Complaints Handling Procedure

1. Definitions and Interpretation

1.1 In this Complaints Handling Procedure the following expressions have the following meanings:

"Appeal" - means a request from a Customer to escalate a Complaint to Level Two following an unsatisfactory outcome at Level One;

"Appeal Handler" - means an employee of Strengthening Practice who will handle Level Two Complaints;

"Business Day" - means, any day (other than Saturday or Sunday) on which ordinary banks are open for their full range of normal business in England;

"Complaint" - means a complaint about products and/or services sold by Strengthening Practice, about our customer service, or about our employees;

"Complaint Handler" - means an employee of Strengthening Practice who will handle Level One Complaints;

"Complaints Policy" - means our customer complaints policy;

"Complaint Reference" - means a unique code assigned to a Complaint that will be used to track that Complaint;

"Customer" - means a customer of Strengthening Practice and includes potential customers (no purchase necessary);

"Decision Letter" - means a letter sent by a Complaint Handler or Appeal Handler to a Customer informing that Customer of the outcome of their Complaint;

"Investigation Report" - means the report prepared by a Complaint Handler or Appeal Handler detailing his/her investigation;

"Level One" - means the first stage in this Complaints Handling Procedure under which Complaints will be handled by a Complaint Handler;

"Level Two" - means the second stage in this Complaints Handling Procedure under which a Customer may appeal the outcome of a Level One Complaint and under which Complaints will be handled by an Appeal Handler;

"Resolution Action" - means the available actions to be taken in response to a Complaint as detailed in Section 8.

2. What this Complaints Handling Procedure Covers

2.1 This Complaints Handling Procedure applies to Complaints pertaining to the sale of products and the provision of services by Strengthening Practice, to our customer service and to our employees.

2.2 For the purposes of this Complaints Handling Procedure, any reference to Strengthening Practice also includes our employees.

2.3 Complaints may relate to any of our activities and may include (but not be limited to):

2.3.1 The quality of our customer service;

2.3.2 The behaviour and/or professional competence of our employees;

2.3.3 Delays, defects or other problems associated with the sale of products;

2.3.4 Delays, defects, poor workmanship or other problems associated with the provision of services;

2.4 The following do not constitute Complaints. Customers raising such questions or matters should be directed to the appropriate person:

2.4.1 General questions about our products and services;

2.4.2 Matters concerning contractual or other legal disputes;

2.4.3 Formal requests for the disclosure of information including, but not limited to, those made under the applicable legislation;

3. Receipt and Recording of Complaints

3.1 Customers may make Complaints to Strengthening Practice using any of the following methods:

3.1.1 In writing, addressed to Erica Gaffney, 12. Market Place, Cockermouth, Cumbria, CA13 9NQ;

3.1.2 By email, addressed to Erica Gaffney at erica@strengtheningpractice.co.uk;

3.1.3 Using our Complaints Form, following the instructions included with the form;

3.1.4 By contacting us by telephone on 01900 822458

3.2 Upon receipt of Complaints, the following steps should be taken within five Business Days:

3.2.1 If a written Complaint is received by post, Erica Gaffney must log this via our internal system;

3.2.2 If a written Complaint is received by email, Erica Gaffney must log this via our internal system;

3.2.3 If a Complaints Form is received, Erica Gaffney must log this via our internal system;

3.2.4 If a Complaint is made by telephone, Erica Gaffney must log this via our internal system.

3.3 All Complaints must be given a Complaint Reference and forwarded to an appropriate Complaint Handler, selected in accordance with Section 6.1 within five Business Days.

3.4 All Complaints must be acknowledged in writing within five working days of receipt by Erica Gaffney. The acknowledgement should inform the Customer of their Complaint Reference, their assigned Complaint Handler and should include copies of Strengthening Practice’s Customer Complaint Policy and this Complaints Handling Procedure.

4. Complaint Information

4.1 Customers are advised in our Complaints Policy that the following information should be provided in as much detail as is reasonably possible when making a Complaint:

4.1.1 The Customer's name, address, telephone number and email address, indicating any preferred method of communication;

4.1.2 If the Customer is being represented by a third party, the information set out in Section 4.1.1 should be provided in reference to both parties;

4.1.3 If the Complaint relates to a particular transaction, the order number, course number or invoice number;

4.1.4 If the Complaint relates to a particular employee the name and, where appropriate, position of that employee;

4.1.5 Further details of the Complaint including, as appropriate, all times, dates, events, and people involved;

4.1.6 Details of any documents or other evidence on which the Customer wishes to rely in support of the Complaint;

4.1.7 Details of how the Customer would like Strengthening Practice to resolve the Complaint. Whilst we undertake to make all reasonable efforts to accommodate such requests, however, we are not bound to take any action beyond that which we may be contractually or otherwise legally obliged to take.

4.2 If the information detailed in Section 4.1 is missing, insufficiently detailed, or incomplete, Erica Gaffney should contact the Customer within five Business Days of receipt of the Complaint to request further information.

5. Complaint Levels

5.1 Strengthening Practice operates a two-stage complaints handling procedure. Upon receipt, all new Complaints should be handled in accordance with the Level One procedure set out in Section 6 below. It is our policy to use all reasonable endeavours to resolve all Complaints to Customers' satisfaction at Level One.

5.2 If a Customer is not satisfied with the resolution of their Complaint at Level One, he/she may request that the Complaint is escalated to Level Two in the form of an Appeal at which point the Complaint should be handled in accordance with the Level Two procedure set out in Section 7 below.

6. Level One Complaints

6.1 Upon receipt of a Complaint, the Complaint Handler shall consider the Complaint and make a decision within five Business Days whether to:

6.1.1 Investigate the Complaint fully if it is considered to be valid, in which case the procedure should resume from Section 6.3; or

6.1.2 Dismiss the Complaint if it is considered to be invalid, in which case the Complaint Handler should inform the Customer of his/her decision in writing within five Business Days.

6.2 Subject to delays arising from circumstances beyond his/her reasonable control (including, but not limited to, delays in other persons responding to communications), the Complaint Handler shall have a period of five Business Days in which to fully investigate the Complaint and to decide upon appropriate Resolution Action(s).

6.3 If the Complaint relates to (a) particular employee(s) (a “Complainee” or “Complainees”), the Complaint Handler shall inform the Complainee(s) in question of the Complaint and arrange meetings and/or telephone calls as required to discuss the Complaint. In such cases, the Complainee(s) should not, under any circumstances, contact the Customer directly regarding the Complaint. If the Customer contacts the Complainee(s) directly regarding the Complaint (which they are requested not to do in our Complaints Policy), the Complainee(s) should respectfully refuse to discuss the matter, referring the Customer to Section 5.2.3 of our Complaints Policy. Any such contact should be reported to the Complaint Handler.

6.4 If the Complaint Handler requires additional information or evidence in support of the Complaint, the Complaint Handler shall contact the Customer using the Customer's preferred method of communication, stating clearly what information or evidence is required. Customers should be respectfully reminded that any delay in their response to such a request may delay the resolution of their Complaint, as per Section 5.2.4 of our Complaints Policy.

6.5 If a Customer is unable or unwilling to provide information or evidence requested under Section 6.5, the Complaint Handler must nevertheless use all reasonable endeavours to resolve the Complaint. If, however, the Complaint Handler considers that it is not possible to uphold the Complaint in the absence of the requested information or evidence, he or she may close the Complaint and inform the Customer of the outcome in accordance with Sections 6.9 to 6.12.

6.6 The Complaint Handler shall examine and evaluate the Complaint, taking full account of all relevant statements, information, evidence and circumstances and shall maintain full objectivity and fairness at all times.

6.7 Following his/her examination of the Complaint, the Complaint Handler shall reach a decision within the time period set out in Section 6.3 (subject to the exceptions noted therein). Resolution Actions that may be chosen are set out in Section 8.

6.8 In the event that Jo Fox, Director does not agree with the Complaint Handler's decision and/or Recommendation under Section 6.10 he/she must give reasons for such disagreement and the Complaint Handler shall have a further 10 Business Days to revise his/her decision and/or Recommendation and resubmit it to Jo Fox, Director for review and authorisation. If, following resubmission, Jo Fox, Director still does not agree with the decision and/or Recommendation, Jo Fox’s preferred decision and/or Recommendation shall be final.

6.9 Upon reaching a decision under Section 6.9, the Complaint Handler shall send an Investigation Report and Decision Letter to the Customer by first class post or by email, as appropriate. Decision Letters shall set out the decision, the Resolution Action(s), and shall remind the Customer of their right to escalate the Complaint to Level Two. 3 copy/copies of the Investigation Report and Decision Letter should be logged via the internal system and copies given to both Directors.

6.10 If a delay either occurs or is considered likely to occur at any stage of the Level One procedure, the Complaint Handler shall inform the Customer using the Customers preferred communication method. The Customer should be informed of the length or likely length of the delay and the reasons therefor.

6.11 The Customer shall have a time limit of 30 Business Days within which to make an Appeal if he/she wishes to escalate the Complaint to Level Two.

6.12 Upon receipt of an Appeal, the following steps should be taken within 5 Business Days by the Complaint Handler:

6.12.1 If a written Appeal is received by post, the Complaint Handler must log it via the internal system;

6.12.2 If a written Appeal is received by email, the Complaint Handler must log it via the internal system;

6.12.3 If an Appeal is made by telephone, the Complaint Handler must log it via the internal system.

6.13 All Appeals must be forwarded to an appropriate Appeal Handler, selected in accordance with Section 7.1 within five Business Days.

6.14 All Appeals must be acknowledged in writing within 10 working days of receipt by Erica Gaffney. The acknowledgement should inform the Customer of their assigned Appeal Handler.

7. Level Two Complaints

7.1 Upon receipt of an Appeal, the Appeal Handler shall consider the Appeal and make a decision within ten Business Days whether to:

7.1.1 Investigate the Complaint fully if it is considered to be valid, in which case the procedure should resume from Section 7.3; or

7.1.2 Dismiss the Complaint if it is considered to be invalid, in which case the Appeal Handler should inform the Customer of his/her decision in writing within ten Business Days. If the Complaint is so dismissed, the Complaint may be dismissed in its entirety, or the Resolution Action from Level One may stand.

7.2 Subject to delays arising from circumstances beyond his/her reasonable control (including, but not limited to, delays in other persons responding to communications), the Appeal Handler shall have a period of ten Business Days in which to fully investigate the Complaint and to decide upon appropriate Resolution Action(s).

7.3 If the Complaint relates to (a) particular Complainee(s), the Appeal Handler shall inform the Complainee(s) in question of the Appeal and arrange meetings and/or telephone calls as required to discuss the Complaint. In such cases, the Complainee(s) should not, under any circumstances, contact the Customer directly regarding the Complaint. If the Customer contacts the Complainee(s) directly regarding the Complaint (which they are requested not to do in our Complaints Policy), the Complainee(s) should respectfully refuse to discuss the matter, referring the Customer to Section 5.3.3 of our Complaints Policy. Any such contact should be reported to the Appeal Handler.

7.4 If the Appeal Handler requires additional information or evidence in support of the Complaint, the Appeal Handler shall contact the Customer using the Customer's preferred method of communication, stating clearly what information or evidence is required. Customers should be respectfully reminded that any delay in their response to such a request may delay the resolution of their Complaint, as per Section 5.3.4 of our Complaints Policy.

7.5 If a Customer is unable or unwilling to provide information or evidence requested under Section 7.5, the Appeal Handler must nevertheless use all reasonable endeavours to resolve the Complaint. If, however, the Appeal Handler considers that it is not possible to uphold the Complaint in the absence of the requested information or evidence, he or she may close the Complaint and inform the Customer of the outcome in accordance with Sections 7.9 to 7.12.

7.6 The Appeal Handler shall examine and evaluate the Complaint, taking full account of all relevant statements, information, evidence and circumstances and shall maintain full objectivity and fairness at all times.

7.7 Following his/her examination of the Complaint, the Appeal Handler shall reach a decision within the time period set out in Section 7.3 (subject to the exceptions noted therein). Resolution Actions that may be chosen that may be chosen are set out in Section 8.

7.8 Upon reaching a decision, the Appeal Handler shall send an Investigation Report and Recommendation for review and authorisation by Jo Fox, Director who shall be required to respond within five Business Days.

7.9 In the event that Jo Fox does not agree with the Appeal Handler's decision and/or Recommendation under Section 7.10 he/she must give reasons for such disagreement and the Appeal Handler shall have a further ten Business Days to revise his/her decision and/or Recommendation and resubmit it to Jo Fox, Director for review and authorisation. If, following resubmission, Jo Fox still does not agree with the decision and/or Recommendation, Jo Fox's preferred decision and/or Recommendation shall be final.

7.10 Upon receiving approval or a final decision under Section 7.10 or 7.11, as applicable, the Appeal Handler shall send an Investigation Report and Decision Letter to the Customer by first class post or by email, as appropriate. Decision Letters shall set out the decision and the Resolution Action(s). 3 copy/copies of the Investigation Report and Decision Letter should be logged via the internal system and copies sent to both Directors.

7.11 If a delay either occurs or is considered likely to occur at any stage of the Level Two procedure, the Appeal Handler shall inform the Customer using the Customer's preferred communication method. The Customer should be informed of the length or likely length of the delay and the reasons therefor.

8. Resolution Actions

When handling Complaints, Complaint Handlers and Appeal Handlers may select from the following Resolution Actions, as appropriate to the facts and circumstances of a Complaint:

 

8.1 A letter will be sent to the Complainant to explain what actions will be taken to ensure the reason for the Complaint does not occur again;

8.2 A refund, where appropriate, can be given;

8.3 Employee disciplinary action, where appropriate, can be undertaken;

9. Implementation of Resolution Actions

Upon the conclusion of a Complaint, whether at Level One or Level Two the Resolution Action(s) settled upon shall require implementation in a timely manner. Responsibility for the implementation of Resolution Actions ultimately lies with the following:

 

9.1 Resolution Actions pertaining to customer service, or the sale of products or services shall be the responsibility of: Erica Gaffney, Business Development Manager, erica@strengtheningpractice.co.uk;

9.2 Resolution Actions pertaining to the behaviour and/or professional competence of our employees shall be the responsibility of: Jo Fox, Director, jo@strengtheningpractice.co.uk;

10. Recording of Resolution Actions

10.1 Upon the conclusion of a Complaint and the implementation of the applicable Resolution Action(s), Erica Gaffney shall record the action on the internal system.

11. Confidentiality and Data Protection

11.1 All Complaints, Appeals, evidence and other information gathered, held and processed under this Complaints Handling Procedure shall be treated with the utmost confidence at all times. Such information may be shared with employees of Strengthening Practice only to the extent required to resolve the Complaint in question in accordance with this Complaints Handling Procedure.

11.2 In the event that the details of a Complaint are to be used for training or quality improvement purposes, in which case they will be shared with other employees of Strengthening Practice beyond the scope of this Complaints Handling Procedure, the relevant Customer’s express permission must first be sought using that Customer's preferred contact method. Personal details (that is, anything that may be used to identify the Customer) shall be removed from all information so used. Such permission may be revoked at any time in accordance with the Customer's right to do so under Section 6.2 of our Customer Complaints Policy.

11.3 All personal information collected by Strengthening Practice (including, but not limited to, Customers’ names and contact details) shall only be collected, used and held in accordance with the provisions of UK data protection law (including but not limited to the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003) and Customers’ rights thereunder, as set out in our Privacy Policy.

12. Procedure Review and Responsibility

12.1 Overall responsibility for this Complaints Handling Procedure and the implementation thereof lies with Jo Fox and Pete Fox, Directors of Strengthening Practice.

12.2 This Complaints Handling Procedure shall be reviewed regularly at intervals of not more than 12 months and shall be updated as required.

12.3 This Complaints Handling Procedure was adopted in March 2022.

12.4 This Complaints Handling Procedure was last reviewed in March 2022.