Accessibility and awareness

‘Organisations should make it easy for individuals to complain by providing different channels through which they can make a complaint. Organisations must consider their duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of individuals who may need to access the complaints process.’ (Paragraph 3.1 of the Complaint Handling Code)

A well-publicised and accessible complaints process is essential in fostering an organisational culture which is fair and open to challenge and learning. This can be measured through the number of complaints received each year.

We have published two focus reports covering access to services and learning from complaints about people’s human rights. Both reports contain important learning for organisations when developing and delivering complaints processes.

Organisations should ensure that all customer facing staff are aware of the complaints policy and how people can raise complaints. Training in accepting complaints should be covered as part of any customer service training. Information about an organisation’s complaints process should also be shared with new staff as part of their induction.

Information about the complaints process should be made available where members of the public are asked to provide feedback on services. This gives the public an opportunity to raise individual concerns with the organisation at the same time as providing general feedback. It also demonstrates to the public that the organisation is open to considering complaints alongside seeking wider feedback about services.

Making reasonable adjustments

The Equality Act 2010 says organisations exercising public functions must anticipate the needs of people with disabilities who may need to access services and make appropriate reasonable adjustments.

The government has published guidance on accessible communications. This says organisations can reduce the need for producing a range of accessible information about its services by designing initial documents with accessibility in mind. This is a cost and time-efficient way of making information instantly accessible for a larger number of people.

Organisations should also ensure complainants can raise concerns through a range of channels. Many organisations have prioritised the use of online systems as the primary means of receiving complaints from the public. This is cost effective, and may meet the needs of neurodiverse individuals who may find it difficult to speak to someone over the telephone or face to face. However, online systems should be accessible and organisations should also ensure complainants can easily raise complaints through other channels, such as over the telephone.

Not every disability is visible and so it is important that organisations provide individuals with the opportunity to disclose any reasonable adjustments they may need when making a complaint.

Organisations may consider including the following wording in complaint forms, along with a text box, to invite people to advise them of any reasonable adjustments they may need:

‘We are committed to making sure the way we work does not put disabled people at a disadvantage and to meeting our legal obligations under the Equality Act 2010.

If you need any help or support to use our service, please let us know and we will consider what changes we can make.’

If a complaint is made over the telephone, the organisation should ask whether the person needs any help or support to use the service.

Once the organisation has agreed to make reasonable adjustments it should record these clearly. This means the complainant does not have to repeatedly request for adjustments to be made. Information about individuals may be held on different systems. This means that information about reasonable adjustments agreed by one service area may not be available to officers in another service. However, we would expect services to share information about any agreed reasonable adjustments when sharing other information about a complaint.

Organisations should also write to complainants to let them know what reasonable adjustments are in place and inviting them to let them know if any changes need to be made now or in the future.

Information about any agreed reasonable adjustments should be held on file in line with the organisation’s data retention policies.