Consumer Complaints Management Policy and Procedure

Disability Services Commission
Consumer Complaints Management
Policy and Procedure
December 2011
Consumer Complaints Management Policy and Procedure December 2011

Table of Contents
Page No.
Part 1 - Consumer Complaints Policy 2
Part 2 - Consumer Complaints Procedure
1 Introduction 6
2 Complaint definition 6
3 Complaints management stages 8
4 Procedural fairness 14
5 Staff support 14
6 Confidentiality 14
7 Documentation of complaints 15
8 Complaints about disability sector organisations 15
9 Brochures 15
Appendices
Appendix 1 - Consumer Complaint Data Form 17
Appendix 2 - Sample complaint report 19
Appendix 3 - Sample paragraph for complaint response re
review and external independent help 20
Appendix 4 - Complaint action plan/record 21
Appendix 5 - Summary of staff roles in complaint management 22
Appendix 6 - Consumer Liaison Service – contact list 24
Appendix 7 - Performance standards 26
Appendix 8 - Complaints Management Standards 28
Appendix 9 - The Western Australian Carers Charter and meaning of ‘carer’ 29
Consumer Complaints Management Policy and Procedure December 2011 1

Disability Services Commission
Part 1: Consumer Complaints Policy
2011
1. Keywords
Consumer, complaint, dissatisfaction, concerns, Consumer Liaison Service, people with
disability, carer, advocate
2. Policy statement
The Disability Services Commission recognises and promotes the right of people with disability,
their families, carers 1 and/or advocates to raise and discuss their concerns regarding the
provision of services by the Commission.
People with disability, their families, carers and/or advocates may feel vulnerable when making
a complaint and negotiating a resolution. This feeling of vulnerability can be compounded for
people from Aboriginal and culturally and linguistically diverse (CaLD) backgrounds. The
principles of this policy are written within this context.
The policy, which is outlined below, is in keeping with the Disability Services Act (1993), the
Disability Services Standards and the Carers Recognition Act 2004.
3. Principles
Principle 1:
People with disability, their families, carers and/or advocates have the right to raise any
complaints or concerns regarding any matter related to services provided by Commission
staff, and to have their concerns investigated and resolved fairly and quickly.
Principle 2:
People with disability, their families, carers and/or advocates raising a complaint should
be able to express their concerns and feel reassured that there will be no retribution.
Principle 3:
People with disability, their families, carers and/or advocates wishing to raise a complaint
can do so at any level in the organisation. However it is generally preferable to resolve
complaints at the level at which they occur, if possible.
Principle 4:
People with disability, their families, carers and/or advocates have the right to be
informed about the internal and external avenues open to them to raise their concerns,
and how their complaint will be handled by the Commission.
1 Carers are usually family members (but they may be a friend or neighbour) who provide
ongoing support and assistance to a person, who may be a child or adult, who has a disability, a
chronic illness, a mental illness or is frail and requires assistance with daily activities. See
Appendix 9.
Consumer Complaints Management Policy and Procedure December 2011 2

Principle 5:
The complaints process will be consumer oriented, culturally secure, accessible, timely,
efficient, confidential and not encumbered by bureaucratic ‘red tape’.
Principle 6:
The principles of natural justice must be followed for all parties involved in a complaint.
Principle 7:
People have the right to have a friend or advocate support them in raising their concerns.
Principle 8:
Complaint handling should, whenever possible, focus upon improving services for people
with disability.
4. Definitions
Complaint
A complaint is an expression of dissatisfaction with any aspect of Commission-provided
services made by people with disability, their families, carers and/or advocates that is not typical
of regular communication or feedback about services. From the viewpoint of the complainant,
the involvement of management staff is required to achieve a satisfactory resolution to the
concern raised.
Consumer
In the context of this policy the term consumer is used to refer to the following:
• a person with disability who has applied for or is receiving a service provided by the
Commission
• a carer, relative or advocate of a person with disability who has applied for or is receiving
a service provided by the Commission.
Resolution
A complaint or dispute is ‘resolved’ when it is settled or concluded, and each of the parties is
notified of the outcome. ‘Resolved’ does not necessarily mean that the complaint or dispute is
concluded in favour of any of the parties.
5. Background
This policy directs the Commission’s consumer complaints service. It was established in May
1994 as a requirement of the principles and objectives in the Disability Services Act (1993) and
the National Disability Services Standards. It was reviewed and/or updated in consultation with
relevant internal and external stakeholders in 2002, 2006, 2007, 2009 and 2011.
Consumer Complaints Management Policy and Procedure December 2011 3

6. Implementation
Executive Directors are responsible for ensuring the principles of this Policy and the associated
Complaints Procedure are observed in their directorate. The procedures, in Part 2 of this
document, are based on the following guidelines:
• complaints will be acknowledged within 24 working hours
• complaints will be responded to within 10-15 working days
• records will be kept of all complaints raised, contacts with complainants, action taken and
outcomes reached
• complaint documentation will be made available to complainants on request (except that
which may violate the confidentiality of other consumers) and this should be kept in mind
when records are made
• confidentiality will be maintained at all times, and complaints will only be discussed with
staff on a ‘need to know’ basis
• if the complaint involves alleged misconduct by Commission staff (including volunteers)
the Operational Procedures for Managing a Suspected Breach of Discipline will be
followed
• any complaint involving an illegal action will be referred to the appropriate authority
• a staff member against whom an allegation is made will be given the opportunity to have
their say. In the event that the allegation is unsubstantiated, any record will be removed
from their personal file
• all staff will be informed of and familiar with the Consumer Complaints Policy.
7. Funding or resource implications
Currently funded program.
8. Related policies, legislation and standards
• Disability Services Act (1993)
• Disability Services Standard 7 - Complaints and Disputes
• Complaint Handling Australian Standard AS ISO 10002-2006
• Access for Aboriginal and Torres Strait Islander people with disabilities Policy and Practice
Plan April 2006
• The Western Australian Language Services Policy 2008
• Substantive Equality Statement of Commitment for People with Disabilities February 2006;
• Reconciliation Action Plan 2010-2012
• Policy, Guidelines and Operational Procedures For Managing Suspected Breaches of
Discipline - May 2006
• Carers Recognition Act 2004.
Consumer Complaints Management Policy and Procedure December 2011 4

9. Communication
This policy is available on the Commission’s intranet and website. Information brochures about
the complaint process are provided to new consumers by Local Area Coordinators and the
Eligibility Coordinator. Information brochures are available on the Commission’s website in
English and other languages. Additional languages and formats can be provided on request.
Articles about how to raise concerns are regularly published in Commission newsletters to
consumers.
10. Training
The Consumer Liaison Officer trains the Local Consumer Liaison Officers and provides briefings
to each directorate annually.
11. Evaluation and review
This policy is evaluated according to the standard Director General policy review mechanism.
This policy replaces the Consumer Complaints Management Policy and Procedure - May 2009.
Officer responsible: Director General, Disability Services Commission
Author:
Fran Tyler
Date: December 2011
Consumer Complaints Management Policy and Procedure December 2011 5

Disability Services Commission
Part 2: Consumer Complaints Procedure
2011
1. Introduction
The Disability Services Commission is committed to the protection of rights of people with
disability and the promotion of quality services.
The Commission welcomes feedback from people with disability, their families, carers and/or
advocates about any concerns they may have. Feedback enables us to correct any problems
with our service, improve our relationship with our consumers and improve the overall quality of
our services.
The Commission encourages staff members providing direct client services to actively resolve
any consumer concerns they encounter in the first instance. This approach reduces the need for
people with disability, their families, carers and/or advocates to lodge a formal complaint.
Staff need to be aware that, for people from Aboriginal and CaLD backgrounds, cultural and
language factors may affect how comfortable they feel to participate in a complaints process.
Therefore additional culturally appropriate support may be required.
The procedures outlined below are to assist staff to respond promptly, effectively and consistently
to feedback received from people with disability, their families, carers and/or advocates.
2. Complaint definition
2.1 A complaint is an expression of dissatisfaction with any aspect of Commission-provided
services made by people with disability, their families, carers and/or advocates that is not typical
of regular communication or feedback about services. From the viewpoint of the complainant,
the involvement of management staff is required to achieve a satisfactory resolution to the
concern raised.
2.2 A complaint is additionally classified as serious when:
• it may result in a legal action – civil, criminal, or an administrative action such as a
disciplinary hearing
• there is an allegation of physical, sexual, or emotional abuse or neglect of a client by
a Commission employee
• the action of a staff member or another client may have resulted in death or serious
injury of the complainant
• any action taken by a staff member is outside the Public Service Guidelines, the
Commission’s standards, code of conduct/ethics for the specific profession(s)
• a complaint may have an impact on the Commission as a whole.
Specific guidelines for handling serious complaints are outlined below in section 3.2.2.
Consumer Complaints Management Policy and Procedure December 2011 6

2.3 2.3.1 Selection of complaints for investigation
Where a complainant raises multiple issues of complaint, the Commission may elect to
identify certain issues and investigate only those issues. The decision to limit the scope
of a complaint investigation will be approved by the Director General and the complainant
must be advised in writing of the decision and the reasons for that decision. Reasons for
not taking up a particular complaint issue may include, but are not limited to, the
following:
• the issue has been investigated or dealt with previously
• the issue is unsubstantiated or unverifiable
• the issue is not current and occurred more than two years ago
• the issue is vexatious.
2.3.2 Prioritisation of issues for complaint investigation
Where there are multiple issues of complaint that are reasonable to investigate, the
Commission may elect to address the issues in a particular order, rather than investigate
all issues concurrently. The decision to do so will usually be based on the availability of
resources and the need to ensure that ongoing services are not disrupted.
Consumer Complaints Management Policy and Procedure December 2011 7

3. Complaints management stages
The three stages of the Commission’s complaints management process are summarised in the
diagram below. Staff need to ensure that a complaint is not subject to more than one internal
review, as it tends to deter the complainant and does not produce consumer satisfaction.
Procedures for handling consumer complaints follow.
Stage 1
↓
Pre-grievance
Consumer feedback - resolved by staff providing direct consumer services
↓
Stage 2
↓
Formal complaint - internal process
Tier 1
Standard complaint handling
• Complaint coordinators resolve complaints wherever possible at first
contact
• Complaint coordinators log complaint details and forward to Consumer
Liaison Officer for entry on database and later analysis
Tier 2
Internal review or investigation
• Director General or a nominee, Executive Director or Consumer
Liaison Officer reviews/investigates unresolved complaints
↓
Stage 3
↓
Tier 3
External independent review
Unresolved complaints are referred to an appropriate external avenue such
as the Health and Disability Services Complaints Office or the Ombudsman.
Consumer Complaints Management Policy and Procedure December 2011 8

Staff procedures for handling consumer complaints
3.1 Stage 1: Pre-grievance
Consumer feedback – concerns resolved directly with staff
Consumers are encouraged to discuss any concerns or dissatisfaction they may have
directly with the staff member who provides the service before lodging a formal
complaint. Within the Accommodation area, this sometimes may involve the local area
supervisor.
Staff should do what they can to try to resolve the concerns. In most cases staff can deal
with the concerns of consumers promptly and successfully within the existing service
relationship, or through discussion with relevant staff. In such cases, it is not necessary
to define the consumer’s concern as a complaint.
Consumers who have been unable to have their concerns resolved during this stage may
wish to lodge a formal complaint. The staff member should advise them of their right to
raise a formal complaint and should refer them immediately to the relevant manager or
the Consumer Liaison Officer if they do wish to pursue the matter further.
Note: The consumer complaint data form is not required at the pre-grievance stage.
Consumer Complaints Management Policy and Procedure December 2011 9

3.2 Stage 2: Formal complaint – internal process
3.2.1 Standard complaint handling
1. Preliminary assessment of a complaint
1.1 Is the complaint within DSC’s No
jurisdiction?
Redirect to appropriate agency or redirect to CLO
for advice.
Yes
go to 1.2
1.2 Is the complaint within the staff
member’s area of
responsibility? Note that
serious complaints - see 2.2
and 3.22 – should be referred
to the appropriate Executive
Director)
1.3 Is the complainant the client
affected or an interested party
(ie. family member, carer,
friend, advocate or
organisation)?
1.4 Is the complaint sufficiently
clear with respect to the nature
of the complaint and the
solutions sought? Document
complaint issues and ask
complainant to sign; provide
copy to complainant.
1.5 Has the complainant been
advised how the matter will be
followed up, any limitations to
providing the solutions sought,
and the expected timeframes
for providing feedback and
resolving the complaint?
1.6 Does the complainant
understand the complaint
process?
No
Take the complainant’s contact details.
Immediately refer to the appropriate line manager,
or the CLO. Inform the complainant of name of
staff member who will contact them.
Yes
go to 1.3
No
Establish if complainant has appropriate authority
to lodge the complaint. Seek advice from the CLO
if necessary.
Yes
go to 1.4
No
Further clarification with complainant as necessary.
Is additional assistance required for cultural or
language reasons? Obtain appropriate support.
Clarify and document.
(Appendix 2: Complaint report)
Yes
go to 1.5
No
Clarify with complainant. Is additional assistance
required for cultural or language reasons? Obtain
appropriate support.
Yes
go to 1.6
No
Clarify with complainant. Is additional assistance
required for cultural or language reasons? Arrange
accordingly. Ensure the complainant has a copy of
the Complaints Policy or knows how to access one.
Yes
Consumer Complaints Management Policy and Procedure December 2011 10

2. Responding to the complaint
2.1 Initial acknowledgement of the complaint should be within 24 working hours.
2.2 All complaint contact and actions should be documented (see Appendix 4: Complaint
action plan/record), including the initial contact with the complainant acknowledging their
complaint. You must also document the efforts made to contact the complainant, in the
event that contact could not be made with the complainant in a timely fashion.
2.3 The timeframe to respond will vary according to the complexity of the complaint. As a
guide, 10-15 working days should be sufficient time to respond for most complaints. For
longer complaints, keep the complainant informed of progress at least every 10 working
days.
2.4 Investigate the complaint, checking the evidence (written information, discussion with
relevant staff) relating to each issue.
2.5 Plan a response to address the complaint, seek senior management endorsement if
necessary, and communicate proposed response to the complainant. Confirm response
in writing if appropriate.
2.6 If the complainant is not satisfied, consider whether any other actions may be taken to
resolve the matter. Inform the complainant of their right to have their complaint reviewed
by the Consumer Liaison Officer, and the Health and Disability Services Complaints
Office (refer to Appendix 3: Sample paragraph for complaint response).
Consumer Complaints Management Policy and Procedure December 2011 11

3. Documentation
3.1 Have you documented all details
of the complaint, from initial
contact to resolution?
Yes
No
Document all information (see
Appendices 2 and 4 for optional
templates)
3.2 Have you completed the
Consumer Complaint Data
Form?
Yes
No
Complete Form
3.3 Have you forwarded the
completed Consumer Complaint
Data Form with the complaint
documentation to the Consumer
Liaison Officer?
Yes
No
Send data form and documentation
to Consumer Liaison Officer
Note:
‣ please forward all forms, at the end of each month, even if the complaint has not
been finalised. All other documents can be forwarded to the Consumer Liaison
Officer upon finalisation.
‣ for confidentiality purposes, documents referring to a complaint ARE NOT kept on
the client’s file. Make a note on the file, such as ‘a report is contained on the
Consumer Liaison Officer’s restricted file’.
3.2.2 Process for handling serious complaints
Serious complaints are defined in section 2.2.
• An Executive Director or a nominee handles serious complaints.
• Staff must refer to the appropriate Executive Director as soon as they recognise that
the complaint falls into the serious category.
• Documents and other evidence are placed in safe keeping as soon as the complaint
is reported to the Executive Director.
• The Executive Director may need to notify the Police or other relevant external
bodies such as the Department for Child Protection, the Office of the Public
Advocate, or a professional registration board.
• Some serious complaints will require the Operational Procedures for Managing a
Suspected Breach of Discipline to be followed, rather than the consumer complaint
procedures.
• The Director General signs the response to the complainant.
Consumer Complaints Management Policy and Procedure December 2011 12

3.2.3 Internal review of complaints
Consumers or carers should be offered an internal review if they are dissatisfied with the
process used to handle their complaint or if they are dissatisfied with the outcome.
• Complaint reviews are handled by relevant senior managers, Executive Directors, the
Director General or the Consumer Liaison Officer.
• The process is the same as for a standard complaint until the final resolution.
• The complaint report and suggested resolution must be submitted to the Director
General for approval and to the Consumer Liaison Officer to ensure that the
Commission:
(i) confines the complaint to a two tier internal review
(ii) can be accountable for its internal handling of the complaint.
• The Director General signs the response to the complainant.
3.3 Stage 3: External independent review
Complaints that are not able to be resolved using the Commission’s complaint processes
should be referred to an appropriate external body.
Health and Disability Services Complaints Office
Under Part 6 of the Disability Services Act the Health and Disability Services Complaints
Office (HADSCO) may investigate complaints about disability services, including
complaints about non-compliance with the Carers Charter. Complaints must be raised
with the Health and Disability Services Complaints Office within two years of the
incident/s occurring, unless there is a good reason for the delay.
Ombudsman
The Ombudsman handles complaints about administrative matters involving State
Government departments and statutory authorities. The Ombudsman also assists where
a problem spans two or more government departments.
Consumer Complaints Management Policy and Procedure December 2011 13

4. Procedural fairness
In the resolution of any complaint, the concept of fair play must apply to both the complainant
and the respondent. Procedures and practices need to be applied flexibly and adjusted
whenever necessary to suit each individual’s circumstances. Accordingly:
• decision-makers must act fairly and without bias
• those directly involved in the complaint should not act as decision-makers
• all parties to the matter should have the opportunity to put their case forward and have all
relevant arguments considered before a decision made
• if a complainant uses abusive, obscene or threatening language towards a Commission
employee, the employee may terminate a conversation or interview, usually after provision
of a warning
• all persons need to be informed of the basis of a decision, where that decision affects
them.
5. Staff support
Line managers have responsibility to ensure that staff who are the subject of a complaint
receive appropriate information and support. Staff have the right to have a support person
present at any stage of the complaints resolution process. They may seek the support of a
union representative if they are a member or any other person. Staff may also contact any of
the Commission’s nominated support persons for support.
Staff, who are the subject of a complaint, are entitled to provide a written response to the
complaint coordinator outlining their perspective on the complaint issues.
Staff must be advised of investigation progress (not details) and the final outcome.
The Commission recognises that some complaints may initially focus on staff actions but
eventually can reveal systemic or procedural difficulties needing attention. When investigation
of the complaint does not identify any substantiated performance issues involving the staff
member, no record of the complaint will be retained on the staff member’s personal file.
6. Confidentiality
Confidentiality will be maintained in relation to all aspects of the complaint, within reasonable
bounds required to conduct an investigation and facilitate a resolution of the complaint.
Information about the complaint should be made known to staff members on a ‘need to know’
basis only.
Complaint records will be stored by the Consumer Liaison Officer on confidential complaint files
with restricted access, and should not be retained on any other client files.
Consumer Complaints Management Policy and Procedure December 2011 14

7. Documentation of complaints
(a)
(b)
(c)
(d)
All Stage 2 and Stage 3 complaints (including ministerials) must be recorded. For
each complaint received, the complaint coordinator completes the Commission’s
consumer complaint data form and forwards it to the Consumer Liaison Officer for central
complaints data collation. (Note: the data form is available at Appendix 1 or on the
intranet).
All forms are to be forwarded at the end of each month. The Consumer Liaison Officer
submits monthly reports to the Director General and Executive Directors on the number
of complaints received, nature of complaint and outcome. The CLO will follow up with
the complaint coordinator any open cases.
To preserve client confidentiality, present and future, the term complaint should not be
used on the main client file. ‘A report is contained on the Consumer Liaison Officer’s
restricted file’ should be the only reference that goes onto a client’s main file.
The complaint report and associated paperwork must be forwarded to the Consumer
Liaison Officer, who will arrange for Records to create a Restricted File for confidential
storage of the complaint documentation.
If the complaint coordinator has recommended some systems change or corrective
action, appropriate steps should be taken to have these implemented. In some cases,
the complaint coordinator may need to prepare a briefing paper or draft policy for
presentation via the Executive Director to Corporate Executive.
8. Complaints about disability sector organisations
Where consumers report a complaint about a Commission-funded disability sector organisation:
• staff should inform complainants that the Commission requires disability sector
organisations to have consumer complaint procedures, and these should be followed
• if the complaint cannot be resolved using the organisation’s complaints procedures, or if
the consumer believes that an independent review is necessary, the complaints
provisions in Part 6 of the Disability Services Act (1993) are available. The consumer
contacts the Director of the Health and Disability Services Complaints Office and asks to
make a complaint under the provisions of Part 6 of the Disability Services Act (1993).
9. Brochures
• Help us to help you – is a pamphlet which describes the complaints process
• How to have your say – this booklet provides information on avenues for registering a
complaint about any of the services provided to people with disability.
The brochures may be available in or translated to other languages or accessible formats
upon request to the Policy and Strategy Directorate.
Consumer Complaints Management Policy and Procedure December 2011 15

Informing consumers about the complaint process
• Local Area Coordinators provide the Commission’s consumer complaint
brochures to new clients and discuss the complaints process within three months
of the commencement of the service.
• Line managers ensure that consumer complaint brochures are displayed and
available to consumers at Colin Street head office, Accommodation, Statewide
Specialist Services and LAC offices.
• LAC Regional Managers ensure that articles about consumer complaint
processes are published at least annually in LAC newsletters.
• The Senior Eligibility Coordinator mails the Commission’s consumer complaints
pamphlets with the eligibility letter for new clients with an intellectual disability or
autism spectrum disorder.
• The Consumer Liaison Officer ensures that the consumer complaint brochures
are available to consumers on the Commission’s website, and available to staff on
the intranet.
Consumer Complaints Management Policy and Procedure December 2011 16

Consumer Complaint Data Form
Confidential – not to be placed on client file
Part 1 – Complaint Details
Consumer
Surname
Address
Given name
Postcode D.O.B Gender Male Female
Phone
no.
Home Other DSC
File
No.
Complainant (i.e. person lodging the complaint, if different from above)
Surname
Given name
Address
Phone
no.
Home
Other
Relationship to consumer (please mark appropriate box):
Parent
Carer
Other relative
Guardian
Advocate/Friend
Member of public
Organisation
Postcode
Complaint under Carers Recognition Act
Yes
No
DSC Complaint Coordinator (i.e. the staff member managing the
complaint)
Name
Phone
Date complaint
Date complaint
received
closed
Complaint Area (please tick appropriate box)
Local Area Coordination
Statewide Specialist Services
Accommodation
Eligibility
Other (please specify)
Policy and Strategy
Service Contracting &
Development
Community & Sector
Development
Corporate Services
Brief description of complaint
Please notify the CLO of any new complaints before the end of each month.
Consumer Complaints Management Policy and Procedure December 2011 17

Standard to which the complaint relates (please mark appropriate
box/es)
1. Service Access
2. Individual Needs
3. Decision Making & Choice 4. Privacy, Dignity &
5. Participation & Integration Confidentiality
7. Complaints & Disputes
6. Valued Status
8. Service Management
9. Protection of Human Rights & Freedom from Abuse & Neglect
Classification of Complaint (please mark appropriate box/es)
Funding policy
Quality of service
Resident conduct
Other (please specify)
Lack of resources
Staff conduct
Communication
Service eligibility
Co-resident conduct
Part 2 – Outcome of Complaint
Outcome (please mark appropriate box)
What was the outcome from the point of view of the complainant?
Resolved
Withdrawn
Partly resolved
Referred to another complaint
avenue
Was the complainant satisfied with the handling of the complaint?
Yes No Unknown
Was the complainant satisfied with the outcome of the complaint?
Yes No Unknown
What was the remedy?
Apology
Discipline
Referral
Service modified
Other (please specify):
Apology-explanation
Explanation
Service increased
Service withdrawn
Unresolved
Unknown
Decision changed
Policy changed
Service improved
System changed
Give brief details of any service/system improvement resulting from this
complaint:
Complaint coordinated/resolved by (please mark appropriate box)
Director General
Consumer Liaison Officer
Other staff member
Local Consumer Liaison Officer
Line Management (Supervisor,
Coordinator, Manager, Executive
Director)
Consumer Complaints Management Policy and Procedure December 2011 18

For data analysis and confidentiality in record keeping, please return the completed Complaint
Data Form and all associated complaint documents to:
Consumer Liaison Officer
2 nd Floor, 146-160 Colin St, West Perth 6005
Email: clo@dsc.wa.gov.au Fax: 9226 2313 Phone: 9426 9244
Please notify the CLO of any new complaints before the end of each month.
Thank you for your assistance.
Consumer Complaints Management Policy and Procedure December 2011 19

Appendix 2
Consumer Liaison Service
Sample complaint report
Client:
(Name, DSC File No., D.O.B. contact details)
Complainant:
(Name and contact details)
Date:
(Name of complainant) raised the following issues (eg. during a home visit, a telephone
conversation) on_________________ with (name of complaint coordinator)
Complaint Background:
(brief description of client’s circumstances and situation leading to complaint)
Complaint Issues:
(list the issues in dot point)
Solutions Sought:
(in dot points list the solutions the complainant is seeking to each of the issues listed above)
Investigation/Action Taken:
(describe the actions taken to follow up the concerns)
Outcome/Resolution:
(briefly describe the outcome of the complaint and any improvements implemented as a
result)
__________________________________
(Name of Complaint Coordinator)
(insert date)
Consumer Complaints Management Policy and Procedure December 2011 20

Appendix 3
Sample paragraph for complaint response:
review and external independent help
All responses to the complainant must include the following information:
In the event that you are not satisfied with the response to your complaint, you can ask the
Commission’s Consumer Liaison Officer, to review the matter. The Consumer Liaison Officer
can be contacted on 9426 9244 or at clo@dsc.wa.gov.au. Alternatively, if you wish to have
your concerns examined by an independent and external agency, you may contact the
Health and Disability Services Complaints Office (HaDSCO) on 9323 0600. I have enclosed
a brochure for your information.
Consumer Complaints Management Policy and Procedure December 2011 21

Appendix 4
Complaint action plan/record
A chronological record of contacts and actions planned and/or made during the investigation of
a complaint. Reference should be made to File Notes for detailed information of the contacts.
Client:_________________________________________________________________
Complainant:___________________________________________________________
Complaint Coordinator:_____________________________________________
Date Time Contact/Action
Consumer Complaints Management Policy and Procedure December 2011 22

Appendix 5
Summary of staff roles in complaint management
1. Direct service providers
(a)
(b)
(c)
(d)
Knowledge of the Commission’s complaints management procedures, Local
Consumer Liaison Officers, Consumer Liaison Officer and consumer complaints
brochures.
Endeavour to resolve any concerns raised at the direct service provision level
utilising an interpreter or other culturally appropriate supports when necessary.
Inform complainant of complaint resolution process, utilising an interpreter or other
culturally appropriate supports when necessary, if concerns cannot be resolved at
direct service provision level.
Arrange for a Local Consumer Liaison Officer, other manager or the Consumer
Liaison Officer to contact consumers or carers who wish to pursue a formal
complaint.
2. Local Consumer Liaison Officers (LCLOs) and other line managers
(Note: LCLOs are staff, usually managers, nominated by their Executive Director to
handle complaints at the local level).
(a)
(b)
(c)
(d)
(e)
Ensure consumer complaint pamphlets are displayed and available in a range of
formats to consumers at service outlets.
Ensure that consumers are provided with information about the consumer
complaint process during periodic service plan reviews.
Handle complaints raised by people with disability, their families, carers and/or
advocates if their concerns are not resolved directly with staff who provide the
service (note: line managers should not handle complaints in which they may have
a conflict of interest).
Clarify and investigate complaints and make regular progress reports to the
complainant until the matter is resolved.
Record complaint on the Consumer Complaint Data Form and forward to the
Consumer Liaison Officer (CLO) together with other complaint documentation for
data collection and confidential document storage. (Note: the Data Form is
available at Appendix 1 and on the intranet).
3. Executive Director
(a)
(b)
(c)
(d)
Management or delegation of serious complaints.
Internal review of complaints when requested.
Responsibility for quality, consistency and effectiveness of complaints
management in region or directorate.
Ensure data on all formal complaints is submitted to the Consumer Liaison Officer
for central collation and confidential storage.
Consumer Complaints Management Policy and Procedure December 2011 23

4. Consumer Liaison Officer (CLO)
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
(i)
Manages the Consumer Liaison Service.
Acts as the Commission’s “neutral” arbitrator.
Provides information and advice on internal and external complaints avenues.
Reviews or investigates concerns which were raised by people with disability, their
families, carers and/or advocates, and unsuccessfully resolved at the local level.
Coordinates complaints which are not suitable for handling in a local area or
Directorate.
Provides monthly and annual reports about the number of complaints received,
the nature of the complaint, the area and the outcome to the Director General and
Executive Directors of the area to which the complaints refer.
Ensures the Consumer Liaison Service is effective and efficient by continuous
review and monitoring.
Provides advice and support to people with disability, their families, carers and/or
advocates in relation to complaints.
Provides advice, education on complaints process and handling, and support to
Commission staff, and to disability sector organisations on request.
5. Director General
(a)
(b)
(c)
Provides direction regarding complaints when necessary, including the limitation of
the scope of a complaint (2.3.1.)
May internally review complaints and handle serious complaints.
Signs complaints correspondence where appropriate, as assessed by the CLO.
6. Local Area Coordinators (LACs)
(a)
(b)
(c)
LACs provide the Commission’s consumer complaint pamphlets to new clients
within three months of the commencement of the service.
LAC Area Managers ensure that consumer complaint pamphlets are displayed
and available to consumers at LAC offices.
LAC Regional Managers ensure that articles about consumer complaint processes
are published at least annually in LAC newsletters.
7. Eligibility Determination Coordinator
The Senior Eligibility Coordinator mails the Commission’s consumer complaints
pamphlets with eligibility letters.
Consumer Complaints Management Policy and Procedure December 2011 24

Local Consumer Liaison Officers (LCLOs):
Appendix 6
Consumer Liaison Service - Contact List
• Accommodation Services
Area Position Telephone
Area North Service Support Officer 9376 0422
Area South Service Support Officer 9329 2411
Area East Service Support Officer 6140 9832
• Local Area Coordination
Area Position Telephone
Area North
New North LAC Area Manager 9301 3781
Mobile: 0457 509 582
North West LAC Area Manager 9300 5962
Mobile: 0419 989 711
Central North LAC Area Manager 9440 5424
Mobile: 0419 952 451
Pilbara LAC Area Manager 9143 1750
Mobile: 0429 089 569
North East LAC Area Manager 9309 6739
Mobile: 0409 680 622
Midwest LAC Area Manager 9921 6423
Mobile: 0428 960 582
Goldfields LAC Area Manager 9082 8105
Mobile: 0428 946 107
Kimberley LAC Area Manager 9192 1144
Mobile: 0419 968 249
Kelmscott LAC Area Manager 9396 0601
Mobile: 0417 919 439
Hills LAC Area Manager 6140 9601
Mobile: 0417 966 784
Swan West LAC Area Manager 6466 4410
Mobile: 0419 968 775
Area South
Coastal LAC Area Manager 9446 6785
Mobile: 0418 934 231
South Central LAC Area Manager 9259 2604
Mobile: 0417 918 968
Lower South West LAC Area Manager 9752 4282
Mobile: 0417 181 769
Fremantle LAC Area Manager 9331 4685
Mobile: 0417 942 928
Cockburn Kwinana LAC Area Manager 6399 7001
Mobile: 0419 924 252
Rockingham LAC Area Manager 9557 1001
Mobile: 0434 325 657
Consumer Complaints Management Policy and Procedure December 2011 25

Lower Great
Southern
LAC Area Manager 9845 5708
Mobile: 0429 154 524
Peel LAC Area Manager 9535 1112
Mobile: 0417 987 389
Central East LAC Area Manager 9493 4833
Mobile: 0417 185 766
Wheatbelt LAC Area Manager 9881 4985
Mobile: 0434 604 183
Upper South West LAC Area Manager 9722 3000
Mobile: 0408 919 313
• Statewide Specialist Services
Area Position Telephone
Area North
Joondalup Office Regional Manager Metropolitan Specialist 9301 3789
Joondalup Office
Area South
Myaree Office
Myaree Office
Services
Regional Manager Metropolitan Specialist
Services
Regional Manager Metropolitan Specialist
Services
Regional Manager Metropolitan Specialist
Services
Mobile: 0423 844 118
9301 3808
Mobile: 0403 331 575
9329 2402
Mobile: 0419 963 691
9329 2401
Mobile: 0409 378 909
West Perth Office
Manager Statewide Resource and
Consultancy
9426 9261
• Consumer Liaison Officer (CLO):
Area Position Telephone
Head Office Consumer Liaison Officer 9426 9244
Consumer Complaints Management Policy and Procedure December 2011 26

Appendix 7
Performance standards
These performance standards are designed to ensure that the Commission’s consumer
complaints policy and procedures are implemented effectively, in line with the Australian
Standard Complaint Handling AS ISO 10002-2006. They are:
Performance Standard
1. People with disability, their
families, carers and/or advocates
are informed about the consumer
complaints policy and procedures
and their right to raise any
concern or complaint regarding
the services they receive from the
Commission.
2. People with disability, their
families, carers and/or advocates
are informed about external
avenues of appeal.
3. All staff are informed of and
familiar with the Consumer
Complaints Management Policy
and Procedure.
4. All Local Consumer Liaison
Officers are provided with training
on the Consumer Complaints
Management Policy and
Procedure.
Key Performance
Indicator
• articles published in
disAbility update and
the LAC newsletter, at
least twice a year;
• brochures displayed at
all the Commission’s
offices;
• eligibility determination
coordinator provides all
people assessed
through eligibility
determination with
brochures;
• policy, procedures and
brochures available on
the Commission’s
website.
• as above
• information about the
Health and Disability
Services Complaints
Office included in all
correspondence (refer
to Appendix 3)
• directorates briefing
sessions – one per
year.
• policy, procedures and
brochures available on
the intranet and
internet.
• training provided, as
required.
Target
100%
100%
100%
100%
100%
Responsible
Officer
Consumer
Liaison Officer
Line Managers
Senior Eligibility
Coordinator
Consumer
Liaison Officer
100%
100% Complaint
coordinators
100%
100%
100%
Consumer
Liaison Officer
Consumer
Liaison Officer
Consumer
Liaison Officer
100% Consumer
Liaison Officer
Consumer Complaints Management Policy and Procedure December 2011 27

Performance Standard
Key Performance
Indicator
Target
Responsible
Officer
5. The complaint coordinator
acknowledges receipt of the
complaint within 24 working
hours, and documents contact
with the complainant. The
complaint coordinator also
documents the effort made to
contact the complainant, in the
event that contact could not be
made with the complainant on a
timely basis.
6. All complainants are informed of
the outcome of their complaint
within 10-15 working days, where
possible
7. All complaints are documented
and forwarded to the Consumer
Liaison Officer.
8. The Consumer Liaison Officer
records all complaints in a
confidential database.
9. The Consumer Liaison Officer
files each complaint on a
restricted file.
10. The Consumer Liaison Officer
provides a monthly report to the
Director General and the
Executive Directors.
11. The Consumer Liaison Officer
provides an annual report to the
Director General for inclusion in
the Commission’s Annual Report,
and a copy to all Executive
Directors.
12. Complainant’s satisfaction with
the complaint handling process.
13. The policy and procedures are
reviewed every 2 years.
• all contacts
documented.
• complaint resolved
within timeframe;
• complainants kept
informed through the
resolution process if
timeframe longer.
• all documents
forwarded to the
Consumer Liaison
Officer.
• all complaints recorded
on database.
• complaints filed on
restricted file.
• reports submitted on
time.
• report submitted on
time.
100% Complaint
coordinators
100%
100%
Complaint
coordinators
100% Complaint
coordinators
100% Consumer
Liaison Officer
100% Consumer
Liaison Officer
100% Consumer
Liaison Officer
100% Consumer
Liaison Officer
• satisfaction with
process.
85% Complaint
coordinators
• policy reviewed. 100% Consumer
Liaison Officer
Consumer Complaints Management Policy and Procedure December 2011 28

Appendix 8
Complaints Management Standards
1. The Commission is committed to the following complaint handling standards:
• Complaint Handling Australian Standard AS ISO 10002-2006
• Disability Services Standards, Standard 7: Complaints and Disputes
2. Consumers can expect the following specific standards, based on the Australian
Standard: AS ISO 10002-2006
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
(i)
(j)
(k)
Visibility. Information about how and where to complain is well publicised to
consumers, carers, personnel and other interested parties.
Accessibility. The complaints handling process is easily accessible to all
complainants. This includes readily accessible information about the process,
flexibility in the methods of making complaints and special arrangements and/or
support for complainants with specific needs (including interpreters).
Responsiveness. Receipt of each complaint is acknowledged to the complainant
immediately. Complaints are addressed promptly, complainants are treated
courteously and kept informed of the progress of their complaint through the
complaints handling process.
Objectivity. Each complainant is addressed in an equitable, objective and
unbiased manner through the complaints handling process.
Charges. Access to the complaints handling process is free of charge to the
complainant.
Confidentiality. Personally identifiable information concerning the complainant is
available where needed, but only for the purposes of addressing the complaint
within the Commission and is actively protected from disclosure, unless the
complainant expressly consents to its disclosure.
Investigation of complaints. Every reasonable effort is made to investigate all
the relevant circumstances and information surrounding the complaint.
Consumer-focused approach. The Commission adopts a consumer-focused
approach, is open to feedback including complaints, and shows commitment to
resolving complaints by its actions.
Resolution of complaint. Following an appropriate investigation, the Commission
offers a response, for example, correct the problem and prevent it happening in
the future. The decision or action taken regarding the complaint is communicated
to the complainant as soon as the decision or action is taken.
Accountability. The Commission ensures that accountability for and reporting on
the actions and decisions of the organisation with respect to complaints handling
is clearly established.
Continual improvement. The continual improvement of the complaints handling
process and the quality of services is a permanent objective of the Commission.
Consumer Complaints Management Policy and Procedure December 2011 29

Appendix 9
The Western Australian Carers Charter
(Carers Recognition Act 2004 – Schedule 1)
1. Carers must be treated with respect and dignity.
2. The role of carers must be recognised by including carers in the assessment, planning,
delivery and review of services that impact on them and the role of carers.
3. The views and needs of carers must be taken into account along with the views, needs
and best interests of people receiving care when decisions are made that impact on
carers and the role of carers.
4. Complaints made by carers in relation to services that impact on them and the role of
carers must be given due attention and consideration.
Meaning of “carer”
Extract from Carers Recognition Act 2004
(1) Except as provided in subsection (2), a person is a carer for the purposes of this Act if
he or she is an individual who provides ongoing care or assistance to —
(a) a person with a disability as defined in the Disability Services Act 1993 section 3;
(b) a person who has a chronic illness, including a mental illness as defined in the
Mental Health Act 1996 section 3;
(c) a person who, because of frailty, requires assistance with carrying out everyday
tasks; or
(d) a person of a prescribed class.
(2) However a person is not a carer if he or she —
(a) provides the care or assistance under a contract for services (other than an
agreement entered into under the Disability Services Act 1993 section 25) or a
contract of service; or
(b) provides the care or assistance while doing community work as defined in the
Volunteers (Protection from Liability) Act 2002 section 3(1).
(3) A person is not a carer for the purposes of this Act only because —
(a) the person is a spouse, de facto partner, parent or guardian of the person to
whom the care or assistance is being provided; or
(b) the person provides care to a child under an arrangement with the chief
executive officer of the department principally assisting the Minister
administering the Child Welfare Act 1947 in the administration of that Act.
Consumer Complaints Management Policy and Procedure December 2011 30