Customer Complaints Management Policy

POLICY ID 2.06

Version 2 (May 2024)

Customer Complaints Management Policy

 

1. PURPOSE

This policy establishes the underlying principles and obligations of the Board of Professional Engineers of Queensland (Board) in relation to the management of customer complaints.

This policy has been approved by the Board and is consistent with the following:

• Public Sector Act 2022
• Code of Conduct for the Queensland Public Service
• Human Rights Act 2019
• Right to Information Act 2009
• Information Privacy Act 2009

This policy applies to all Board members and employees working for the Board (both Board appointed employees and public servants) regardless of whether they are permanent, fixed term temporary, full-time, part-time, or casual employees and/or on secondment from another department.

It also applies to other persons who perform work for the Board including contractors, students gaining work experience and volunteers. For the purposes of this policy, the term contractor includes on-hired temporary labour services (agency staff).

This policy applies to employees in all of their work-related dealings with each other and with customers, contacts or clients including while:

• in the workplace or when working off site
• at work-related functions (including social functions and celebrations)
• on work-related travel
• attending conferences.

 

2. POLICY STATEMENT

The Board is committed to a positive complaint management environment. We encourage feedback and our customer complaints management system allows us to effectively manage all feedback and complaints in an accountable, transparent, timely and fair manner.

The Board recognises that effective complaints management is essential to improving our customer service.

2.1 Objectives

The objectives of this policy are to ensure:

• A readily accessible complaints process and information for all persons regardless of background and circumstances.
• Fair, accountable, transparent and responsive management of complaints.
• All complainants are managed equitably.
• Business improvement opportunities are identified and

2.2 Authority

Section 264 of the Public Sector Act 2022 (PS Act) requires the Board to establish a complaints management system for customer complaints which complies with the Australian/New Zealand Standard – Guidelines for complaints management in organizations (AS/NZS 10002- 2018). The Standard requires the Board to establish a policy setting out our commitment to effective complaints management. This policy is supported by procedures that detail how complaints will be managed.

2.3 Principles

The complaint management principles underlying this policy reflect the Australian/New Zealand Standard – Guidelines for complaints management in organizations (AS/NZS 10002- 2018), s.264 of the Public Sector Act 2022 and the Human Rights Act 2019. To achieve our objectives, the Board is committed to these guiding principles in managing complaints.

Principles	This means we will…
Enabling complaints people focus	Recognise and respect everybody’s right to provide feedback. Demonstrate a commitment to addressing feedback in a timely manner and without charge. Involve the complainant in the process as far as is practicable and appropriate.
Visibility and access	Record, track, acknowledge and process complaints in a timely manner, in accordance with the relevant Board complaints management procedures. Manage the expectations of complainants by ensuring the complainant is aware of the process, timeframes, their likely involvement, the possible outcomes of the complaint and any other necessary information. Assess the nature of complaints, including any human rights considerations, how they should be dealt with and by whom.
Managing complaints responsiveness	Record, track, acknowledge and process complaints in a timely manner, in accordance with the relevant Board complaints management procedures. Manage the expectations of complainants by ensuring the complainant is aware of the process, timeframes, their likely involvement, the possible outcomes of  the complaint and any other necessary information. Assess the nature of complaints, including any human rights considerations, how they should be dealt with and by whom.
Objectivity and fairness	Manage complaints objectively and deal with them fairly, respectfully, consistently, in accordance with the principles of natural justice and without actual or perceived conflicting interests. Take all reasonable steps to ensure that a complainant is not adversely affected. Protect the rights of officers where they are the subject of a complaint. Deal with complaints confidentially to the extent possible and with personal information in accordance with the Information Privacy Act 2009. Manage unreasonable complainant behaviour and consider the merits of each complaint. Manage unreasonable and/or vexatious complaints appropriately.
Feedback and decision	Provide adequate and timely feedback on complaints to all parties. Provide a clear explanation of the final decision and any recommendations. Notify complainants of their internal and external review options
Monitoring and reporting	Record and report complaints in accordance with legislative and other requirements. Monitor the time taken to resolve complaints. Monitor and analyse complaints feedback and trends to improve our complaints management system. Commit to using complaints as an essential tool for continuous improvement.
Staff awareness training	Empower staff to effectively manage customer complaints by ensuring that all staff are aware of the Board’s Customer Complaints Management Policy and procedures. Providing training at induction and on an ongoing basis.
Remedies	Attempt informal resolution and compromise wherever possible. Offer remedies that are fair to all parties, minimising the possibility of ongoing dispute.

 

2.4 Scope

This policy applies to a written or verbal complaint made by a person (the complainant or other authorised person) who is directly affected by the service or action of the Board and/or our staff.

A complaint is an expression of dissatisfaction in relation to a Board policy or service, where a response or resolution is explicitly or implicitly expected or legally required. This includes actions of Board employees, such as:

• a decision, or a failure to make a decision
• an act or failure to act
• an act or decision that is not compatible with human rights
• the formulation of a proposal or intention
• the making of a recommendation
• customer service provided
• the handling of a customer complaint

This policy does not apply to complaints about:

• complaints about the conduct of registered professional engineers or notifications regarding potential breaches of the Professional Engineers Act 2002 (PE Act).
• the Board’s decisions in relation to Registration of Professional Engineers under Part 2 of the PE Act
• the Board’s decisions in relation to investigations (Part 4 of the PE Act)
• employee complaints that are dealt with under the Board’s Employee Complaints Policy
• complaints about the Board which are made to and dealt with by the Office of the Minister for Housing, Local Government and Planning and Minister for Public Works (e.g. complaints being responded to via ministerial correspondence)
• complaints that are primarily contractual in nature
• matters subject to legal proceedings
• complaints about access application decisions dealt with under the Right to Information Act 2009
• complaints about access and amendment application decisions under Chapter 3, Part 2 of the Information Privacy Act 2009
• another agency or organisation
• matters outside the Board’s direct responsibility
• a third-party agent or service provider where the matter is referred to the agent or service provider for direct investigation and/or response to the customer

These complaints should be made to the agency or organisation which is the subject of the complaint, or as follows.

A complaint assessed as a public interest disclosure (PID) made under the Public Interest Disclosure Act 2010 (PID Act) is to be managed in accordance with the Board’s Prevention and Management of Corrupt Conduct and Public Interest Disclosure Procedure.

A complaint which includes an allegation/s of corrupt conduct as defined under section 15 of the Crime and Corruption Act 2001 is to be managed in accordance with the Prevention and Management of Corrupt Conduct and Public Interest Disclosure Policy.

 

3. COMPLAINTS MANAGEMENT PROCESS

3.1 How to make a complaint

Complaints may be made verbally (in person or phone) or in writing (website, email or post) by the complainant (or another authorised person). An online complaints form is available if you wish to use this as a guide. Further information is available on the Board website.

Anonymous complaints, and those provided by an authorised third party are afforded the same consideration as other complaints.

The complaint is to be made within twelve months from the time from which the grounds of the complaint arose. If the complaint is submitted outside the twelve-month timeframe, exceptional circumstances will need to be provided explaining why the complaint is submitted outside this timeframe. Exceptional circumstances include situations which are out of the ordinary, unusual, special, or uncommon (for example, ill-health and/or personal issues impacting on the complainant’s ability to address the concerns).

The assessment of the complaint will consider any exceptional circumstances and the seriousness and complexity of the complaint.

In accordance with the Human Rights Act 2019, assessment of human rights complaints will only occur for acts or decisions made on or after 1 January 2020.

The Board will meet the reasonable costs of services which assist people with hearing or vision impairments or who may require a translation and interpreting service.

• The Queensland Government Translation and Interpreting Services are available for complainants who are unable to speak or write in English. They are available at https://www.qld.gov.au/help/languages or by phoning (TIS National) on 131 450.
• The National Relay Service is available for people with hearing or vision impairments (133 677 TTY/Voice or 1300 555 727 (Speak and Listen).

  

3.2 Our timeframes

All customer complaints will be acknowledged within 3 business days of receipt.

Complaints will be resolved within the timeframes that apply to the following level of complexity:

Simple complaints are resolved within 20 businesses day if possible. These are complaints that have no risk or detriment to the client or the Board and are generally able to be resolved at the point of service by a Board staff member with oversight by the Manager of the business unit.

Standard complaints are resolved within a maximum of 30 working days of receipt of the complaint. This type of complaint has minimal risk or detriment to the client or the Board and usually one single issue or concern.

Significant / complex complaints may require more than 90 working days due to the medium or high level of risk/detriment to the client or the Board and multiple and/or serious issues that usually requires an extensive investigation.

Privacy and human rights complaints – a complaint that the Board has breached an individual’s privacy or a complaint about a matter affecting a relevant human right must be resolved within 45 working days of receipt.

 

3.3 Complaints management model

Step 1: Officer – receipt and first contact resolution.

Step 2: Board Complaints Coordinator – coordinates assessment, resolution and outcome advice.

Step 3: Internal Review Officer – conducts a merit review at request of complainant.

Step 4: External review requested by complainant (external review bodies include Queensland Ombudsman, Office of the Information Commissioner).

The Complaints Coordinator is the officer responsible for the coordination and oversight of our customer complaints management system.

Board staff members (receiving officers) will try to resolve your complaint at your first point of contact, if possible, for example on the phone or in person (Step 1). Otherwise, your complaint will be referred to the Complaints Coordinator for assessment and management, and verbal or written advice will be provided to you on the outcome of your complaint (Step 2).

If you are dissatisfied with the outcome of your complaint or how the complaint was handled, you may seek an internal review by a senior Board officer within twelve months of the decision on the complaint (Step 3). If you are dissatisfied with the internal review you may seek an external review by an independent external review body (Step 4).

A complainant who is dissatisfied with the Board response to their complaint about a human rights matter can make a complaint to the Queensland Human Rights Commission.

The external review bodies which may accept your complaint include the:

• Office of the Queensland Ombudsman
• Office of the Information Commissioner (for complaints about breaches of privacy)

 

3.4 Different procedures may apply to some customer complaints

The Board is required to address certain types of complaints in specific ways. The Complaints Coordinator will assess and address an incoming complaint as per the below table.

Type of complaint	The complaint is governed by this policy and…
Complaints about Board products, services and conduct of employees	The Board Customer Complaints Procedure
Complaint that the Board has breached an individual’s privacy	Information Privacy Act 2009, Human Rights Act 2019 and the Board Customer Complaints Procedure
Complaints about breaches of human rights	Human Rights Act 2019 and the Queensland Government Guide: Handling Human Rights Complaints
A complaint assessed as a public interest disclosure (PID) in accordance with the Public Interest Disclosure Act 2010	The Board Prevention and Management of Corrupt Conduct and Public Interest Disclosure Procedure
A complaint which is an allegation about ‘corrupt conduct’ as defined under s.15 of the Crime and Corruption Commission Act 2001	The Board Prevention and Management of Corrupt Conduct and Public Interest Disclosure Policy The complaint may be referred to the CCC for investigation or investigated by the Board and reported to the CCC if required under the Crime and Corruption Commission Act 2001

Customer complaints the Board will not action

The Board will not accept or action complaints about matters:

• already dealt with or currently being dealt with by the Board, another board or agency, a court or tribunal,
• that are impractical to investigate, or that appear to be frivolous, vexatious, misconceived or lacking in

A determination to not action or accept a matter under this section will be made by the decision maker for the relevant level of the complaint.

  

3.5 Managing unreasonable complaint behaviour

The Board recognises that in managing complaints fairly, efficiently, and effectively, all parties to a complaint (for example, complainants, complaint handlers and any people the subject of the complaint) have certain rights and responsibilities. The Board will ensure that our work health and safety responsibilities and duty of care obligations are met.

This obligation extends to Board staff who deal with complaints. The Board will ensure appropriate strategies are in place for managing unreasonable complainant conduct fairly, ethically, and reasonably (for example, unreasonable persistence, demands, lack of cooperation, unreasonable arguments and behaviour).

Unreasonable complainant conduct is behaviour by a complainant which, because of its nature or frequency, raises substantial health, safety, resource or equity issues for the parties to a complaint including the complainant, staff or other service users.

Examples of unreasonable complainant conduct can include but are not limited to:

• Persistence – making excessive calls or sending excessive emails
• Demands – asking for more reviews than provided for in the policy or demanding different outcomes without evidence the original decision was wrong
• Lack of cooperation – refusing to identify the issues of the complaint or providing disorganised information
• Arguments – expressing irrational claims or making vexatious complaints or denying responsibility for own actions
• Behaviours – making self-harm threats or threatening harm to others, using abusive language or threatening violence.

The Board is committed to addressing valid issues however, it will manage unreasonable complainant conduct in a manner consistent with the Board’s obligation to ensure a healthy and safe work environment.

The Board will not tolerate complainant conduct or conduct from associated persons that presents a risk to employees’ health and safety.

For more information about the management of unreasonable complainant conduct refer to the Queensland Ombudsman resources for managing unreasonable conduct or the Managing unreasonable complainant conduct practice manual issued by the NSW Ombudsman.

 

 

4. ROLES AND RESPONSIBILITIES

Corporate Services Manager (Complaints Coordinator)

• Has responsibility for managing customer complaints in accordance with this policy and associated procedures.
• Provides reports to senior management and meets annual reporting requirements (section 264 Public Sector Act 2022 (PS Act) and section 97 Human Rights Act 2019).
• Is the delegated PID Coordinator and is responsible for managing these complaints in accordance with the relevant legislation and procedure.
• Coordinates training sessions for Board staff and maintains a register of training provided to each staff member.

Registrar

• Conducts internal reviews of decisions relating to public interest disclosures and complaints about corrupt conduct.
• Conducts annual review of compliance with the policy and associated procedures.
• Reviews policy and procedures at least every two years.
• Oversights Board staff awareness of Board Customer Complaints Policy and Procedures.

Senior Officers (Officers – internal review); (Officers – investigating)

• Oversight first point of service contact resolution of customer complaints by employees within their teams and reporting of resolved or referral of unresolved point of service customer complaints to the Complaints Coordinator.
• Respond to customer complaints referred by Complaints Coordinator and investigate complaint if appropriate.
• Conducts internal review of decisions on customer complaints as requested and in accordance with this Policy and associated Procedure.

Employees (Officers – receiving)

• Develop a working knowledge of the Board Customer Complaints Management Policy and Procedures to ensure customer complaints are appropriately managed.
• Receive complaints at the first point of contact; in consultation with Senior Officers resolve or refer unresolved complaint to the Complaints Coordinator to manage.
• Record complaint details and resolution or reasons for referral appropriately.

 

5. REPORTING REQUIREMENTS

The Complaints Coordinator will provide six-monthly reports to the Board regarding customer complaints data.

The Board will publish its customer complaints data on its website on an annual basis.

 

6. HUMAN RIGHTS

Decision makers must act and make decisions in a way that is compatible with human rights and give proper consideration to a human right relevant to a decision, as required by s 58 of the Human Rights Act. For further information please refer to the Board’s Human Rights intranet page.

The policy has been reviewed for compatibility with human rights under the Human Rights Act.

The policy has been found to limit human rights only to the extent that is lawful, reasonable, and demonstrably justifiable in accordance with section 13 of the Human Rights Act, therefore, it is reasonable to conclude that the policy is compatible with human rights.

 

7. APPROVAL

This policy was approved by the Board on 28 May 2024 to commence on 1 July 2024.

 

ATTACHMENT 1: CONTACT

The Corporate Services Manager as the Complaints Coordinator is the first point of contact for any questions regarding this policy.

 

ATTACHMENT 2: REFERENCES

The requirements set out in this document are based on, and are consistent with, relevant Government legislation, regulations, directives, information standards and/or policies at the time of publication.

Any reference to legislation, policy or other document is taken to be a reference to that legislation, policy or other document as amended or replaced from time to time.

• Public Sector Act 2022
• Code of Conduct for the Queensland Public Service
• Human Rights Act 2019
• Right to Information Act 2009
• Information Privacy Act 2009
• Crime and Corruption Commission Act 2001
• Public Interest Disclosure Act 2010

 

ATTACHMENT 3: DEFINITIONS

Unless otherwise defined, the terms in this policy have the meaning set out in the Public Sector Act 2022.

Term	Description
Employee	This policy applies to all Board members and employees working for the Board (both Board appointed employees and public servants) regardless of whether they are permanent, fixed term temporary, full-time, part-time, or casual employees and/or on secondment from another department. It also applies to other persons who perform work for the Board including contractors, students gaining work experience and volunteers. For the purposes of this policy, the term contractor includes on-hired temporary labour services (agency staff).
Customer complaint	A complaint about the service or action of a department, or its staff, by a person who is apparently directly affected by the service or action [section 264(4) Public Sector Act 2022 (PS Act)]
Officer – receiving	The Board staff member who receives the complaint at first contact in Step 1 of the process and either resolves the complaint or refers to Complaints Coordinator for management through their Senior Officer
Officer – internal review	The senior officer nominated by the Complaints Coordinator to conduct an internal review who is not involved in the complaint or investigation process
Officer – investigating	The senior officer with the appropriate authority and expertise in their role to investigate the complaint.
Complaints Coordinator	The officer responsible for managing Board customer complaints and has oversight of all steps in the process. Assesses complaints including Public Interest Disclosures and allegations