PAPER C
Purpose: For approval

COMMITTEE

CORPORATE SCRUTINY COMMITTEE

DATE

10 MARCH 2020

TITLE

REVIEW OF THE COMPLAINTS PROCESS

REPORT OF

CHAIRMAN OF THE CORPORATE SCRUTINY COMMITTEE

SUMMARY
1.

At its meeting of 8 October 2019, the Corporate Scrutiny agreed to review the
Council’s complaints process in early 2020. This was to allow data to be available
from the first six months of a new customer relationship management system
(CRM).

2.

The Committee had agreed that the review would be based on the overarching
question:
•

Is the way that the Council handles complaints leading to improvements in
service delivery?

3.

This paper reports the review. It finds that there is evidence that learning from the
complaints process is leading to improvements in service delivery.

4.

However, learning outcomes are only being formally identified in a minority of cases.
This suggests that there is significant potential to develop the Council’s work in this
area, and further improve service delivery. This possibility is recognised by the
Corporate Management Team and work is actively under way to achieve this.

5.

It is recommended that the committee receive a report on complaints at its
September 2020 meeting. This will allow it to consider a full year of complaints
reporting using the new CRM and the impact of work to encourage learning
outcomes.

BACKGROUND
6.

Learning from complaints is recognised as good practice. The Isle of Wight
Complaints Policy (Appendix A) identifies as the first of its list of aims and objectives
to “improve the quality of the services we provide”. This objective is echoed by the
Local Government and Social Care Ombudsman (LGCSO); for example, in their
annual letter of 11 July 2018 under a heading of “Learning from complaints to
improve services”.
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 7.

The Corporate Plan includes a performance indicator of a rolling twelve-month
average number of stage 1 complaints made about council services per month. The
baseline figure for 2017 is 57; the 2022 target is 50. This measure is reported
through the quarterly performance reports to Cabinet. The figure for September
2019 was 85. The figures over time show considerable variability.

SUMMARY OF POLICY AND PROCESSES
8.

The Council’s Complaints Policy was reviewed and updated in December 2019. In
particular, this clarified responsibility for the complaints at any given stage with a
particular focus on identifying learning outcomes and using these to improve
services for the Council’s customers in line with LGCSO guidelines.

9.

The policy defines a complaint as follows: any expression of dissatisfaction with our
services or those for which we are responsible, (this includes some provided under
contract to the council), that requires a response. There is no difference between a
“formal” and an “informal” complaint. Both are expressions of dissatisfaction that
require a response.

10.

The policy sets out processes and timescales. It should be noted that there are
separate provisions for complaints about adult social care and children’s social care.

11.

Responsibility for complaints management within each service area is with a
Nominated Complaints Officer (NCO) and deputy. Their responsibilities include
recording and updating of information about complaints on a Customer Relationship
Management system (CRM). A new CRM was introduced in June 2019 and NCOs
were trained in its use.

12.

First receipt of a corporate complaint is ‘Stage One’. (Adult Social Care complaints
have an ‘Initial Stage’). The NCO or deputy enters the information into the CRM and
passes on the details to the relevant service manager whose responsibility it is to
respond to the complainant.

13.

If the complainant is dissatisfied with the response at Stage One, then a Stage Two
investigation is undertaken. This is carried out by a head of service or a strategic
manager.

14.

If the complainant is still dissatisfied, they may take the matter up with the LGCSO.
In practice, the Stage One process does not have to be a single back-and-forth of
complaint and response. Dialogue is encouraged.

15.

Closure of a complaint on the CRM requires completion of a learning outcomes field.
Responsibility for identifying learning outcomes is with service managers. These are
passed to the NCOs for recording on the CRM. The new system does not allow the
learning outcomes field to be left blank.

HOW COMPLAINTS ARE MADE
16.

The complaints policy sets out that complaints may be made by email, telephone,
letter, online, or in person at any relevant council office. A complaint form is available
at any council office that is open to the public.

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 17.

When making a complaint online the Council’s website requires the complainant to
log in. A user without an account must register for one. When online the user is
presented directly with an online form. It should be noted that a requirement to log
in can unnecessarily deter users from proceeding with communications.

18.

The main complaints section of the Council’s web site provides the County Hall
address for correspondence, and the customer contact centre number for phone
contact. No email address is displayed on either the contact information page or on
the FAQ page.

Complaints about Children’s Social Care Services
19.

The Council’s website provides a link to the Hampshire County Council web site. It
also provides an email address and phone number. The linked Hampshire County
Council page provides:
• a link to an online form (log in is not required)
• a specific complaints email address
• a postal address
• a phone number for verbal complaints
• The page also identifies that complaints may be recorded on video, DVD, CD or
audio tape.

Complaints about Adult Social Care Services
20.

The Council’s website provides:
• a link to the general online complaints form (log in required)
• a specific complaints email address
• a Freepost address including a link to a downloadable complaint reporting form
• a specific phone number for verbal for making an appointment to meet with
Adult Social Care Complaints Team

Complaints about Island Roads
21.

Any complaints received by the Council which relate to Island Roads service (project
network) are passed to Island Roads to deal with directly and the customer would
be notified that their complaint has been forwarded.

22.

Any complaints received by the Council which do not relate to Island Roads service
(project network) but do relate to highways matters that the Council are still
responsible for are dealt with by the Council in accordance with our policy and
process.

23.

The Highways Maintenance section of the Council’s website provides a contact form
but otherwise provides Island Roads’ postal address and phone number. The Island
Roads’ website provides a link to its complaints policy from its ‘Contact Us’ page.
The policy identifies that the version dates from November 2015.

24.

The policy provides:
• a phone number
• the general Island Roads’ email address
• an address for making complaints in person
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 25.

The policy echoes the Council’s policy for the main part, including discussing
procedures for Stage 1 and Stage 2 complaints. It makes no reference to the role
of the Local Government and Social Care Ombudsman (LGCSO). Island Roads
have confirmed, however, that letters from them do refer to the LGCSO.

REPORTING AND PERFORMANCE MANAGEMENT
26.

Figures on the number of Stage 1 complaints received by the council are reported
to Cabinet as part of its quarterly performance reports.

27.

An annual letter is issued by the Local Government and Social Care Ombudsman
(LGCSO) relating to complaints that have been taken up with them. The most recent
letter (Appendix B) was reported to Cabinet in September 2019.

28.

The Policy and Scrutiny Committee for Health and Adult Social Care receives an
annual report (the most recent is at Appendix C). The Policy and Scrutiny Committee
for Children’s Services does not receive an annual report.

29.

The complaints policy sets out that the Corporate Complaints Team will prepare an
annual report with learning outcomes from complaints for both members and officers
in line with LGCSO guidance.

PERFORMANCE STATISTICS
30.

There have been two quarters since the new CRM was implemented. The table
below summarises
Quarter

Complaints
logged

Complaints
closed*

Learning outcomes
recorded

June to September 2019

342

349

60 (17%)

October to December 2019

187

199

36 (18%)

* complaints logged in one quarter may go on to be closed in the succeeding quarter
31.

The percentages are of number of learning outcomes recorded to number of
complaints closed.

32.

Data relating to the statutory process for children’s services, and on complaints
relating to the delivery of the Highways PFI contract by Island Roads is not included
in this table.

33.

The need for a mechanism to capture appropriate data for the statutory children’s
services complaints process has been identified by the Corporate Management
Team.

34.

There is a monthly report that demonstrates the number of complaints received by
Island Roads. This is a high-level meeting which is required as part of the contract.

35.

The most recent LGSCO annual letter reports on the period ending 31 March 2019.
The LGCSO received 43 complaints and enquiries. It referred 12 back for local

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 resolution and closed 15 after initial enquiries. Detailed investigations took place in
16 cases, of which 5 were upheld.
36.

The LGSCO’s letter confirms the ongoing steps it is taking to “…move away from a
simplistic focus on complaint volumes and instead focus on the lessons learned…”.
To support this, it has established a web-based interactive map of council
performance for all councils in England at: https://www.lgo.org.uk/your-councilsperformance/isle-of-wight-council/statistics

LEARNING OUTCOMES AND IMPROVING SERVICE DELIVERY
37.

There will be many reasons why people express dissatisfaction with council
services, and some may be unique to the circumstances of individuals.

38.

The first two quarters show that substantive learning outcomes were identified and
recorded in the CRM in a little under one-fifth of cases.

39.

For the quarter October to December 2019, officers have carried out analysis of the
36 complaints with a learning outcome. The following themes were identified:
•

wording of letters and terms and conditions to be rephrased to ensure that
information is clear and accurate

•

staff training required

•

process improvement such as improving response times, not issuing
unnecessary forms, and ensuring additional checks are made for accuracy of
information

•

workload management through automating of processes and of training staff so
that they may assist at times of high workload

40.

Where substantive learning outcomes from a complaint were not recorded, it should
be noted that this does not necessarily mean learning did not arise. It could be that
these were not recognised as needing formal capture. It has been confirmed that
staff are encouraged to identify learning outcomes, and training is being provided to
support this.

41.

Examples of learning outcomes leading to improvements in service delivery include:
•

Customers had reported that the wording of some council tax correspondence
(especially the reminder for non-payment) is harsh. The Council Tax team is
working with the Council’s communications team to review the content and
advice on providing the same message and information in a more customerfriendly way.

•

A “Social Care Jargon Buster” written by ‘think local act personal’ and endorsed
by the Social Care Institute for Excellence has been circulated to all adult social
care staff in the newsletter and made available as a document on the department
webpages. This provides a useful guide for individuals and their families to
support them in their contact with the various agencies and departments
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 involved in their care and support. (Note: more examples from Adult Social Care
can be found in the annual report to the Policy and Scrutiny Committee).
•

42.

Complaints were received regarding the assisted collection review letters
requiring return by post, which caused difficulty for some residents who found it
difficult to do this. To address this a dedicated e-mail account was set up so that
residents could respond via e-mail, with this information added to the review
letters sent by Amey.

The Corporate Management Team has committed to ensuring that the importance
of identifying and recording learning outcomes is understood throughout the
authority, with regular reviews of complaints and learning outcomes take place at
directorate management team meetings.

OBSERVATIONS AND CONCLUSION
43.

In summary, the following observations are made:
•

The Council has an up to date complaints policy with clear objectives relating to
improving service delivery by identifying learning outcomes

•

The policy is appropriately managed in service areas by designated nominated
complaints officers (NCOs)

•

The new CRM provides an appropriate tool for recording information for all
stages of a complaint, and for providing performance information

•

Through a dedicated learning outcomes field, the CRM provides a specific
means for capturing learning outcomes

•

Learning outcomes are being formally identified by service managers, and
captured in the CRM, but only in a minority of cases

•

The desirability of increasing the number of learning outcomes captured is
recognised by CMT and service managers, and action is under way to deliver
that

44.

The Committee had an overarching question in mind for the review: Is the way that
the Council handles complaints leading to improvements in service delivery?

45.

The conclusion is that there is, indeed, evidence to answer this question positively
while recognising that there is still work to be done.

46.

If successful, this work should lead to learning outcomes being recorded in a higher
proportion of complaints cases. Ideally, improvements in service delivery should
lead to a lower rate of complaints in areas where they are currently being made.

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 47.

It may be that a baseline figure for the percentage of complaints that could
reasonably be expected to have a learning outcome could be introduced at some
time. If so, this could support performance monitoring in due course.

MATTERS FOR CONSIDERATION
48.

Recommendations are made in the section below. As well as considering these,
committee members may have views on the following issues:
•

The scrutiny of complaints relating to the delivery of the Highways PFI contract
by Island Roads through the quarterly reports to Corporate Scrutiny Committee
on the contract’s performance.

•

The means for making a complaint being standardised with the information
clearly available on all relevant web pages (email, phone, postal address, in
person, by recorded medium such as DVD etc).

•

Whether or not there should be a requirement for a user to log in to a council
account – for which they may have to register first – to make a complaint, as the
requirement could deter people from raising the issue.

RECOMMENDATIONS
1)

Corporate Scrutiny Committee notes that there is evidence that the way the Council
handles complaints is leading to service improvements.

2)

Corporate Scrutiny Committee supports the Corporate Management Team’s focus
on encouraging the identification of a learning outcomes in a greater proportion of
cases.

3)

Corporate Scrutiny Committee should review the available data on complaints
handling once four quarters of performance information from the new CRM is
available; and should schedule this in its workplan for its September 2020 meeting.

4)

Thereafter, Corporate Scrutiny Committee should review the annual report
produced by the Corporate Complaints Team following its publication.

5)

Island Roads’ be asked to review their complaints policy to ensure it is up to date
and in line with the Council’s own policy.

APPENDICES
49.

Appendix 1 - the Council’s Corporate Complaints Policy

50.

Appendix 2 - Annual Review letter from the Local Government and Social Care
Ombudsman’s, July 2019

51.

Appendix 3 - Adult Social Care Annual Complaints Report to Policy and Scrutiny
Committee for Health and Social Care, October 2019

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 Contact Point: Councillor Andrew Garratt, Chairman of the Corporate Scrutiny Committee
e-mail Andrew.Garratt@iow.gov.uk
CLLR ANDREW GARRATT
Chairman of the Corporate Scrutiny Committee

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