9
Resolved
That Cabinet:
i) agrees the proposed changes to the corporate complaints policy including
- the proposal to change the corporate complaints process from a three-stage process to a two-stage process.
- agree proposal to increase of the time allowed for stage 1 responses from 10 days to 20 days.
- revised definition of a complaint
ii) notes the proposed go live of the customer digital complaints solution (customer portal) Dec 2021.
iii) notes that members will be engaged and consulted with regarding the implementation of the new digital members portal.
iv) notes the complaints and Ombudsman performance as outlined (Appendix 2 of the report)
v) notes the council’s self-assessment against Compliance with the Complaint Handling Code as required by the Housing Ombudsman (Appendix 4 of the report)
Reason for Decision and Options Considered
Corporate complaints were dealt with in different ways across the organisation depending on the volumes and complexity. Adults and Children’s and Housing Landlord services also have their own separate complaints policies or procedures with these areas having dedicated officers dealing with the inputting, administration, preparing draft replies and chasing of responses.
Until Jan 21 most complaints were logged through iCasework, a system which was now switched off as unsupported and would have required investment to improve the functionality. Some services were also using their own individual systems to manage complaints. This made accurate reporting and monitoring at a corporate level difficult which in turn limits the opportunity to identify in a timely manner, areas of concern or failure with regards to service delivery.
The speed, completeness and quality of responses also differed quite significantly across the Council and the ability to gain insight into the nature and type of complaint was limited.
Another challenge with the existing process was addressing a complaint that had multiple parts and required a cross directorate response, co-ordination and the provision of a unified response often proved difficult.
The report set out a summary of the current 3 stage process for corporate
complaints:
Currently all complaints were received via email, letter, e-form or telephone, then these were manually recorded onto the new digital corporate complaints system. They were then directed to the correct service area for response and sign off by the relevant service head or their representative
Stage 1
All stage 1 complaints currently should be acknowledged within four days with the target to respond within 10 working days. These were signed off by the head of service or Assistant Director.
Stage 2
Where the customer was not satisfied with the response at stage 1, they could request the complaint to be reviewed by the director of the relevant department, by making clear what aspects of the response they did not agree with and what outcome they would like to see. (These requests should be submitted by the customer within 28 days of receipt of the stage 1 response). The target for services was to respond to Stage 2 complaints within 20 working days. These were received and logged as in the Stage 1 process.
Stage 3
If a customer was still dissatisfied, they could currently request to have the complaint escalated to the Chief Executive where the complaint was reviewed and responded to within a further 20 working days. The Chief Executive was only to consider cases that had already been through stages 1 and 2. Customers needed to set out why they were dissatisfied and what outcome they would like to see. (A stage 3 complaint should be responded to within 28 days of receipt of the stage 2 response.)
On reviewing a sample of the stage 3 complaints it was found that the stage 3 review did not change the outcome for the complainant (apart from a small number of cases) As with the above stages there was a significant amount of administration in logging, managing, chasing and writing responses to stage 3 complaints.
Digital Programme and refined complaints process
The digital programme played a key role in delivering improved efficiency by streamlining processes, promoting new ways of working, and making substantial improvements to IT by delivering a Customer Relationship Management (CRM) system in a phased implementation approach to cover all the Council’s service. Some of the benefits are:
• Simplification of processes, allowing the adoption of a model that was efficient, fully defined and standardised across the council, and capable of improving the quality of decisions.
• Improve customer service by building a Customer Relationship Management (CRM) system as the primary channel for residents to access products and services whilst providing proactive customer interactions to our service users.
• Deliver a modern, fit for purpose IT infrastructure for the Council drawing together all relevant customer information from interactions between the council and the customer, enabling a single accurate view of the customer, thereby promoting efficiency.
The complaints process was included in Wave 2 of the digital programme. Through business analysis and engagement with complaints staff, a process had been agreed to channel all customers to log their complaints through the new customer portal. This would allow for a single consolidated complaints service.
Proposal to change to a 2 stage complaints procedure
After going through the digital ‘as is’ and ‘to be’ mapping and engaging with service teams and directors including the Senior Leadership Team. All processes had been reviewed with one of the key recommendations being that it would be more efficient and an improved experience for the customer if the organisation only had a 2-stage procedure. If after stage 2 a customer was still unhappy with their response, they would be referred to the Ombudsman. This approach was supported by The Ombudsman and to support this decision we had also surveyed complaint processes for other London Boroughs.
Out of Local Authorities reviewed we have found the following:
• 23 have a two-stage process, including. Brent, Hounslow, Harrow, Hammersmith and Fulham, Richmond, Barnet, and Camden
• Of the West London Borough’s only Hillingdon still retain the stage 3 process.
From December 2021 all customers would be encouraged to log their complaints through the new customer portal (Dynamics CRM) which would eliminate the need for staff to input complaints information and data which would allow for automation in respect of allocation. All complaints received in this way could be tracked internally and reminders issued to those responsible for responding within timescales improving performance.
Any additional supporting documentation could also be uploaded by the customer, linked and case notes made, which will give a full history of the complaint.
The Head of Service would still be responsible in ensuring that an appropriate response is completed at stage 1 and the Director/ Executive Director would have responsibility at stage 2.
It was appreciated that there would be some complaints received through non-digital methods, with customers unable to use this service due to no access to digital or lack of skills. These customers would be supported by staff to submit their complaints, or the complaint would be logged onto the system manually through the CRM by the appropriate staff member, which would instigate the allocation and response process.
This reasonable adjustment was a requirement of the Housing Ombudsman Complaints Handling Code and has been reflected in the revised corporate complaints policy (Appendix 1 of the report) Staff would still be on hand in customer services to assist customers in using the new customer portal with a portal helpline being available for any enquiries regarding registration.
Change response times – Stage 1
On reviewing complaint SLAs across London, it was found that there were varying SLAs for stage 1 with many LA’s having a longer time to respond, up to 20 days (13 LA’s) or 15 days (8). Taking this into account and after feedback as outlined above from services, the proposal for a longer response time of 20 days for stage 1 with an acknowledgement of receipt within 2 days (currently 4).
It was thought the longer response time allowed would enable services to carry out a proper and full investigation and ensure the complaint was dealt with thoroughly which was often challenging in some areas such as Planning, Housing and Benefits due to the service complexity. With the new digital solution in place and improved reporting it would be easier to monitor the performance against response times and processes would be in place to ensure robust management of the new response times to ensure targets are met. It was anticipated with the longer time allowed to respond the quality and resolution of complaints would improve, this would be monitored closely after implementation.
The complaints policy had been updated to reflect the outlined changes in process as detailed in Appendix 1 of the report The attached policy also reflected a change in the definition of a complaint which was now in line with the Ombudsman definition.
Member Enquiries
The digital programme had also reviewed the Member enquiry process which was currently very haphazard. Although there were dedicated members mailboxes for individual service areas, it was common practice to email free text to any number of officers with the same enquiry at the same time. This risked, duplicating officer time or not having the enquiry resolved as no one took responsibility for the enquiry. Members have raised issues in the past where they felt that officers did not respond in a timely manner or in some cases not at all.
The proposal will be for members to use the “members portal” to submit all their enquiries, as this would ensure they were allocated in a timely manner to the correct officers and would be tracked to ensure that an appropriate response was done. This ask of the Members would be a behavioural and cultural change, however if the benefits of the portal were to be realised for both efficiency and service improvement it would be a necessary requirement. Benefits were:
• Members could track cases via the portal
• Improved response times
• Improved quality of responses
• Reduction in administration and duplication
• Data held in one place
• Achieving economies of scale from the consolidating of activities across the council
It was recognised that we would need to have a clear consultation and engagement plan for members to implement this strategy. This would follow the same format used in the digital change programme with planned communication about the proposed changes, demonstrations of the system and training if required. The plan would be to start looking at implementing after the go live of the complaints
Ombudsman
Currently the Ombudsman was required to use one access point to contact the council and this was at their request, and it was not envisaged that this would change, however responsibility for administration of Ombudsman enquiries sat with Customer Services who received and distribute all complaints and enquiries and would also have the oversight of Cllrs/MP’s and all complaints enquires. All Ombudsman enquiries would be logged and managed by customer services through the new customer portal.