This is the fourth and final part in a series of articles on complaints handling, what it involves and why schools need to implement effective complaints handling processes. The articles are based on a paper entitled ‘Managing Complaints - Walking the Tightrope between Ignorance and Knowledge’ presented by CompliSpace Managing Director James Field at the Australia and New Zealand Education Law Association (ANZELA) Conference in Adelaide on 2 October 2014. The paper is available in full here.
Records should be kept of every complaint including records of the description of the complaint, supporting documents if any, immediate action taken, records relating to the investigation including witness statements if any etc.
All complaints should be recorded on a complaints register, classified and analysed to identify systemic, recurring and single incident problems and trends in order to identify key risk areas and help eliminate the underlying causes of complaints through corrective actions.
A school’s board of governors and senior management team should receive regular reports with respect to the status of existing complaints, any underlying statistical trends, as well as information with respect to corrective actions that have been put in place.
ISO 10002-2014 (the ‘Complaints Handling Standard’, ‘the Standard’ or ‘ISO 10002’) requires regular review and continual improvement of a school’s complaints handling process.
The legal framework for complaints handling in Australian schools is characterised by an inconsistent patch-work of laws and regulations, departmental directives and non-government school registration standards. See the executive summary of the legal obligations of Australian schools to manage complaints set out in Schedule 1 of the paper, together with a gap analysis of these obligations against the Australian Complaints Handling Standard.
Notable findings from this gap analysis include:
There can be little argument that the proactive management of complaints in schools has considerable benefits. Common sense dictates this. There are not too many schools that, given the chance, would not want to control the agenda when dealing with problems and issues raised by members of their communities.
There can also be little doubt, especially in this “social media” age, that the risk of failing to manage complaints effectively has the potential to create adverse consequences for a school that in all likelihood will lead to reputational damage.
So why is it that schools are not managing complaints effectively?
One of the reasons often cited by schools is that they would be overrun with complaints from pushy Type-A parents and they can’t afford to allocate resources to this process. Unfortunately this amounts to letting pushy Type-A parents control the agenda whilst the legitimate feedback of other parents that really does reflect on a school's standard of services is not captured effectively.
The irony is that a properly designed complaints system will enable a school to identify and effectively manage frivolous and vexatious complainants. This was illustrated by the following story. At a school with Junior, Middle and Senior school campuses, the various heads of school only became aware by chance conversation that they were all receiving volumes of complaints from the same parent (with three children at the school, all in different years). On further (co-ordinated) investigation the source of the parent’s issues were traced back to a recent separation and managed with appropriate sensitivity.
This series of articles contends that the real reason that many schools don’t manage complaints effectively is that they don’t understand the benefits that they would gain from effective complaints management and they don’t understand how to implement an effective complaints handling process.
The lack of regulatory direction and guidance is partially to blame for the current state of affairs. Requiring a school to “implement a complaints handling policy” with no further guidance, or education, is not likely to achieve the desired result. Even where regulators have published detailed guidelines, they provide schools with little or no practical assistance. Ultimately it is up to each school, individually, to work out what to do.
Now here’s a radical idea. Every school in Australia has more or less the same issue. A complaints handling program designed to be implemented in one school would, in all likelihood, (99%) fit another school. Rather than have regulators produce lots of bulky guidance documents that are difficult to read and impossible to implement, why not produce a “complaint handling pack (kit, module etc)” that is designed to be implemented at a local school level?
What would you need?
Properly designed such a system would not only facilitate the proper management of complaints at a local school level but also it would allow regulators to benchmark performance between schools and identify key risks before they become substantial issues.