Complaints Policy

Purpose

Complaints are unavoidable in all organisations and provide an opportunity to learn, improve and increase services to a higher standard, and it is therefore vital that complaints are viewed positively and are handled constructively.
The purpose of this policy is to provide an effective framework that will ensure complaints
are dealt with consistently, efficiently, and whilst ensuring Spectrum Life meets its regulatory duties under the Health and Social Care Act, through CQC Regulation 16 ‘Receiving and Acting on Complaints’ and abides by national best practice such as the ISCAS Subscribers Code of Practice for Managing Complaints June 2017 and NHS
England Complaints Policy.
To ensure that Spectrum Wellness UK Ltd (t/a Spectrum Life) has a system in place to effectively manage complaints, suggestions, and compliments.
To ensure that Spectrum Wellness UK Ltd (t/a Spectrum Life) complies with any legal requirements, regulations, guidelines, and best practice.
To ensure that all complaints, compliments, and suggestions are dealt with in accordance with legislative, occupational, regulatory requirements in a professional manner and within required timescales.
To have systems in place to continuously monitor and evaluate themes in relation to complaints, compliments, and suggestions to use in the development and improvement of services provided to the general public.
To support Spectrum Wellness UK Ltd (t/a Spectrum Life) in meeting the following Key Lines of Enquiry/Quality Statements

Sub-processors and service providers

We use trusted third-party providers to help us deliver our services. Each is contractually bound to process your data only on our documented instructions, to keep it confidential, to implement appropriate technical and organisational security measures, and not to use your data for their own purposes. Our current sub-processors and key third-party providers are set out in the table below. We maintain this list and will keep it updated.

To meet the legal requirements of the regulated activities that {Spectrum Wellness UK Ltd
(t/a Spectrum Life)} is registered to provide:

• Compensations Act 2006
• Equality Act 2010
• The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
• Human Rights Act 1998
• The Local Authority Social Services and National Health Service Complaints
  (England) Regulations 2009
• Medical Act 1983
• Mental Capacity Act 2005
• Data Protection Act 2018
• UK GDPR

Scope

This policy outlines the different stages of the complaints procedure and includes
arrangements to identify, receive, record, handle and respond to any complaint. This
document also provides guidance on how to process and manage patient concerns,
compliments, and feedback.

It applies equally to all Spectrum Life employees and any workers on our premises,
including clinicians, locum/agency workers, volunteers, and contractors. For ease of
reference, the term “staff” will be used in this document to describe this group of individuals.
The following stakeholders may be affected by this policy:

• Family
• Advocates
• Representatives
• Commissioners
• External health professionals
• Local Authority
• NHS

Reference Materials/Documents

• Author: CQC, (2022), Complain about a service or provider. [Online] Available
  from: https://www.cqc.org.uk/contact-us/how-complain/complain-about-service-orprovider [Accessed: 14/7/2023]
• Author: Independent Sector Complaints Adjudication Service (ISCAS), (2022),
  Complaints process. [Online] Available from:
  https://iscas.cedr.com/patients/complaints- process/ [Accessed: 14/7/2023]
• Author: CQC, (2022), GP mythbuster 35: Fundamental standards of care.
  [Online] Available from: https://www.cqc.org.uk/guidance-providers/gps/gpmythbuster-35- fundamental-standards-care [Accessed: 14/7/2023]
• Author: Parliamentary and Health Service Ombudsman, (2021), What to do
  before you come to us. [Online] Available from:
  https://www.ombudsman.org.uk/making- complaint/before-you-come-to-us
  [Accessed: 14/7/2023]
• Author: NHS England, (2021), NHS England Complaints Policy. [Online]
  Available from: https://www.nhs.uk/using-the-nhs/about-the-nhs/how-to-complainto-the-nhs/ [Accessed: 14/7/2023]
• Author: NHS England, (2022), How to complain to the NHS. [Online] Available
  from: https://www.nhs.uk/using-the-nhs/about-the-nhs/how-to-complain-to-thenhs/ [Accessed: 14/7/2023]
• Author: PARLIAMENTARY AND HEALTH SERVICE OMBUDSMAN (PHSO),
  (2021), How we deal with complaints. [Online] Available from:
  https://www.ombudsman.org.uk/making -complaint/how-we-deal-complaints
  [Accessed: 14/7/2023]

Relevant Legislation

• Compensations Act 2006
• Equality Act 2010
• The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
• Human Rights Act 1998
• The Local Authority Social Services and NHS Complaints (England) Regulations 2009
• Medical Act 1983
• Mental Capacity Act 2005
• Data Protection Act 2018
• UK GDPR

Definitions

A complaint is a communication that requires an investigation and is ‘an expression of
dissatisfaction made to an organisation, either written or spoken, and whether justified or
not, which requires a response. There is no difference between a ‘formal’ complaint and an
‘informal’ complaint. Both are expressions of dissatisfaction – The Client’s Association,
2013. Complaints will be referred to as Escalations.
Founded: When an escalation is deemed “founded,” is defined as a concern or issue
raised was legitimate, valid, and justified. It is understood, there was a genuine problem or
dissatisfaction that needed to be addressed, and the escalation process successfully
identified it, and accepted it as a Complaint.
Unfounded: An escalation is considered “unfounded” when the concern or issue raised is
determined to be unjustified or without merit after investigation. This means that upon
examination, it was found that there was no actual problem, dissatisfaction, or deviation
from requirements or standards.
Salesforce: Internal Software for the documentation and reporting of escalations.
Client: A person who is using the service on behalf of a contract/account.
Customer: The company who is commissioning spectrum life to deliver services.

Responsibilities

Spectrum Life’s organisational procedures are vital for effective management and to minimise any potential risks. It is therefore essential that responsibility for policies is located at the highest level.
The Board
The Board has ultimate responsibility for the safety and quality of client care and for managing the organisation’s risks. The Board will be informed and assured of the effectiveness of the complaint’s policy and Escalation standard operating procedures.
Chief Executive Officer
Overall accountability for ensuring compliance with the Managing Complaints Policy.
The Executive Team
The Executive Team will ensure that appropriate resources are identified, where this is thought advisable for the escalation, and review the on-going appropriateness of any individual assigned to oversee any investigations that may be required.
Compliance Department / Registered Manager (where the service is CQC registered)

• The Compliance Department has overall accountability for Spectrum Life’s escalations arrangements.
• Ensuring that there is a coordinated, effective system for acknowledging, reporting, investigating, and monitoring of escalations.
• To provide guidance to staff on the local handling of escalations.
• To provide support to colleagues on the process for managing concerns and escalations The Clinical Governance and Compliance Team maintains overall responsibility and oversight for the process including the maintenance of the logs.

Escalation Owner
Is responsible for overseeing the escalation process and facilitating A timely resolution. In most cases the escalation owner will be an account manager unless otherwise specified.
Escalation Team
An escalation team will be identified where any concerns have been escalated around an increase or unexpected volume of escalations raised.
Investigation Lead
A Service lead will be assigned as an investigation lead as appropriate and is responsible for:

• Ensuring independence and objectivity of the investigation.
• Completing the investigation of a specific escalation in line with the processes laid out within this policy.
• Making sure they include all relevant parties.
• Feeding back to the account manager to update on progress and outcome of the investigation.
• Ensuring that the escalations log is kept up to date.
• The Investigation Lead will acknowledge all escalations, request escalations investigations, and advise colleagues, in the resolution of escalations.

Clinical Governance and Compliance Committee
All escalations will be reviewed by the Clinical Governance and Compliance Committee to:

• audit compliance with the escalation’s procedures.
• review and share themes and trends.
• review and share lessons learned.

All Staff
It is expected that front line staff will have responsibility for dealing with any escalations made to them in the first place, as most issues can be resolved at a local level. All concerns should be dealt with as quickly as possible, and the Registered Manager should be notified to enable lessons learned.
Any concerns that cannot be dealt with at this stage must be:

• Escalated to the service Lead for investigation
• Inputted into Salesforce
• In addition, staff are responsible for:
• Being open and cooperative with any investigation process. Clinical staff are reminded that professional regulators (e.g., HCPC & GMC) require regulated healthcare professionals to assist with reviews and investigations when requested.
• Ensuring that all clients making complaints are not treated adversely because of making a complaint.

Openness transparency and candour

Following the Francis Report (2013), it is a CQC requirement for Clinicians and Service Provider Organisations to be candid with clients about avoidable harm and for safety concerns to be reported openly and truthfully.

Definitions of openness, transparency and candour are described in the Francis Report 2013 as:

Openness: enabling concerns and complaints to be raised freely without fear and questions asked to be answered. “Being open simply means apologising and explaining what happened to clients and/or their carers who have been involved in a client safety incident”.

Transparency: allowing information about the truth about performance and outcomes to be shared with staff, clients, the public and regulators.

Candour: any client harmed by the provision of a healthcare service is informed of the fact and an appropriate remedy offered, regardless of whether a complaint has been made or a question asked about it.

Who can Complain

A complaint may be made by the person who is affected by the action, or it may be made by a person acting on behalf of a client in any case where that person: 

• is a child; (an individual who has not attained the age of 18) In the case of a child, we must be satisfied that there are reasonable grounds for the complaint being made by a representative of the child, and furthermore that the representative is making the complaint in the best interests of the child.
• has died; In the case of a person who has died, the complainant must be the personal representative of the deceased. Spectrum Life needs to be satisfied that the complainant is the personal representative. Where appropriate we may request evidence to substantiate the complainant’s claim to have a right to the information.
• has physical or mental incapacity; In the case of a person who is unable by reason of physical capacity or lacks capacity within the meaning of the Mental Capacity Act 2005, to make the complaint themselves, Spectrum Life needs to be satisfied that the complaint is being made in the best interests of the person on whose behalf the complaint is made.
• has given consent to a third party acting on their behalf; In the case of a third party pursuing a complaint on behalf of the person affected we will request the following information: 1.Name and address of the person making the complaint; 2. Name and either date of birth or address of the affected person; 3. Contact details of the affected person so that we can contact them for confirmation that they consent to the third party acting on their behalf.
• This will be documented in the Salesforce escalation file and confirmation will be issued to both the person making the complaint and the person affected.
• Has delegated authority to act on their behalf, for example in the form of a registered Power of Attorney which must cover health affairs.
• Is an MP, acting on behalf of and by instruction from a constituent.

Consent

Any person (family member or client representative) wishing to make a complaint on behalf of someone else must have written consent to do so from the client.

If the client has died, then the Compliance Department/ Registered Manager must determine whether the complainant had sufficient interest in the person’s welfare or is suitable to act as a representative. If he/she does not consider this to be the case, then they will notify that person in writing stating the reasons behind their decision. Children may have someone make a complaint on their behalf if they are under the age of 16. This person should normally be a parent, guardian or other adult person who has responsibility for the care of the child. If the child is in the care of the Local Authority or a voluntary organisation, the representative must be a person authorised by the Local Authority or the voluntary organisation.

It is important to note through the escalation process that if the escalation is for Clinical or Mental Health Services, we are bound by confidentiality to the client and therefore will require formal consent from whom the escalation has originated. Therefore, we are unable to discuss anything with any person who is not the client. We are unable to confirm or deny an individual’s participation in any clinical services without their explicit written consent authorising the discussion of their personal matters with individuals other than themselves. Spectrum Life will not share direct communication with the client unless there is explicit consent from the client to do so. This is to ensure spectrum life remains compliant with GDPR regulations.

Timescales for making a complaint

Complaints must be made not later than:

• 6 months after the date on which the matter which is the subject of the complaint occurred; or
• 6 months after the date on which the matter which is the subject of the complaint came to the notice of the complainant.
• There is discretion to extend the time limit where it would be unreasonable, in the circumstances of a particular case, for the complaint to have been made earlier and/or where it is still possible to investigate the facts of the case.

Matters excluded from this policy

Spectrum Life will not be required to deal with the following complaints under this policy: –

• Any complaint made by an employee of Spectrum Life about any matter relating to their contract employment.
• Any complaint, the subject matter of which is the same as that of a complaint that has previously been made and resolved in accordance with this policy.
• Made by another organisation which relates to the exercise of the company’s functions.
• Made by an independent contractor which relates either to the exercise of its functions by the company or to the contract or arrangements under which it provides services.
• Which is being, or has been, investigated by the Health Service Ombudsman
• Arising out of the company’s alleged failure to comply with a data subject request made under the Data Protection Act 2018 or a request for information under the Freedom of Information Act 2000
• Where the company is taking, or is proposing to take, disciplinary proceedings in relation to the substance of the complaint against a person who is the subject of the complaint.

Making a Complaint

Verbal Complaints and Concerns
Staff will often receive informal comments and suggestions, and these may include expressions of dissatisfaction. If staff receive verbal comments from clients, the person receiving the comment should establish the facts and clarify whether a complaint is being made. Staff are encouraged, in conjunction with their lead to deal with verbal complaints to which they can provide an immediate response. The aim is to resolve the matter causing concern, to reassure the complainant, to learn from the complainant’s experience and to eliminate the potential for similar problems. Details of the complaint, and action taken in response, should be completed on Salesforce. It is important to keep a written record of any verbal complaint in case the complainant takes further action later. Where the complainant indicates that they are not satisfied with the verbal response, or where the person dealing with the complaint considers that the complainant may wish to take the matter further, it is recommended that the complainant is informed of their right to bring the matter to the attention of the service lead.

Written Complaints
All written complaints must be acknowledged within 1 working day of receipt and logged on salesforce.
Acknowledgement and record of the complaint

The Account Manager, or the service lead managing the client escalation, will endeavour to respond the same day and will offer a call and send a written acknowledgement within 1 working day of the date on which the escalation was received.

Where the complaint is made verbally, the acknowledgement must be accompanied with a written record of the complaint. A copy of the complaint and the acknowledgement letter, as well as a copy of the Service Leads full response, must be sent to any person identified as the subject of the complaint.

Handling Complaints/Escalations:

Expectations

All Escalations should be acknowledged within 1 working day of receipt, this should include an offering to call the complainant to discuss their concerns.

An update on the progression of the investigation should be provided within a further two days. In the update the complainant should be notified if there are any reasons why the escalation would not have an outcome within 10 working days.

The final outcome of the complaint should be provided within 10 working days of the complaint. Where the complaint has been initiated form a contract/account and we require consent from the client the 10 days will start form the day we get consent.

• An explanation of how the complaint has been considered.
• An apology if appropriate
• An explanation based on facts.
• Whether the complaint, in full or in part is upheld.
• The conclusions reached in relation to the complaint including any remedial action that the Spectrum Life considers to be appropriate.
• Confirmation that Spectrum Life is satisfied any action has been or will be actioned.
• Where possible, we will respond to people about any lessons learnt.
• Information and contact details on what to do if the complainant is not happy with the way the complaint has been managed.
• Our response to a complainant will be wherever possible by their preferred method of communication (email correspondence will only be responded to by email when the complainant has expressly requested this as their method of communication and security measures will be implemented in line with Spectrum Life policy to protect personal information sent via email).
• The response will include:

All Escalations will be categorised within 4 Tiers:

Tier 1: Initial point of contact for escalations, typically Account Managers. Responsible for triaging escalations and resolving issues within their authority and knowledge.

Tier 2: Escalations requiring further investigation or expertise beyond Tier 1. Escalated to designated Investigation leads or specialists for resolution.

Tier 3: Highest escalation level involving senior management or executive leadership. Reserved for critical issues or unresolved escalations requiring top-level intervention.

Tier 4: External complaint investigation

Complaints Which Could Potentially Lead to Disciplinary Action

A complaint can be investigated at the same time as disciplinary proceedings. However, Spectrum Life must keep its complaints procedure separate from its disciplinary procedure.

The purpose of the complaint’s procedure is not to apportion blame amongst staff but to investigate complaints to the satisfaction of the complainant whilst being scrupulously fair to staff and to learn any lessons for improvement in service delivery.

However, some complaints will identify information about serious matters which indicates a need for disciplinary investigation. Consideration as to whether disciplinary action is warranted must be subject to a separate process of investigation.

Information gathered during the complaints process can be made available to the appropriate person who will be considering the need for disciplinary or any other form of investigation.

Possible Claims for Negligence

Where a complaint has been made and legal action is being pursued at the same time, or where police or counter-fraud investigators are involved, the Chief Clinical Officer must be informed. It should not necessarily be inferred that a complaint made via a solicitor means that the complainant has decided to take legal action. If proper consent has been received, a response should be made in the normal manner. An apology is not necessarily an admission of liability.

Discussion should then take place with the relevant authority (legal advisors, Police or Crown Prosecution Service) to determine whether progressing the complaint might prejudice subsequent judicial action. If this is the case, the complaint will be put on hold and the complainant advised of this.

If this is not the case the investigation into the complaint will take place. If a complaint reveals a prima facie case of negligence, or if it is thought that there is a likelihood of legal action being taken, the person in receipt of the complaint should inform the Chief Clinical Officer and the Compliance Department. It may be necessary for the Chief Clinical Officer or a member of the Executive Team to discuss the issues and options available to the complainant to prevent litigation. Legal advice may be sought at this time. Copies of all correspondence should be passed to any staff member concerned and they should be informed that legal advice is being taken.

The complaints procedure should cease if the complainant explicitly indicates an intention to take legal action in respect of the complaint. All parties concerned should be advised in writing that the complaints procedure will be ended.

Financial Compensation and EX-Gratia Payments

The Executive Team and the Compliance Department should be immediately notified if any client writes to the Spectrum Life indicating that they want financial compensation to resolve their complaint or concerns.

Serious Untoward Incidents

The procedure for the investigation of Serious Incidents is separate from the complaint’s procedure. If a complaint has been received by Spectrum Life during an investigation under the Serious Incident procedure the latter procedure will take precedent.

The complaint should be acknowledged, and the complainant kept informed throughout the process with a final response explaining the outcome of the investigation when completed.

When a complaint alleges serious misconduct or a criminal offence including:

• Physical abuse
• Sexual abuse
• Financial misconduct

Where a complaint, or investigation into a complaint, suggests that a criminal offence may have taken place, The Executive Team and the Compliance Department should be notified immediately so that he can decide whether the police should be informed.

Reporting of Escalations

Clients: All Clients who have raised an escalation will get a report detailing the investigation and the outcome of their complaint.
Customers: All Customers that have raised a complaint will get a report detailing the investigations and outcome of the complaint. The customer will not be provided and Client sensitive information. Customers will receive monthly or quarterly (as agreed in the contract) reports from Spectrum life providing data on complaints.

Support for Complainants

It is important that all clients and carers or relatives are aware of their right to complain and have equal access to the complaint’s procedure.

As part of an investigation into a complaint, Spectrum Life should make telephone contact with the complainant/s as they have a right to make their views known and raise questions regarding the care and service provided to themselves or a significant other and reassurance that actions will be taken to prevent recurrence.

The basic principles underlying this communication are:

• Principle of acknowledgement.
• Principle of truthfulness, timeliness, and clarity of communication.
• Principle of apology and regret.

Any contact should be undertaken in an open, respectful, dignified, and compassionate manner. Spectrum Life (under the auspices of being open and the Duty of Candour) should offer the complainant a meeting at a convenient time via a videoconference. It should be made explicit who will be meeting them, the purpose of the meeting and the purpose of the investigation process.

To enable the complainant/s to fully participate in the investigation process, Spectrum Life should consider their potential needs:

• Independent advocacy.
• Cultural complexities.
• Support and assistance for participating in the investigation process.
• Ongoing support e.g., counselling.
• Signposting to other organisations who may be able to provide support and information.
• Support in liaison with other external agencies

Support for Staff

An effective complaints procedure needs the confidence of staff employed by Spectrum Life. It is important that staff experience the investigation of complaints as being fair and objective. This includes provision for protecting staff from complainants who abuse or harass staff.

Staff can also access advice about the complaint’s procedure from the Compliance Department. The outcomes and any recommendations relating to a particular complaint should be fed back to all staff concerned via the Investigation Lead and clinical governance structures.

Managing habitual or vexatious complaints

Most complainants behave entirely reasonably but, on rare occasions, their behaviour can cause concern. They may, for example, abuse or threaten members of staff, or continue to raise new questions when their original concerns appear to have been fully addressed. It is recognised that a point can come, even with a complaint put in a courteous and reasonable manner, at which it must be accepted that no purpose will be served by further communication.

The following form of words – or a very close approximation – should be used by any member of Spectrum Life staff who intends to withdraw from a telephone conversation with a complainant. Grounds for doing so could be that the complainant has become unreasonable, aggressive, abusive, insulting, or threatening to the individual dealing with the call or in respect of other Spectrum Life personnel.

It should not be used to avoid dealing with a complainant’s legitimate questions or concerns which can sometimes be expressed extremely strongly. Careful judgement and discretion must be used in determining whether a complainant’s approach has become unreasonable.

FORM OF WORDS “I am afraid that we have reached the point where your approach has become unreasonable, and I have no alternative but to discontinue this conversation. Your complaint(s) will still be dealt with by Spectrum Life in accordance with the Spectrum Life complaints procedure. I am now going to put the telephone down but wish to assure you that the situation will shortly be confirmed in writing to you.”

FOLLOW-UP ACTION The incident should immediately be reported to the Registered Manager and Compliance Department, and agreement reached on the future means of communication with the complainant together with any further action deemed necessary.

Confidentiality

The clients express consent is not required to use information pertaining to the client to investigate a complaint. Care must be always taken throughout the complaints procedure to ensure that any information disclosed about the client is confined to that which is relevant to the investigation of the complaint and only disclosed to those people who have a demonstrable need to know it for the purpose of investigating the complaint.

It is good practice to explain to the client that information from their health records may need to be disclosed to the relevant nominated Investigation Lead to thoroughly investigate issues raised. Where a complaint is made on behalf of a client who has not authorised someone to act for them, care must be taken not to disclose personal health information to the complainant, unless the client has expressly consented to its disclosure.

The duty of confidentiality applies equally to third parties who have given information or who are referred to in the clients records. Care must be taken where the clients records contain information provided in confidence, by or about, a third party who is not a health professional. It must not be disclosed to the client unless the person who provided the information has expressly consented to the disclosure. Disclosure of information provided by a third party outside Spectrum Life also requires the express consent of the third party. If the third-party objects, then it can only be disclosed when there is an overriding public interest in doing so.

As a balance to complaints, it is important that we also record the things that go well. Positive comments and letters of praise should always be fed back to the staff concerned. When compliments are received, a copy will be forwarded to the Registered Manager so that the comments can be passed to the staff member/s being praised. The Compliance Department would like to receive copies of any letters of praise or written positive comments so that they can be recorded and included in monthly/quarterly reports.

Complaining on behalf of someone else

Please note due to strict medical confidentiality rules, if a patient is complaining on behalf of someone else, we need to know that they have the clients’ permission to do so. A note signed by the person concerned will be required, unless they are incapable of providing this due to illness or disability. Once a request for patient consent has been sent, a ‘stop the clock’ will be placed on the response timeframe, until the consent is received. Should the patient refuse to provide consent or the consent to disclose information not be received within 20 working days of the request, we will close this matter.

The timeframe for response to the complaint will restart from the first working day on which the consent is received.

Compliments

Compliments are considered as important as complaints and should be seen as a means of learning how things have gone well. Compliments should always be shared with the team member who provided the care, and positive feedback is appreciated and valued by Spectrum Life.

Resolution of Concerns

We encourage all patients if they are able too, to raise their issue at the time, as we would like to address any problems as quickly and informally as possible. Concerns are a form of feedback on our services from patients and the public, and all staff have a responsibility to act upon them. Concerns should, if possible, be resolved locally and immediately or within a short timescale agreed with the individual.

If patients are not happy or able to do this, they should contact our Administration Team by telephone and ask to speak to a Team Lead who will try to resolve the issue and offer them further advice on the complaint’s procedure.

Where possible, these concerns and their resolutions/outcomes should be shared with the Governance Team. Where appropriate, copies of any related information correspondence should be shared and entered in Sales Force. Any lessons to be learnt from these enquiries should be disseminated to staff within the relevant departments.

If a patient’s problem cannot be resolved at this stage and they wish to make a formal complaint, we ask that patients let us know as soon as possible, ideally within a matter of days, so that we can get a clear picture of the circumstances surrounding the complaint. The details should be taken and forwarded to the Governance Team to enable management of the issue through Sales Force.

Concerns raised through third parties will be acted on directly with the patient. Feedback to the third-party that raised the concern on behalf of the patient is subject to consent being received from the patient.

Complaints Resolution Meetings

Complaint meetings can be effective to diffuse a potential complaint, resolving an ongoing complaint, or clearing up outstanding issues following a written complaint response. Meetings should be seen as a tool to assist resolution of the matter and lessen the likelihood of an escalation of the complaint.

Independent External Appeal

Spectrum Life is a member of the Independent Sector Complaints Adjudication Service (ISCAS). If a patient remains dissatisfied with the internal appeal process, he/she may exercise a right of Appeal to ISCAS. This should be done directly to ISCAS (Stage 3).

ISCAS adjudication is only designed to be used once Stages 1 and 2 of the complaints process have been exhausted.

Address: Independent Sector Complaints Adjudication Service, 70 Fleet Street, London EC4Y 1EU

Telephone: 020 7536 6091

Email: info@iscas.org.uk

Web: www.iscas.org.uk

Complaints regarding data protection act and freedom of information

• All complaints relating for a breach in data protection will be passed to the Spectrum Life Data Protection Officer and their team for investigation.
• Should the outcome of the investigation not be satisfactory, the complainant is encouraged to contact the Information Commissioners Office (ICO).
• The ICO will contact the Trust regarding a complaint arising out of an alleged failure to comply with a data subject request under the DPA 2018 and GDPR (General Data Protection Regulation).
• The ICO will contact the Freedom of Information Officer regarding complaints arising out of an alleged failure to comply with a data subject request under the Freedom of Information 2000.
• Spectrum Life may consult with the ICO during the investigation about complaints arising out of an alleged failure to comply with a data subject request under the DPA 2018 and GDPR and the Freedom of Information 2000.
• Further information is available at http://www.informationcommissioner.gov.uk/

Client Feedback

All feedback is welcomed. Within the clinical services Net promoter scores (NPS) are requested to be completed following interactions with clinicians. This feedback is reviewed during the clinical governance meetings and individually with staff who the feedback was regarding.

Training requirements

This policy is to be disseminated to all members of staff. A copy of this policy will be available for all staff on SharePoint. All staff must familiarise themselves with the requirements of this policy and should receive guidance from the Compliance Department, as required.

Audit, Monitoring & Compliance

Organisational Learning:
The Service Leads and Compliance Department will review all complaints and ensure compliance with the policy. The Compliance Department will report into Executive Team as part of the wider Compliance Department reporting.

Complaints are reviewed as part of the annual audit cycle; outcomes will be reported to the Compliance Committee. All Staff members will be required to sign to say they have read and understand the Managing Concerns, Complaints and Feedback Policy.

Individual Learning and Service Improvements:

When lessons learnt have been identified because of a complaint, the complainant will be informed and advised of any changes that have been made to prevent the problem recurring. This will occur at the time when a copy of the final investigation is shared with the complainant. In addition, Spectrum Life is committed to improving the client experience and as such lessons learnt from complaints will be shared with the wider organisation via the Compliance Department.

Outcomes Reporting:

Complaints are reported monthly by the Compliance Department. These reports will contain qualitative and quantitative information on both concerns and complaints raised and learning from concerns and formal complaints. Recommendations arising from a complaint’s investigation are reviewed and monitored by the Compliance Department until the risk reduction measure is implemented.