External Complaints Handling Policy

1. OVERVIEW

The HALO Trust (the Charity) views third party complaints (complaints from outside the organisation) as an opportunity to learn and improve for the future, as well as a chance to put things right for the person or organisation that has made the complaint. Our policy is:

• to provide a fair external complaints procedure which is clear and easy to use for anyone wishing to make a complaint;
• to publicise the existence of our external complaints procedure so that people know how to contact us to make a complaint;
• to make sure everyone at the Charity knows what to do if an external complaint is received;
• to make sure all external complaints are investigated fairly and in a timely way;
• to make sure that external complaints are, wherever possible, resolved and that relationships are repaired; and
• to gather information which helps us to improve what we do.

2. DEFINITION OF A COMPLAINT

2.1An external complaint is any expression of dissatisfaction, whether justified or not, about any aspect of the Charity.
2.2 External complaints may come from donors and other individuals who we contact about our work, or any other person or organisation with an interest in the Charity and its activities.
2.3 An external complaint can be received verbally, by phone, by email or in writing.

3. CONFIDENTIALITY

All complaint information will be handled sensitively, telling only those who need to know and following any relevant data protection requirements.

4. RESPONSIBILITY

Overall responsibility for this policy and its implementation lies with the Board of Trustees of the Charity.

5. REVIEW

This policy is reviewed regularly and updated as required.

6. COMPLAINTS PROCEDURE

6.1 Written complaints may be sent to the Charity at:

The HALO Trust, Carronfoot, Thornhill, Dumfries DG3 5BF

or e-mail mail@halotrust.org

6.2 Verbal complaints may be made by phone to 01848 331100 or in person to any of the Charity’s staff, volunteers or Trustees.

6.3 Complaints can also be made directly to the Charity Commission or, if the complaint relates to the use of the complainant’s personal information by the Charity, to the Information Commissioner’s Office (the ICO) (see paragraph 11).

7. RECEIVING COMPLAINTS

7.1 External complaints may arrive through channels publicised for that purpose or through any other contact details or opportunities the complainant may have. Complaints received by telephone or in person need to be recorded. The person who receives a phone or in person complaint should:

• Write down the facts of the complaint;
• Take the complainant's name, address and telephone number;
• Note down the relationship of the complainant to the Charity (e.g. donor, mailing list member);
• Tell the complainant that we have a complaints procedure;
• Tell the complainant what will happen next and how long it will take;
• Where appropriate, ask the complainant to send a written account by post or by email so that the complaint is recorded in the complainant’s own words.

7.2 For further guidelines about handling verbal complaints, see the Appendix.

8. RESOLVING COMPLAINTS: STAGE ONE

8.1 In many cases, a complaint is best resolved by the person responsible for the issue being complained about. If the complaint has been received by that person, they may be able to resolve it swiftly and should do so if possible and appropriate. Whether or not the complaint has been resolved, the complaint information should be passed to the Office Manager within one week.

8.2 On receiving the complaint, the Office Manager records it in the complaints log. If it has not already been resolved, they pass it to the appropriate person to investigate it and to take appropriate action.

8.3 If the complaint relates to a specific person, they should be informed and given a fair opportunity to respond.

8.4 Complaints should be acknowledged by the person handling the complaint within a week. The acknowledgement should say who is dealing with the complaint and when the person complaining can expect a reply. A copy of this complaints procedure should be attached.

8.5 Ideally, complainants should receive a definitive reply within four weeks. If this is not possible – because, for example, an investigation has not been fully completed – a progress report should be sent with an indication of when a full reply will be given.

8.6 Whether the complaint is justified or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint.

9. RESOLVING COMPLAINTS: STAGE TWO

9.1 If the complainant feels that the problem has not been satisfactorily resolved at Stage One, they can request that the complaint is reviewed by the CEO, or by the Board of trustees. At this stage, the complaint will be passed to the CEO, or to the Chair, via the CEO..

9.2 The request for Board level review should be acknowledged within a week of receiving it. The acknowledgement should say who will deal with the case and when the complainant can expect a reply.

9.3 The Chair may investigate the facts of the case herself / himself or delegate a suitably senior person to do so. This may involve reviewing the paperwork of the case and speaking with the person who dealt with the complaint at Stage One.

9.4 If the complaint relates to a specific person, they should be informed and given a further opportunity to respond.

9.5 The person who dealt with the original complaint at Stage One should be kept informed of what is happening.

9.6 Ideally, complainants should receive a definitive reply within four weeks. If this is not possible because, for example, an investigation has not been fully completed, a progress report should be sent with an indication of when a full reply will be given.

9.7 Whether the complaint is upheld or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint.

9.8 The decision taken at this stage is final, unless the Board decides it is appropriate to seek external assistance with resolution.

10. VARIATION OF THE COMPLAINTS PROCEDURE

The Board may vary this procedure if it has good reason for doing so, such as a conflict of interest. For example, if the complaint was about the Chair, it would not be appropriate for the Chair to conduct a Stage Two review.

11. COMPLAINTS TO A REGULATOR

11.1 A complainant can complain to the Charity Commission at any stage. Information about the kind of complaints the Commission can involve itself in can be found on its website.

11.2 If the complaint relates to the use of the complainant’s personal information by HALO the complainant may complain to the ICO. Information about the kind of complaints the ICO can involve itself in and how it deals with complaints can be found on its website.

11.3 In the event a regulator receives a complaint in relation to the Charity, the Charity will cooperate with that regulator as appropriate.

12. MONITORING AND LEARNING FROM COMPLAINTS

Complaints are reviewed annually to identify any trends which may indicate a need to take further action.

Latest Revision/ Agreed by Trustees: 26 February 2021