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PROCEDURAL GUIDANCE ON COMPLAINTS AND COMMENTS
SERVICE USER TO SERVICE USER
• If a service user wishes to make a complaint about the actions of another service user, then they may do
so to their key worker, if they do not feel comfortable about this then they may approach any manager
from the Senior Leadership Team. Contact details can be acquired from any key worker within the
organisation.
These are:
➢ Volunteer and Training Manager:
➢ Refuge Manager:
➢ Finance Manager:
➢ Chief Operations Officer:
➢ Please also see Organisational chart at appendix A:
• If the member of staff who has received the complaint or comment can resolve the issue within the
designated boundaries of their delegated authority, they should attempt to do so. However, if theLL 2024 Version 3 3complaint or comment cannot be resolved like this, or the complaint or comment is about staff at project
level, a manager must lead on resolving the complaint or comment.
• A complaint may be sent to the Chief Executive Officer (CEO), but to retain a clear route of escalation
this will be passed to the Senior Leadership Team for full investigation. The CEO will acknowledge the
complaint, explain what will be happening and will then recuse herself from the investigation in order to
remain objective and allow for the escalation of the appeals process, if necessary. The CEO may send
out additional papers to the Senior Leadership Team and the complainant, if required.
• In order to ensure the safety of all service users, if the complaint falls under the definition of the
protection of vulnerable adults, as per the Vulnerable Adults Policy, the service user who has had the
complaint made against them will be moved from that service. For outreach support that may mean
moving to another key worker, or service and for refuge that may mean a planned move internally, or
externally. If a service user (refuge) is on her final warning Pathway Project may have no option but to
do a planned external move. If a service user refuses to engage with a planned service move, it may
mean there are no further options than an end to service.
• If the alleged individual wishes to offer a counter complaint, they will still be required to comply with the
above and in line with the Vulnerable Adults Policy. This will not affect the investigation into the totality
of their complaint, and this will still be followed through to conclusion. This complaint will be dealt with in
the processes detailed below.
SERVICE USERS
• If a service user wishes to complain or make a comment about the services they are receiving, or any
other aspect of their experience whilst being supported by Pathway Project, they can do this by speaking
with a refuge/outreach worker.
• Pathway Project have a zero tolerance to the any form of abuse or bullying towards another. In line with
the Equality Act 2010, any issues raised will be investigated speedily, and with full transparency,
including the following areas:
• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race
• Religion or belief
• Sex
• Sexual orientation
• Should the service user not feel comfortable in discussing their complaint or comment with a
refuge/outreach worker for any reason, they can talk to any manager within the organisation, as listed
above.
• A complaint may be sent to the CEO, but to retain a clear route of escalation this will be passed to the
Senior Leadership Team for full investigation. The CEO will acknowledge the complaint, explain what
will be happening and will then recuse herself from the investigation to remain objective and allow for the
escalation of the appeals process if necessary. The CEO may send out additional papers to the Senior
Leadership Team and the complainant, if required.
• Once a service user has approached a member of staff to make a complaint, that staff member must
first establish whether the complaint or comment is a minor matter, which can be rectified simply and
without conflict. In these cases, it may be unnecessary to seek a written version of the complaint or
comment. This should be discussed with the service user and only done with their agreement.
• If the member of staff can resolve the complaint or comment within the designated boundaries of their
delegated authority, they should attempt to do so. However, if the complaint or comment cannot be
LL 2024 Version 3 4resolved like this, or the complaint or comment is about staff at project level, the line manager must lead
on resolving the complaint or comment.
• Where staff members have been approached about a more serious complaint or comment this must be
put in writing. Staff must establish whether the service user needs assistance in putting their complaint
into writing. No pressure will be exerted on the service user to do this on their own, but they can be
offered the opportunity to sit down with a member of staff and record the complaint or comment or be
signposted to another agency that will support them to do this. In cases where a member of staff is
recording details of a complaint or comment for a service user, they will be given the document back for
proof reading before being required to sign the document to confirm it is an accurate record.
• A serious complaint or comment must follow a clear path of investigation, and this must be conducted
face to face to clearly establish the issues and allow for clarification and evidence to be presented. No
serious complaint or comment can be dealt with over email or by letter only, and complaints and
comments will not be responded to in the complaint acknowledgement email.
• To ensure a complaint is dealt with effectively both the service user and the Senior Leadership Team
will need to make themselves available for a minimum of one, and up to four, face-to -face meetings.
The number of meetings will depend on the level of content in the complaint and how much is reviewed
per meeting. The service user has the right to bring another individual with them to the meetings to help
support them.
• The service user will receive contact from a manager informing them of the process and times and dates
they will be available to meet. This may happen through phone calls, emails or letters. The service user
will have the option to provide additional dates.
• If a service user refuses to attend investigation meetings, then Pathway Project will be unable to
continue with the complaint as we will have no way of verifying and clarifying issues or presenting and
viewing evidence. The service user will be notified of the reason why this decision must be made,
including the options given to them, by letter or email. The reasons for not carrying the complaint
forward may also be given to any external agencies the service user has involved.
• In the meeting the individual who is leading on resolving the complaint or comment should ensure that
they get clear information from the service user making the complaint or comment about what they found
unsatisfactory, and if they have any view on what could be done to resolve their complaint or comment.
Each area of the complaint will be gone through point by point, allowing for questions, discussion and
evidence to be presented.
• Pathway Project will begin investigating the complaint as soon as it is received and may bring evidence
to present at the meetings to ensure that the process is as timely as possible. If during the course of the
investigation into the complaint or comment it is found that Pathway Project have provided a poor
service, this should be rectified immediately and resolved satisfactorily with the service user and with
Pathway Project.
• During the meeting minutes will be taken, the service user can have the option to read them on the day
and sign to say that they are accurate or take them away to read and come back to us with any queries.
It is preferential for them to be read and signed on the day, and copies distributed where required and
appropriate.
• The lead for the investigation will aim to have resolved the complaint to everyone’s satisfaction by the
end of the last meeting, and the actions taken will be confirmed both in this meeting and in writing.
• If a complaint or comment is considered to be unjustified by Pathway Project, the reason for this will be
explained to the service user, both in this meeting and in writing.
• It may be that an investigation finds that there are elements of the complaint which are considered to be
unjustified and elements that require actions; this will be explained to the service user both in this
meeting and in writing.
• If Pathway Project considers some areas of the complaint to be justified, they may need to take discuss
the complaint and the issues discovered with external agencies, e.g. around building maintenance or
security, to be ensure they are complaint. This will be done in line with General Data Protection
Regulations (GDPR).
STAKEHOLDERS
• If a stakeholder wishes to complain or make a comment about the Pathway Project, they should do so in
writing to the Senior Leadership Team at Hope Centre, 3 Quonians Lane, Lichfield, WS13 7LB who will
lead on resolving the issue.
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• Should the stakeholder not feel comfortable in discussing their complaint or comment with the Senior
Leadership Team for any reason, they can write to the CEO at the same address, however, this will not
fast track the complaint and if there is no clear reason why it should not be investigated by the Senior
Leadership Team, the CEO will refer back to them and recuse themselves from the process in order to
allow for escalation of the appeals process, if necessary. The CEO may send out additional papers to
the Senior Leadership Team and the complainant, if required.
• If a stakeholder feels that they need to access assistance in putting their complaint or comment into
writing, Pathway Project will be able to signpost them to other agencies who will be able to offer
appropriate support, at their request. All written complaints or comments from a third party on behalf of
the stakeholder must detail that they have gained approval of the complaint or comment and have
agreed for it to be sent off.
• All written complaints or comments from stakeholders must clearly document what it is they have found
to be unsatisfactory about the work of Pathway Project and what they feel could be done to resolve their
complaint or comment.
• A complaint or comment that does not reach a serious threshold, e.g. grammatical errors in a letter sent
out or a staff member being five minutes late to a meeting can be dealt with through email, letter or
phone calls, if this is preferable to the stakeholder.
• A serious complaint or comment must follow a clear path of investigation, and this must be conducted
face to face to clearly establish the issues and allow for clarification and evidence to be presented. No
serious complaint or comment can be dealt with over email or by letter only, and complaints and
comments will not be responded to in the complaint acknowledgement email.
• To ensure a complaint is dealt with effectively both the stakeholder and the Senior Leadership Team will
need to make themselves available for a minimum of one, and up to four face to face meetings. The
number of meetings will depend on the level of content in the complaint and how much is reviewed per
meeting. The stakeholder has the right to bring another individual with them to the meeting.
• Stakeholders will receive contact from a manager informing them of the process and times and dates
they will be available to meet. This may happen through phone calls, emails or letters. Stakeholders will
have the option to provide additional dates.
• If a stakeholder refuses to attend investigation meetings, then Pathway Project will be unable to continue
with the complaint as we will have no way of verifying and clarifying issues or presenting and viewing
evidence. The stakeholder will be notified of the reason why this decision must be made, including the
options given to them, by letter or email. The reasons for not carrying the complaint forward may also
be given to any external agencies the stakeholder has involved.
• In the meeting the individual who is leading on resolving the complaint or comment should ensure that
they get clear information from the stakeholder making the complaint or comment about what they found
unsatisfactory and if they have any view on what could be done to resolve their complaint or comment.
Each area of the complaint will be gone through point by point, allowing for questions, discussion and
evidence to be presented.
• Pathway Project will begin investigating the complaint as soon as it is received and may bring evidence
to present at the meetings in order to ensure that the process is as timely as possible. If during the
investigation into the complaint or comment it is found that Pathway Project have provided a poor
service, this should be rectified immediately and resolved satisfactorily with the stakeholder and with
Pathway Project.
• During the meeting, minutes will be taken, stakeholders can have the option to read them on the day
and sign to say that they are accurate or take them away to read and come back to us with any queries
within an agreed timeframe. It is preferential for them to be read and signed on the day, and copies
distributed where required and appropriate.
• The lead for the investigation will aim to have resolved the complaint to everyone’s satisfaction by the
end of the last meeting, and the actions taken will be confirmed both in this meeting and in writing.
• If a complaint or comment is considered to be unjustified by Pathway Project, the reason for this
decision will be explained to the stakeholder, both in this meeting and in writing.
• It may be that an investigation finds that there are elements of the complaint which are considered to be
unjustified and elements that require actions; this will be explained to the stakeholder both in this
meeting and in writing.
• If Pathway Project considers some areas of the complaint to be justified, they may need to take discuss
the complaint and the issues discovered with external agencies, e.g. around building maintenance or
security, in order to be ensure they are compliant. This will be done in line with GDPR.
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PERPETRATOR COMPLAINTS
• Due to the nature of the work that Pathway Project does there may be times when a stakeholder
complaint is bought by a perpetrator, whose partner or family is accessing the service.
• While the complaint will still be investigated, Pathway Project reserve the right to only deal with the
complaint in writing, so as not to put the staff or service users in danger by having a face-to-face
engagement.
• If Pathway Project feels that the complaint is threatening or dangerous, we reserve the right to report this
to other agencies, or the Police.
• Pathway Project will confirm the outcome of the investigation in writing.
COMPLAINT LEVELS
• If the complaint is about a staff member, then the Senior Leadership Team will lead on resolving the
complaint.
• If the complaint is about an individual manager, then the remaining Senior Leadership Team will lead on
resolving the complaint or comment.
• If the complaint is about the entirety of the Senior Leadership Team, then the CEO will lead on resolving
the complaint or comment.
• If the complaint is about the CEO, then the Chair of the Board of Trustees will lead on resolving the
complaint or comment.
APPEALS PROCESS
If it has not been possible to achieve a resolution to a service user or stakeholder’s complaint or comment
that is both satisfactory to them and to Pathway Project, the service user or stakeholder can proceed to the
next stage of the process if they wish to pursue the matter.
• If a complaint or comment has been made to a refuge/outreach worker but remains unresolved, the
Senior Leadership Team must review the complaint or comment and action taken.
• If a complaint or comment has been reviewed by the Senior Leadership Team but remains unresolved,
the CEO must review the complaint or comment and the action taken. The escalation must be in writing
and cannot be a simply the same complaint but must cover why the complainant is unhappy with the
outcome and what they feel should have been considered and may have led to a different outcome. The
CEO may ask for a face- to- face meeting to clarify the issues around why the complainant is
unsatisfied.
• If a complaint or comment has been reviewed by the CEO but remains unresolved, the Board of
Trustees must review the complaint or comment and the action taken. The information that the Board of
Trustees will need to consider the complaint or comment will be:
- What has been found to be unsatisfactory by the service user or stakeholder?
- What action has been taken to rectify this?
- Why the service user or stakeholder remains dissatisfied
- What the service user or stakeholder would consider to be a satisfactory resolution to their complaint and if this is reasonable in relation to the complaint or comment.
• Once the Board of Trustees have considered the service user or stakeholders complaint, the Chair of
the Trustees may ask for a face-to- face meeting to further clarify the issues around why they are
LL 2024 Version 3 7unsatisfied
During this meeting the Chair of the Trustees will aim for final clarification around the
resolving of the complaint, this may also be followed up in writing.
MONITORING COMPLAINTS AND COMMENTS
Pathway Project has internal processes in place for monitoring complaints or comments made by service
users or stakeholders. This information is then used to develop services through:
• Business planning
• Identifying and prioritising changes and improvements of existing services.
• Identifying gaps in service provision.
• Service reviews
• Reviews of policies and procedures
The results of complaints or comments will also be presented to the Board of Trustees at least annually.