Complaints Policy

COMPLAINTS POLICY AND PROCEDURE

Say GP:

• Understands the importance of dealing effectively with complaints in a timely manner, as well as acknowledging and acting on feedback received
• Recognises that failure to deal with a complaint is a serious matter
• Will acknowledge a complaint and offer a discussion about the handling of the complaint
• Will keep the complainant informed if a response is delayed
• Considers the quality of care provided by putting themselves in the place of the complainant and assessing their expectations for the service
• Reviews services and how they are delivered in relation to complaints and feedback received
• Makes changes where necessary or appropriate to improve services and the Patient experience
• Monitors outputs from changes and developments as part of a continuous cycle of improvement
• Keeps accurate records and documentation for all complaints and feedback
• Provides access to Patients for information about how to make a complaint, the complaints process and timescales in appropriate or specific requested accessible formats
• Understands statutory obligations in respect of the Duty of Candour and will follow the agreed policy and procedure

Say GP will ensure that the complaints and compliments process is fair and transparent and does not discriminate directly or indirectly because of:

• Age
• Being or becoming a transsexual/transgender person
• Being married or in a civil partnership
• Being pregnant or on maternity leave
• Disability
• Race including colour, nationality, ethnic or national origin
• Religion, belief or lack of religion/belief
• Sex
• Sexual orientation

The complainant will feel free to complain without fear of reprisal and will be treated with courtesy, respect and compassion.

Say GP understands that it can be difficult to separate a complaint from a concern. Therefore, Say GP will follow this policy when any dissatisfaction arises with the service.

Say GP will protect the Patient's right to confidentiality. 

Dr. Semiya Aziz will keep a full record of all complaints received, regardless of the level of seriousness and means of communication. This approach allows an open and transparent culture around raising concerns in the earliest stage to allow resolution.

It is acknowledged that Dr Semiya Aziz of Say GP could be presented with a patient wishing to raise a concern or complaint at any time. Therefore, Dr Semiya Aziz will need to be able to manage this in a sensitive, structured and timely manner. In order to do so Dr Semiya Aziz will:

• Have access to the complaints procedure
• Be provided with the opportunity to reflect and learn from complaints as a means of developing and driving quality care
• Appreciate that any feedback from Patients or their representatives that is of concern needs immediate resolution, where possible, to their satisfaction
• Be clearly advised that, when presented with a complaint, swift escalation to is necessary, and purposefully withholding or concealing concerns expressed by Patients or their representatives could lead to disciplinary action

• Dr. Semiya Aziz is responsible for ensuring compliance with this policy, for regulations, for improvement planning and having arrangements in place to provide relevant reports and information regarding complaints
• Dr. Semiya Aziz is the main initial point of contact for the receipt, investigation and management of complaints within Say GP. This will then be forwarded to an independent body ISCAS of which Say GP is registered with. ISCAS have the experience, knowledge and competence to investigate and manage complaints as an Independent Body.
• Say GP will ensure that the procedure for raising a complaint is accessible

Say GP will seek out opportunities to obtain feedback from Patients. Say GP will act with sensitivity, integrity and professionalism by treating individuals who do raise a suggestion with compassion, courtesy and respect.

Consent for feedback and opinions will be required for all feedback requested from individuals. It is an individual's right to not participate with workplace ongoing feedback requests. Permission will be sought, alongside full explanations of the aim of feedback requests to ensure that understanding is clear.

Where a complaint or concern is raised that relates to a Patient being harmed or likely to be harmed, Say GP will follow the Safeguarding Adults Policy and Procedure at Say GP in addition to the complaints procedures, seeking advice and guidance from the London Borough of Barnet Safeguarding Team and raising a safeguarding notification where required. Say GP will also notify the Barnet NHS CCG in line with its statutory duty.

PROCEDURE

• A complaint can be received either verbally or in writing and can be made by:
• Patients
• Someone acting on behalf of a Patient with their written consent, for example, a relative, advocate or Member of Parliament
• Someone acting on behalf of a Patient who is unable to represent their own interests provided this does not conflict with the Patient’s right to confidentiality or a previously expressed wish of the Patient

Say GP should ensure that Patients are given information on how to make a complaint and the process once a complaint has been made, including any agreed timescales.

Before beginning an investigation, Dr. Semiya Aziz will assess the seriousness of the complaint and forward this to ISCAS. If a complainant does not wish to pursue an issue, ISCAS will investigate the issue to identify what led to the complaint so that Say GP can use complaints as part of the learning and improvement cycle to assist in service improvement.

The complainant may be invited to meet with Dr. Semiya Aziz to discuss the complaint. This may be done face to face, online, or over the telephone if appropriate. It is important to establish, at the earliest opportunity, what outcome the complainant expects, and to let the complainant know whether this is a realistic and possible expectation.

When a complaint is made on behalf of a child, Dr. Semiya Aziz must be satisfied that there are reasonable grounds for the complaint being made by the complainant, rather than the child. Dr. Semiya Aziz must also be satisfied that the complaint is being made in the best interests of the child. If Dr. Semiya Aziz is not satisfied that this is the case, written notification of this decision must be sent to the complainant.

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Anonymous complaints should be investigated in the same way as named complaints. They should be logged and any corrective action necessary should be taken and also logged.

Step 1

When a complaint is raised, Dr Semiya Aziz will make an effort to resolve it immediately using ISCAS to the satisfaction of the complainant.

Dr Semiya Aziz will apologise for the fact that there was the need to complain in the first instance and explain the complaints process as described in the procedure steps.

The complaint will be logged by Dr Semiya Aziz.

Formal acknowledgement of the complaint will be sent to the complainant within 3 working days and could be via letter or email. Say GP will ensure that complaints received out of normal working hours are managed effectively.

The acknowledgement will include:

• An invitation to meet and discuss the complaint
• Who will be investigating the complaint which for Say GP will be ISCAS.
• How the investigation will be handled - the response should state what the investigation will be focused on
• A time limit for the investigation to be concluded. This should be 28 days. However, some cases may take longer and the complainant will be made aware of this
• The complaints procedure and contact details of bodies that can be accessed in the event of dissatisfaction with the outcome of the investigation

Following a full investigation, a response letter will be sent and this will include the following:

A summary of the issue from the complainant’s point of view

• Details of the evidence and sources consulted in order to investigate the issue fully and fairly
• A presentation of the findings for each issue clearly and concisely described
• A conclusion, stating clearly whether the issue is “upheld”, “partially upheld” or “not upheld”, unless it is ineligible, in which case the reason for this will be given, e.g. out of time or out of jurisdiction
• An explanation of the outcome and whether any remedial action or learning points arise from the investigation of that issue
• An apology where the issue is upheld and shortcomings or failings have been found
• The complainant's rights if not satisfied with the outcome
• A signature from Dr. Semiya Aziz.

The complaint will be closed once confirmation has been received that there is satisfaction with the outcome. In the event of dissatisfaction, Dr. Semiya Aziz will support the complainant to access further support if required.

Occasionally, Say GP may receive complaints that are vexatious in that they cause considerable disruption to the work at Say GP, disproportionate cost and time to handle and impact the wellbeing of Dr Semiya Aziz (because of the way the complaint is made or because of its repetitive nature).

Say GP will ensure that it meets the requirements of the Equality Act 2010 to make ‘reasonable adjustments’ for disabled customers. In some circumstances, customers may have a disability that makes it difficult for them to either express themselves or communicate clearly and/or appropriately. Where there is an indication that this may be the case, Say GP will consider the needs and circumstances of the Patient or complainant in the first instance and use this information to inform any decisions that are made.

Where appropriate, Say GP will consider complaints to be vexatious but would not label an individual complainant as vexatious. Even if Say GP decides that an individual’s complaint about the service is vexatious, that does not preclude that person from making a formal complaint. Say GP would still consider any such complaints in line with the usual procedures.

To help decide whether a complaint is vexatious, Say GP will consider the full history and context of interactions with the individual making the complaint and will look at both the nature of the complaint and the manner in which it is made. The particular issues that will inform a decision will include whether:

• The primary purpose and/or effect of the complaint is to disturb, disrupt and/or pressurise Say GP, and Dr Semiya Aziz
• The primary purpose and/or effect of the manner in which the complaint is made is to disturb, disrupt and/or pressurise Say GP, and Dr Semiya Aziz
• The complaint is otherwise clearly unreasonable

Dr. Semiya Aziz will consider the complaint, seek external advice if appropriate, and will either declare the complaint as being vexatious, or not. Where a complaint is not deemed to be vexatious, it will be returned to the appropriate point in the complaints handling process.

If a complaint is deemed to be vexatious, Dr. Semiya Aziz will ask ISCAS to directly to the complainant explaining why it is thought to be so and explain that the complaint will be closed with no further action. Dr. Semiya Aziz will also consider if the making of a vexatious complaint also requires the application of a restriction on communication following unreasonable behaviour.

The decision to declare a complaint as vexatious will be recorded in the complaints register for future reference.

Any declaration that refers to the specific complaint being vexatious and any further complaints from the same individual will still be considered.

This will contain all correspondence from each complaint received including the following:

• Details of the complaint including subject matter, date of receipt and method of receipt
• Date and method of acknowledgement
• Notes from any meetings with the complainant wherever possible agreed with the complainant by countersignature
• Details of any reason for delay where investigations took longer than any agreed response period and evidence of keeping the complainant informed of any delay
• The date the response letter was sent to the complainant
• Dates when the complaint was discussed in internal meetings at Say GP
• Changes or developments made in response to the complaint as a result of the complaints investigation, including how and when these were shared
• Learning from the complaint to improve quality of care
• Dates of formal complaints reviews

Where complaints are raised by telephone, the log will include the date and time of the call and the content of the conversation.

Complaints to be shared for learning purposes will be anonymised by removing all identifiable Patient information or details and information pointing to the identity of the complainant.

All investigations will be managed by using the following approach:

• Investigating the fact
• Assessing evidence
• Reviewing records
• Interviewing those involved

Where necessary, advice and support will be sourced via ISCAS. The complaint should be investigated by ISCAS  with the knowledge, experience and seniority to undertake the investigation robustly.

Confidentiality of information will be considered at all times and staff will adhere to the confidentiality policies and relevant codes of practice.

If an investigation of a complaint results in disciplinary action for Dr Semiya Aziz within Say GP, the complaint will continue to its conclusion. The complainant will be informed that the investigation has led to a disciplinary process, but the details of the outcome or ongoing investigation should remain confidential.

There are many bodies that can support, or will need to be informed of, unresolved complaints:

1. General Medical Council

Individuals can escalate their complaint to GMC via:

• Website
• Email

Individuals have the right to raise a concern about private healthcare (not including dental or eye care):

Email: info@iscas.org.uk

Telephone: 020 7536 6091

Address: ISCAS, CEDR, 3rd Floor, 100 St. Paul’s Churchyard, London, EC4M 8BU

Individuals can make a complaint about a health service they are receiving or have received and can discuss this with the commissioner of their local ICB service.

If a complaint involves the serious misconduct of a healthcare professional, their relevant professional body can be informed and this is determined on an individual case basis in discussion with Dr. Semiya Aziz.

Suggestions can be made verbally or in writing and generally are in response to seeking a means of changing things for the better.

• Suggestions are not complaints, but in some circumstances, if they are not considered or actioned, they could lead to a complaint
• When suggestions are raised in meetings or as part of a conversation, these should be documented and then outcomes of such suggestions recorded to show that they have been considered
• Staff should be encouraged to share their suggestions with their manager
• Consideration should be given to implementing a suggestions system to encourage comments from Patients, staff and visitors

Receiving compliments is an opportunity to celebrate and recognise success. Say GP will ensure that:

• All compliments are and documented to highlight good practice
• Compliments are anonymised or permission is sought before displaying them
• Numbers of compliments received are logged as part of a quality assurance programme

Say GP will record, monitor, review and analyse all complaints and other feedback received about the service as part of continuous improvement cycle to identify and inform performance, effectiveness, quality, safety and trends. Say GP will investigate or explore what has been received and act on the findings that emerge.

Say GP will:

• Share themes and trends with Dr Semiya Aziz as required
• Carry out and submit complaints reviews to statutory bodies as required
• Review complaints, compliments and other feedback received, together with the outputs and outcomes from the management process, as a standing agenda item at meetings
• Ensure that Dr Semiya Aziz is trained to deal with complaints, compliments, suggestion and feedback and understand the complaints procedure so that they can advise complainants with accuracy