Performance reporting and self-assessment

‘Organisations should produce an annual complaints performance and service improvement report for scrutiny and challenge’ (Paragraph 8.1 of the Complaint Handling Code)

The annual complaints performance and service improvement report provides organisations with an opportunity to publicly show that they are learning from complaints. This demonstrates to the public that the organisation is open to fair challenge and improving services as a result.

The Code says the annual complaints performance and service improvement report should be published on the organisation’s website. This should include the response to the report from the Member responsible for complaints. This demonstrates to the public that complaints about the organisation are subject to scrutiny and that statutory officers are being held accountable for performance.

The Complaint Handling Code recommends organisations carry out a self-assessment against the Code. Whilst there is no legal obligation to carry out a self-assessment, this process can be helpful in demonstrating that an organisation is following the Code. If this is not the case, it provides an opportunity for organisations to highlight what work is being done to address this. If there are barriers to being able to address any issues, the annual report provides a way of highlighting this and seeking potential solutions such as the allocation of more resource. This supports the effective scrutiny of complaint handling.

The self-assessment is also a useful tool in ensuring that any significant changes within an organisation take account of complaint handling. It can help officers managing complaints processes to highlight potential risks with statutory officers and help improve the visibility of complaints processes and demonstrate their wider value.

Key performance indicators

We have issued a set of key performance indicators (KPIs) to help measure the effectiveness of complaint handling within organisations in relation to complaints dealt with under the Complaint Handling Code. These are designed to support councils to measure and demonstrate best value. We consider it good practice for these to be reported regularly alongside data relating to statutory complaints and Ombudsman investigations. These should be reported to senior officers and Members responsible for complaints or oversight of particular services.

Councils are not obliged to report on these KPIs, but we believe these provide the most relevant information on complaint handling performance. Using our recommended KPIs also gives councils an opportunity to benchmark performance against others who are also using these measures.

Councils are strongly discouraged from setting targets in relation to complaint handling as this can result in officers focussing on meeting these rather than providing a good outcome to the complaint.

Instead, we encourage councils to benchmark performance across previous quarters and on a rolling 12 month basis. We also encourage councils to benchmark performance against others who are using our recommended KPIs. Over time this will help to establish expected performance levels allowing organisations to analyse performance more closely when organisational, service level or individual performance deviates from expectations.

The KPIs are broken down into four key areas:

1. Number of complaints received.
2. Timeliness
3. Outcomes
4. Learning from complaints and remedies

We believe these KPIs should be reported for the organisation as a whole, but also broken down by department and/or service area to identify potential risks.

1. Number of complaints

The Complaint Handling Code says:

‘High volumes of complaints should not be seen as a negative, as they can be indicative of a well-publicised and accessible complaints process.  Low complaint volumes are potentially a sign that individuals are unable to complain.’

The Council should be aware of increases and decreases in complaint numbers across the organisation and in individual service areas and seek information from colleagues to understand reasons behind this.

The Council is also encouraged to look at reasons why complaints are being excluded from the complaints process to ensure people are not being unfairly denied an opportunity to have their complaint heard.

2. Timeliness

Timescales for responding to complaints set out in the Code are intended to encourage prompt and efficient complaint handling. These are not deadlines by which complaints must be responded to. Councils should let complainants know when they need more time to consider a complaint and let them know in good time. Councils should have good reasons for extending timescales for responding to a complaint. This could be because a complaint is particularly complex. It would not usually be acceptable to extend timescales for responding because the Council lacked resources to respond promptly.

Each complaint should be dealt with proportionately. This means some may take up little officer time and receive a short response, whilst others may require a thorough investigation and a detailed response.

By scrutinising data on timeliness of complaint responses, the Council can consider whether it has sufficient resources in place to respond to complaints promptly and whether it is taking a proportionate approach to considering complaints, so it focuses its resources on complaints which have the most impact on individuals and the wider public.

The average time for responding to complaints should indicate how often the organisation is responding promptly to complaints. We have suggested this is reported as an overall % of total complaints handled at stage 1 and stage 2 but organisations may choose to break this down further to provide context.

3. Outcomes

The outcomes of complaints are an important measure of the quality of complaint handling in an organisation and data can be used to identify areas where repeat findings may indicate wider issues which need to be addressed.

Outcomes are separated into four categories to support transparency and openness.

• Upheld: The organisation has accepted it was at fault in all or most areas raised by the complainant or it only identified a small number of errors or technical faults but these had a significant adverse impact on the complainant or the wider public.  

• Partially upheld: The organisation found it acted without fault in most areas raised by the complainant. However, it identified a small number of errors or technical faults and these had very little impact on the complainant or the wider public. 

• Not upheld: The organisation found it acted without fault in all areas raised by the complainant. 

• Resolved: The organisation was able to agree action it should take with the complainant to resolve the complaint and did not have to investigate further to decide whether it acted with fault. 

High or increased levels of upheld and partially upheld complaints may indicate systemic issues within services, departments or across the organisation as a whole. These should be analysed alongside data relating to resolved complaints.

Recording some complaints as “resolved” supports prompt proportionate responses to complaints. Where appropriate, organisations may be able to take action to resolve complaints without the need for a detailed investigation. This benefits both the organisation and the complainant. However, organisations should not seek to provide people services they are not entitled to in order to resolve complaints. High levels of resolved complaints may indicate that services are missing opportunities to resolve issues through normal service delivery.

4. Learning from complaints and remedies

The resolution of complaints is an important measure of the council’s willingness and ability to put things right.

Understanding how frequently this happens as well as the types of complaints where remedies are provided also gives insight into the impact of failings on individuals and the wider public. Remedies should be provided within timescales provided to complainants. Failure to do this may lead to further complaints and a decrease in the level of trust between the individual and the council.

Details of service improvements made as a result of learning from complaints are also an important indicator of the culture of an organisation. Councils that learn from complaints, even where a complaint is not upheld, are more likely to have a wider culture of openness and transparency which aids good governance.

Service improvements are difficult to quantify. Therefore organisations are encouraged to report qualitative data to Members summarising the types of service improvements achieved as a result of learning from complaints. This may include learning from complaints data as well as individual complaints. If a particular service area has not recorded any service improvements this may warrant further scrutiny.

Officers overseeing complaints systems should identify opportunities to share learning from complaints between different services or across the organisation. It is often the case that learning from a complaint in one service area will benefit other services.

Ombudsman decisions and data

Data and learning from Ombudsman investigations should be included in any regular reporting on complaint performance.

Councils are encouraged to share learning from Ombudsman investigations across the organisation and particularly with services that were not subject to the complaint but may benefit from understanding what went wrong and how this could have been prevented.

Equality monitoring data

Organisations should collect data on the protected characteristics of people who complain. This should be collected at the point the person first raises a complaint but should not be made available except for statistical analysis. By analysing data collected, organisations can assess whether complaint systems are equitable and fair and whether they disproportionately affect different groups.

Oversight of statutory complaints

It is considered good practice for data about complaints handled under the Complaint Handling Code to be considered alongside data about statutory complaints processes. This provides the council with an overview of complaint handling performance across the organisation.

We believe data about adult social care and children’s services complaints in particular should be reported alongside the recommended KPIs set out above. This complaint data should also be shared regularly with elected officials responsible for overseeing those services.