10 steps to developing an effective Complaints
Management System (CMS)
Councils
1. What is a CMS?
A CMS is a staged way of receiving, recording, resolving,
responding to and reporting on complaints.
3. Review your council’s current process of
managing complaints
Councils make important decisions and provide vital services
to their communities.
A complaint is simply one form of feedback. Other forms of
feedback include service requests, information and document Complaints are inevitable for any organisation dealing with
requests, enquiries, suggestions, compliments.
the public. Accordingly, your council will be dealing with
One of the key differences between a complaint and another complaints even though it may not have a formal or approved
CMS, meeting legislative requirements and other recognised
form of feedback is that a complaint involves a person
expressing dissatisfaction, either verbally or in writing, about standards of good complaints management.
a decision, action or service provided (or not provided) by a
Your council’s current process of complaints management is
council or its staff. The other forms of feedback don’t include
relevant and should inform any development or enhancement
any indication of dissatisfaction. An effective CMS should:
of an effective CMS. The review of the current process should
ÆÆ Provide a simple and clear process (to staff and public),
fair and timely complaint outcomes and information to
help improve service delivery.
ÆÆ Include written policy and procedures, a complaints
recording and reporting system and other resources
including trained staff and website.
ÆÆ Meet recognised standard and principles of good
complaints management practice.
Under the Local Government Regulation (LGR) s306 each
council is required to adopt, a complaints management
process for resolving administrative action complaints. This
statutory complaints management process is a CMS. The
requirements for this process (CMS) are outlined in LGR s306.
2. Why would an effective CMS be valuable to
your council?
People have a right to complain and the community expects
that councils will be customer-focused and responsive to
feedback, particularly complaints. An effective CMS is an
integral part of quality customer service and the accountability
process. It should provide tangible benefits for councils, staff
and in particular the community. Benefits of an effective
CMS include:
ÆÆ providing a structured and consistent approach to
complaints management across council
ÆÆ promoting customer satisfaction
ÆÆ enabling poor decisions/actions to be rectified quickly
and efficiently
identify, for example:
ÆÆ What are the main types and sources of complaints?
ÆÆ Is the complaints process is communicated to staff, the
community and complainants and, if so, how?
ÆÆ How are complaints managed from receipt to
resolution or finalisation?
ÆÆ What staff and other resources are used in managing
complaints?
ÆÆ What authority and training staff have to manage and
resolve complaints?
ÆÆ Are complaints recorded and reported on and if so, how?
ÆÆ Is complaints data used to identify and rectify systemic
and recurring problems?
ÆÆ Is management involved in reviewing and monitoring
the effectiveness of the CMS?
ÆÆ Is management and staff committed to effective
complaints management?
ÆÆ What is the council’s complaints culture? Are complaints
viewed negatively or positively?
The QOO ‘Effective Complaints Management SelfAudit Checklist’ is designed to help councils and other
agencies review their current complaints processes and
to identify improvements. This checklist is available at
the QOO website at http://www.ombudsman.qld.gov.
au/PublicAgencies/EffectiveComplaintsManagement/
ComplaintsManagementResources.aspx
4. Commit to an effective CMS
ÆÆ saving money by resolving complaints internally, close
to the source
The review of your council’s current complaints process should
provide a good indication of its commitment to complaints
management.
ÆÆ preventing complaints from unnecessarily escalating,
a situation which can be resource intensive and lead to
adverse publicity
An effective CMS requires a strong commitment by
management and staff to make it work.
Complaints management should be taken seriously and seen
ÆÆ identifying areas, practices, procedures and services for as integral to good customer service. Complaints should be
improvement
welcomed and viewed positively as providing an opportunity
ÆÆ satisfying council’s statutory obligation to implement a to review and improve council’s performance.
complaints management process.
In particular, councils should have a commitment to
recognised or guiding principles of good complaints
One of the major returns on investment in an effective CMS
should be administrative and service improvements to benefit management (AS ISO 10002-2006 Customer satisfaction –
Guidelines for complaints handling in organisations refer).
individuals and the community.
These principles are:
ÆÆ visibility- information about how and where to
complain should be well publicised to customers, staff
and the public
ÆÆ accessibility - the CMS process should be easily
accessible to all complainants
ÆÆ responsiveness - complaints should be acknowledged,
and addressed promptly in accordance with their
urgency
ÆÆ objectivity - each complaint should be addressed in an
equitable, objective and unbiased manner through the
complaints process
ÆÆ charges - there should be no charge for access to the
complaints process
ÆÆ confidentiality – personal information concerning the
complainant should be used only for the purposes
of addressing the complaint and protected from
disclosure unless the complainant agrees to the release
ÆÆ customer-focused approach – customer-focused
approach should be adopted, open to complaints
and show commitment to resolving complaints by its
actions.
ÆÆ accountability – accountability for and reporting on
complaint decisions and actions is clearly established
ÆÆ continual improvement – continual improvement of the
CMS and services is a key objective.
is fair, all relevant information is considered and
affected people are afforded a fair hearing)
ÆÆ complaints resolution timeliness (e.g. complaints are
promptly handled within expected timeframes)
ÆÆ complaints resolution outcomes (e.g. correct complaint
outcomes are achieved and reasonable remedies to
rectify complaints are implemented)
ÆÆ complaints monitoring (e.g. complaints data is used to
identify improvements to decision-making, practices
and service delivery).
Clarifying the CMS underlying principles and objectives at the
outset should inform the overall direction and development
of the CMS. In particular, the CMS principles and objectives
should be considered in determining the substance, form and
complexity of the CMS that will best suit your council.
6. Determine the substance, form and
complexity of the CMS
Each council has flexibility to determine the substance, form
and complexity of their CMS. The LGR doesn’t require a council
to adopt a complex or detailed CMS. It requires only that a
council’s CMS comply with certain requirements.
A good CMS is one that provides a simple and fair process that
is clear to the public and staff and meets good complaints
management principles and statutory requirements. This
approach recognises that the ‘one size fits all’ CMS is not
effective. Councils should develop a CMS that suits their own
ÆÆ adopting a complaints management process and
needs. In determining the substance, form and complexity of
supporting written policy and procedures
ÆÆ placing the complaints management process (including the CMS, councils should have also have regard to:
policy and procedures) on the council website and at
ÆÆ their size
its office.
ÆÆ the nature of functions and services provided
ÆÆ recording all complaints
ÆÆ geographic distribution of council offices
ÆÆ responding quickly and efficiently to complaints in a
ÆÆ the source of complaints
fair and objective way
It is also important that councils are committed to ensuring
compliance with the statutory requirements of the
administrative action complaints process. (LGR s306 & s187
refers). These requirements include:
ÆÆ informing complainants of the complaint decision and
reasons
ÆÆ internal reporting to senior management on complaint
trends and monitoring effectiveness of the CMS
ÆÆ external reporting on the operation and performance
of the cms in council’s annual report.
Your council’s commitment to an effective CMS should be
clearly stated and available e.g. in the approved CMS policy
and on your council’s website. However, the key is putting
commitments into operation.
5. Determine the CMS objectives
An effective CMS should have clearly stated and defined
objectives. The objectives should be determined by
considering recognised principles of good complaints
management and relevant statutory requirements. The
objectives of an effective CMS should generally address:
ÆÆ complaints visibility and accessibility (e.g. complaints
process and related information is easily visible and
accessible to the community, customers and staff )
ÆÆ complaints resolution process (e.g. complaints process
ÆÆ the volume and type of complaints.
Integral to the substance, form and complexity of the CMS is
the complaints model. The complaints model is essentially
the complaints handling stages in the CMS. The LGR doesn’t
prescribe a particular complaints model. It is important that
each council adopt a suitable model.
Generally, a two stage internal model may suit smaller
councils. This model has an initial frontline stage and an
internal review stage. The frontline stage is where staff
have authority to deal with specified low-level complaints.
The internal review stage handles unresolved or referred
complaints from the frontline (stage1) by way of an
independent merits review. Complaints unresolved at stage
two should be advised of the external review right to the
Queensland Ombudsman.
Alternatively, smaller councils may adopt a centralised
model i.e. where all complaints are referred to one person
for management e.g. the Deputy CEO or CEO. Unresolved
complaints may then be referred to the council for
consideration or to the Queensland Ombudsman for external
review.
For further information about complaints management
models refer to the QOO ‘Effective Complaints Management
Fact Sheet Series’.
Having reviewed your current process, committed to
recognised principles of good complaints management, and
determined your CMS objectives and model, you are now in
a position to develop your CMS policy, procedures, recording
and reporting system and other resources.
receiving, recording, assessing, reviewing and responding
stages of the complaints process. [The LGR s306 requires
council CMS’s to quickly and efficiently respond to
complaints in a fair and objective way and inform an
affected person of the complaint decision and reasons.]
Internal reporting is about collecting and analysing
individual or aggregate complaints data to highlight
complaint trends, systemic or recurring issues and to identify
improvements. [The LGR s306 requires internal reports to be
provided about the operation of the CMS and mechanisms
7. Preparing a CMS policy
to be in place to identify, analyse and respond to complaint
An effective CMS should be supported by an approved written trends.]
policy. LGR s306 requires the administrative action complaints
Monitoring effectiveness is about reviewing regularly the
process be supported by written policy. Each council is
operating effectiveness/performance of the CMS. Reviewing a
required to adopt a CMS policy.
CMS should include evaluating the policy and procedures and
A CMS policy shouldn’t be a lengthy document. Its purpose is other elements of the system, auditing resolved complaints for
data accuracy, compliance with procedures and correctness of
to set out the direction of council’s complaints management
approach. It should explain the strategic intent i.e. the ‘why’ of outcomes, and consulting staff, customers and complainants.
council’s commitment to the principles underlying the CMS. A [The LGR s306 requires each council to monitor the
effectiveness of the CMS e.g. by monitoring the time taken
CMS policy document should include:
to resolve complaints.]
ÆÆ policy name
External reporting of the CMS is important for accountability
ÆÆ policy approval (date and council resolution)
and transparency purposes. Councils should publicly report
ÆÆ policy review date/period
on the operation and performance of CMS’s in annual reports.
ÆÆ legislative authority (LGA s268 & LGR s306)
[The LGR s187 requires each council annual report to contain
ÆÆ commitment to recognised good complaints
information about the implementation and performance of
management principles
the CMS including complaints statistics.]
ÆÆ policy objectives
Importantly, the CMS policy should be consistent with and
ÆÆ scope/application of the policy
ÆÆ complaints model
ÆÆ CMS elements (and associated principles) – external
visibility and accessibility , internal communication
and training, complaints resolution, feedback, internal
reporting, monitoring effectiveness and external
reporting
ÆÆ roles and responsibilities
ÆÆ definitions – key terms
CMS policy elements
External visibility and accessibility is about providing
customers and the public with readily available information
about, and easy access to, a council’s CMS. Council websites
are an important channel in this regard and should include
general complaints information, the CMS policy and
procedures and online or other electronic complaints access.
[The LGR s306 requires each council to ensure their CMS
including related policy and procedures are available on
their website.]
incorporate relevant statutory requirements (LGA s268, LGR
s306, and s187). The CMS policy is the primary overarching
internal document governing the CMS. It provides the basis for
developing the CMS procedures.
For further information about developing CMS policy refer
to the QOO ‘Guide to Developing Effective Complaints
Management Policies and Procedures’ and ‘Effective
Complaints Management Fact Sheet Series’.
8. Preparing CMS procedures
An effective CMS should be supported by approved
procedures. LGR s306 requires the administrative action
complaints process be supported by written procedures.
Councils are required to adopt CMS procedures. CMS
procedures should be consistent with and incorporate the
statutory requirements. They should also be consistent with
the CMS policy.
The CMS procedures document is necessarily longer than the
policy and describes the steps involved in achieving the CMS
policy’s objectives. In particular, the CMS procedures should
Internal communication (visibility) of the CMS, and training
outline the steps involved in handling complaints. However,
on effective complaints management principles including
they can’t cover every situation. Generally, CMS procedures
CMS policy and procedures, are critical to staff awareness
document should include:
and understanding of the CMS. Staff are the most important
resource in an effective CMS. [The LGR s306 doesn’t specify
ÆÆ procedures name
any requirements on internal communication or training on
ÆÆ approval (date and council resolution)
the CMS.]
ÆÆ procedures review date/period
Effective complaints resolution is about achieving right
ÆÆ legislative authority (LGA s268 & LGR s306)
outcomes in a fair and timely way and providing meaningful
ÆÆ scope/application of the procedures
responses. Central to effective complaints resolution is the
ÆÆ complaint model - stages
ÆÆ complaints resolution procedures – receiving,
recording, assessing, investigating/reviewing and
responding
ÆÆ procedures for internal complaints reporting,
monitoring CMS effectiveness, external (annual)
complaints reporting
ÆÆ roles and responsibilities
ÆÆ definitions – key terms.
For further information about developing CMS procedures
refer to the QOO ‘Guide to Developing Effective Complaints
Management Policies and Procedures’ and ‘Effective
Complaints Management Fact Sheet Series’.
9. Establishing a CMS recording and reporting
system
Complaints management is an essential part of a council’s
decision-making and service delivery to individuals and the
community.
The LGR (s306) requires all complaints to be recorded
(regardless of where or how a complaint is made to council or
how quickly a complaint may be resolved). It also requires that
councils have mechanisms in place to identify, analyse and
respond to complaint trends with internal reports to senior
management about the CMS operation.
Accordingly, complaints must be recorded and reported on for
statutory, accountability and business improvement purposes.
Your council’s CMS policy and procedures should reflect
these requirements and provide further guidance to staff on
complaints recording and reporting.
A complaints recording and reporting system doesn’t have to
be complex or expensive database or other electronic system.
Effective complaints recording and reporting system should
meet council’s individual needs and structure and may be as
simple as a spread sheet.
However, any system implemented by a council should be
able to capture key complaints information in sufficient detail
to support the analysis of complaints data for the purpose
of identifying business/service delivery improvements. Key
complaints information includes:
ÆÆ complainant’s details - name, address, contact
ÆÆ date and how complaint received
ÆÆ Set out complaint numbers and outcomes (for different
complaint types).
ÆÆ Provide comparisons with previous periods to highlight
any trends, recurring or emerging issues.
ÆÆ Identify any significant or systemic issues requiring
attention.
ÆÆ Outline any potential improvements.
For further information on complaints recording and reporting
systems refer to the QOO ‘Effective Complaints Management
Fact Sheet Series’.
10. Developing other resources
Competent complaints handling staff and readily visible and
accessible CMS on the website are important CMS resources.
All staff should be made aware of the existence and operation
of the CMS e.g. by email, induction programs. Also, staff
involved in complaints handling should be trained on
the operation of the CMS, particularly the CMS policy and
procedures and their roles/responsibilities.
A council’s website is an important channel for people to make
complaints. The CMS and related policy and procedures must
be available on a council’s website (LGR s306 refers). However,
your website should also include:
ÆÆ a clearly identifiable complaints link on the homepage
to a complaints page
ÆÆ a complaints page providing general information about
the CMS
ÆÆ online, email or other electronic complaints access.
For further information on internal communication and
training on the CMS to staff and website complaints visibility
and accessibility refer to the QOO ‘Effective Complaints
Management Fact Sheet Series’.
Want to know more?
The Queensland Ombudsman offers training in Complaints
Management, Good Decisions, Administrative Investigations
and Ethical Decision-Making. You can find an outline of these
programs in our training book at:
http://www.ombudsman.qld.gov.au/Portals/0/Training_
Workbook_June2012.pdf
Access QOO’s Complaints Management resources
at: http://www.ombudsman.qld.gov.au/
PublicAgencies/EffectiveComplaintsManagement/
ÆÆ significant actions taken to progress and resolve complaint ComplaintsManagementResources.aspx
ÆÆ complaint outcome - substantiated, unsubstantiated,
partly substantiated
ÆÆ nature of complaint - subject matter/issue, outcome/s
sought
ÆÆ date complaint finalised - resolution timeframe
ÆÆ resolution type - remedies to rectify complaint.
Overall, the system should be able to record and monitor
complaints, capture sufficient meaningful complaints
information to identify, analyse and respond to complaint
trends, identify improvements and produce reports for
consideration by senior management. For example, complaint
reports should: