly document complaint process workflows and step by step instructions to help staff implement your policy consistently and effectively.

Make sure your policy and process documentation is integrated with induction and complaint handling training packages.

We suggest modelling your operational guidance for staff on this Better Practice Guide, incorporating step by step instructions tailored to your agency's needs.

Tip: Make sure staff have ready access to clear guidance about how to enable, receive, manage, resolve and record complaints.

6. All staff should have the skills and support to deliver better practice

Your staff are your most valuable resource.

Recruit the right people

Complaint handlers need specialist skills and attributes, including empathy, resilience, impartiality, conflict management and communication skills.

Depending on the nature of your agency's work and the complaints it receives, you may need to ensure your complaint handling teams include staff with a particular subject matter expertise or specialisations.

Train your staff

You will need a structured complaint handling training program with a specific budgetary allocation and performance measures.

We expect agencies to include complaint handling in their induction training, and refresher and specialist training as appropriate.

All agency staff should be trained on their role in your complaint handling system and should be able to recognise a complaint and assist people to access your complaints system.

All staff should be trained in how to identify and assist vulnerable complaints.

Complaint handlers should be trained and mentored to ensure they:

  • can properly apply internal complaint handling procedures and deliver good complaint service

  • are able to handle complaints confidentially and impartially

  • are aware of and up to date about agency programs or areas of work—particularly those likely to come up in complaints.

Agencies should provide ongoing and specialist training for complaint handlers, in particular training on managing unreasonable complainant conduct.

Other business areas need to know how to support complaint handling, receive feedback and implement changes.

Where possible, complaint managers should participate in complaint handling communities of practice and forums.

Empower your staff

Make sure delegations and policies are in place so:

  • all staff are empowered to assist people to make complaints

  • complaint handling staff have the authority they need to resolve complaints quickly and effectively.

Look after wellbeing

Complaint handling is stressful. Your staff will need support to monitor and manage their own wellbeing.

Ensure complaint handling staff are trained on how to identify and manage unreasonable complainant conduct. Mentoring, wellness programs, role variety and mobility can help reduce complaint handling 'burnout'.

Provide feedback and support

You will need a formal process for systematic review of complaints and providing feedback to staff.

Make sure more intensive supervision and support can be provided where staff are new, matters are complex or the complainant requires extra assistance or more intensive management.

Feedback should be provided on both individual performance and team performance against internal benchmarks.

Your process should ensure managers in other business areas are made aware of issues arising in complaints to ensure feedback to their staff.

Reward good complaint handling

Your system design should foster a culture that is non-defensive and open to feedback. Acknowledge and praise staff who exhibit this approach in their work. We suggest including complaint handling achievements in employee recognition schemes.

You should also acknowledge positive examples of systemic improvement arising from complaint handling. Positive reinforcement of the value of the work they do will help motivate complaint handling staff and improve job satisfaction.

The value of complaint handling should be reflected in career and promotional opportunities.

7. The system should have robust quality assurance and review processes

Strong quality assurance and review processes will underpin the success of your system.

Your quality assurance process should include:

  • a supervision framework, with clear quality check points

  • a process for people to seek review of how their complaint was handled

  • complainant satisfaction analysis

  • strong performance benchmarks

  • regular review of complaint handling processes.

Supervision frameworks

Supervision arrangements should be designed to:

  • provide direction and support to staff

  • monitor how well complaints are being handled and that remedies are offered

  • identify complaint trends and issues

  • provide performance and program feedback.

Staff should be encouraged to approach a supervisor for assistance or guidance or to talk about the emotional demands of their job. Pairing a new complaint handler with a more experienced officer is a good way of providing support and informal training.

Supervision and monitoring should be constant, with regular consultation and feedback to both new and experienced staff.

Tip:Make sure your supervision arrangements can flexibly respond to:

  • the experience of the staff member—new staff generally need closer supervision than experienced staff
  • the complexity of the complaint—complex or novel complaints may need closer supervision or allocation to more experienced staff
  • the complainant’s needs—people who are vulnerable or display difficult behaviour may need special arrangements, more experienced handling or closer oversight
  • complaint handler needs—supervisors may need to monitor staff wellbeing more closely at times – for example where a complainant is upset or aggressive or the subject of the complaint is distressing.

Escalation and review processes

Complainants should have an opportunity to seek review of how their complaint was handled and resolved.

A good way to achieve this is having a tiered escalation system so that a person unsatisfied with the handling of their complaint can have it reviewed at a higher level.

Legislation requires some agencies to have decision review processes which may be separate to its complaint process.

External review options, such as tribunals, conciliation or mediation programs and oversight agencies should generally be mentioned in outcome letters. Other external review options, such as judicial review and freedom of information should be provided where appropriate.

Some things to keep in mind when designing a review system are:

Create a review culture

Staff should be encouraged not to take review requests personally and to see the review process as a valuable part of the overall complaint handling system.

Reviews can provide valuable insights about your internal processes, improve complainant satisfaction and embed high quality complaint handling.

Develop procedural guidance

Each step of the review process should be clearly explained in internal guidelines.

Your default position should be that all complainants may have their complaint escalated or reviewed by a person who was not the original complaint handler.

If it is necessary to limit this option, you will need to provide very clear guidance to staff about the circumstances where they may decide not to grant a request for escalation or review.

Enable review requests

You will need to clearly explain the escalation process to complainants (such as in outcome letters, factsheets and on your website).

Your training program will need to include how to recognise a review request.

Make sure the review process is accessible to everyone. Encourage people to specify what they want reviewed and why they disagree.

Start with better explanations

Sometimes, a person seeking a review will be satisfied with a better explanation of the complaint outcome or process.

Often the original decision maker will be best placed to provide a better explanation of complaint actions, findings or outcomes.

There is a large power imbalance between an agency and individual members of the public. Supervisors should monitor this process to ensure staff do not inadvertently discourage a person from seeking a review when providing a better explanation.

Keep good records

Make sure your guidelines instruct staff to record all review requests, communication, decisions and outcomes.

In particular, if a request for review is refused, staff should be required to record their reasons so supervisors can conduct quality checks.

Complainant satisfaction

Your system should build in processes for seeking complainant feedback.

This can be done in a variety of ways, including:

  • regular complainant satisfaction surveys

  • feedback buttons and surveys in online forms and webpages

  • telephone surveys at the end of calls.

Performance benchmarks

Develop strong performance benchmarks

You will need to develop benchmarks that suit the needs of your agency, and appropriately reflect reasonable community and oversight expectations.

In the table below, we set out some timeframes that we would consider reasonable for an agency to meet when handling straightforward complaints. We adjust our expectations as needed, considering the type of agency and nature of its complaints.

At a minimum, you should have benchmarks for measuring:

  • timeliness

  • complainant satisfaction

  • escalation.

Timeliness

Timeliness benchmarks mitigate the risk of unnecessary delay in complaint handling.

We suggest agencies consider establishing benchmarks for the following as a starting point:

  • acknowledgement

  • simple complaint resolution

  • urgent and priority complaint resolution

  • complex and sensitive complaint resolution

  • notify complainant of delay.

Benchmarks should be efficient, but allow sufficient time for complaints to be handled properly. Agency data will help establish and refine the most appropriate benchmarks.

Sometimes complaints may be delayed while waiting for additional information from the complainant, and complex and major complaint investigations will need longer timeframes for the complaint to be properly handled.

Complaints should be reviewed at established deadlines to see if they need extended timeframes and/or escalation.

Complainant satisfaction

Benchmarks are a matter for each agency to decide, but they should be set high. Set a separate benchmark for satisfaction with process and outcomes. This is because people may be satisfied with the process, even if they are unhappy with the outcome.

We suggest measuring:

Process

  • good, satisfactory or excellent—a very high proportion of people

  • unsatisfactory—a very low proportion of people

Outcome

  • satisfactory, good or excellent—a high proportion of people

  • unsatisfactory—a low proportion of people

Balancing benchmarks It is important that complaint handlers do not feel pressured to meet benchmarks where doing so would result in a negative outcome for the complainant. Make sure your system can record reasons why timeliness standards were not met in a particular case. Strong quality assurance frameworks will help balance competing imperatives of quality and timeliness.

Escalation

Set targets to help measure escalation.

Your targets for internal and external escalation will depend on your agency's needs and strategic objectives.

For example, if you have recently enhanced accessibility of your review system, you will want to know if there are more reviews being requested.

Other

Other benchmarks you will need to measure the quality of your system may include complaint outcomes, causes, remedies and implementation.

Agencies should publish their benchmarks and measure against them.

Regular review of processes

Quality assurance frameworks should be reviewed regularly to ensure they meet the changing needs of your agency.

In addition to ongoing iterative improvement, we recommend reviewing your quality assurance and review framework every 2 years.

8. The system should be adequately resourced

A complaint handling system must be properly staffed and resourced.

The agency must have enough staff to enable it to comply with its own timeliness standards for complaint handling.

Line area managers should also ensure that their staff give appropriate priority to helping complaint handling staff investigate and resolve complaints.

Unless complaints are few in number, there must be an electronic system for entering, tracking and monitoring complaints and for analysing complaint data.