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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Complaints Handling Policy

1. Purpose

The purpose of this policy is to set out how {{org_field_name}} receives, records, investigates, responds to and learns from complaints raised about its recruitment, staffing and employment business activities in England. {{org_field_name}} is committed to handling complaints promptly, fairly, consistently, confidentially and without retaliation.

This policy supports compliance, where applicable, with the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (as amended), the Agency Workers Regulations 2010, the Employment Rights Act 1996, the Equality Act 2010, the Working Time Regulations 1998, the National Minimum Wage legislation, the Immigration, Asylum and Nationality Act 2006, the Health and Safety at Work etc. Act 1974, the UK General Data Protection Regulation and the Data Protection Act 2018.

2. Scope

This policy applies to complaints raised by or on behalf of:

• job applicants, candidates and work-seekers;
• temporary workers, agency workers and employees of {{org_field_name}};
• clients and hirers;
• former workers or former candidates;
• family members, representatives or advocates where appropriate; and
• regulators, commissioners, local authorities, contractors and other stakeholders.

Complaints may relate to, without limitation:

• recruitment processes, matching, introductions or assignment arrangements;
• suitability checks, onboarding, right to work checks or references;
• pay, holiday pay, deductions, timesheets or other pay-related concerns;
• equal treatment rights, access to facilities, vacancy information or other Agency Workers Regulations issues;
• discrimination, harassment, victimisation or failure to make reasonable adjustments;
• conduct of staff, workers or representatives of {{org_field_name}};
• health and safety concerns arising during recruitment, placement or assignment;
• data protection, confidentiality or records handling;
• safeguarding concerns identified during recruitment or assignment activity;
• alleged breaches of law, contract, policy or regulatory requirements; and
• the way a previous complaint was handled.

This policy does not replace separate procedures for subject access requests, whistleblowing disclosures, disciplinary matters, safeguarding referrals, or statutory reporting obligations. Where a concern falls more appropriately under another policy or legal process, {{org_field_name}} may redirect the matter while ensuring the person raising the concern is informed of the correct route.

3. Definitions

For the purposes of this policy:

• Complaint means any expression of dissatisfaction, whether justified or not, about the services, conduct, decisions, omissions, recruitment activity, assignment arrangements or complaint handling of {{org_field_name}}.
• Complainant means the person raising the complaint or their authorised representative.
• Worker / Agency Worker / Temporary Worker shall be interpreted in accordance with the relevant legal and contractual context.
• Client / Hirer means the organisation to which a worker is introduced or supplied.
• Working day means Monday to Friday excluding public holidays in England.

4. Principles of Complaint Handling

{{org_field_name}} is committed to the following principles:

• Accessibility: complaints may be raised verbally, in writing, by email, by telephone, and in any reasonable alternative format requested by the complainant.
• Reasonable Adjustments: where a complainant is disabled or otherwise needs support to use this procedure, {{org_field_name}} will make reasonable adjustments to remove barriers to access, including providing information in an accessible format or allowing support from a representative where appropriate.
• Fairness and Impartiality: complaints will be handled objectively, proportionately and, where possible, by a person who is not the subject of the complaint.
• Confidentiality: information will be shared only with those who need it for investigation, safeguarding, legal compliance or resolution.
• Timeliness: complaints will be acknowledged and progressed without unnecessary delay, and complainants will be kept informed if more time is required.
• No Retaliation: no person will be disadvantaged, penalised or treated unfavourably for raising a complaint in good faith. Complaints involving discrimination, harassment, victimisation, whistleblowing or safeguarding will be handled with particular care.
• Resolution Focus: {{org_field_name}} will seek early and proportionate resolution where possible, while still investigating serious concerns fully.
• Learning and Improvement: complaint outcomes, themes and trends will be reviewed so that services, recruitment practice and compliance controls can be improved.

5. How to Make a Complaint

Complaints can be made in the following ways:

• Verbally: In-person or over the phone by contacting {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} at {{org_field_registered_manager_phone}}.
• In Writing: By submitting a letter to {{org_field_name}}’s office.
• By Email: Sent to {{org_field_registered_manager_email}}.
• Via Feedback Forms: Available at our offices and online.

A complainant should, where possible, provide:

• their name and contact details;
• the name of any worker, consultant, client, branch or department involved;
• a description of the issue, including relevant dates, assignments or vacancies;
• any documents or evidence they wish {{org_field_name}} to consider; and
• the outcome they are seeking.

Anonymous complaints may be considered where sufficient information is provided, although this may limit the extent to which {{org_field_name}} can investigate or give feedback on the outcome.

If the complaint raises immediate safeguarding, criminal, serious health and safety, modern slavery or illegal working concerns, {{org_field_name}} may take urgent protective action and notify the appropriate authority without waiting for the full complaints process to conclude.

6. Complaints Handling Process

6.1 Receipt and Logging

All complaints must be recorded in the complaints register on receipt, assigned a unique reference number, dated, risk-assessed and categorised according to subject matter, for example pay, conduct, discrimination, safeguarding, health and safety, data protection or compliance.

6.2 Acknowledgement

{{org_field_name}} will normally acknowledge a complaint within 2 working days of receipt. The acknowledgement will confirm, where possible:

• the complaint reference number;
• the issues understood to be in scope;
• the person handling the complaint;
• whether any urgent protective or escalation action is being taken; and
• the expected next steps and target timescale.

6.3 Initial Risk Assessment and Escalation

On receipt, the complaint handler must consider whether the matter raises immediate concerns relating to safeguarding, discrimination, harassment, victimisation, modern slavery, illegal working, serious health and safety risk, serious payroll error, data breach, or potential criminal conduct. Where necessary, the matter must be escalated immediately to the appropriate internal lead, senior management, the client/hirer, the police, the local authority, the Information Commissioner’s Office, the Health and Safety Executive or another relevant body.

6.4 Investigation

A proportionate investigation will be carried out. This may include reviewing recruitment records, assignment records, pay records, right to work checks, communications, timesheets, policies, CCTV where lawfully available, witness accounts and any evidence supplied by the complainant or third parties.

The investigator will act impartially. Where the complaint concerns the person who would usually investigate, the matter must be reassigned to an appropriate alternative manager or director.

6.5 Meetings and Representation

Where appropriate, {{org_field_name}} may invite the complainant to a meeting or call to clarify the issues. Employees and workers raising workplace grievances may be accompanied at formal meetings in line with applicable law, the Acas Code and internal procedure.

6.6 Outcome

{{org_field_name}} will normally provide a written outcome within 20 working days of acknowledgement. Where this is not reasonably possible, the complainant will be informed of the reason for delay, the action taken so far, and the revised expected timescale.

The written outcome will usually set out:

• the issues investigated;
• the evidence considered;
• the findings reached;
• whether the complaint is upheld, partially upheld or not upheld;
• any remedial steps, apology, correction, training, monitoring, referral or other action proposed; and
• how to request a review or appeal.

6.7 Resolution and Remedies

Depending on the findings, {{org_field_name}} may take one or more of the following actions:

• apologise and explain what went wrong;
• correct records or rectify administrative errors;
• address payroll issues, holiday pay or deductions where appropriate;
• review assignment arrangements or candidate handling;
• implement training, supervision, process improvement or disciplinary action;
• make a safeguarding, regulatory or statutory report where required;
• agree reasonable adjustments or practical measures to prevent recurrence; or
• confirm why no further action will be taken.

Nothing in this policy prevents a complainant from seeking advice, pursuing statutory rights, notifying a regulator or, where applicable, commencing Acas Early Conciliation or other legal action.

7. Escalation of Complaints

7.1 Internal Review

If the complainant is dissatisfied with the outcome, they may request an internal review in writing within 10 working days of the outcome letter, stating the reasons for dissatisfaction and any new evidence relied upon.

The review will, where possible, be undertaken by a person more senior than the original decision-maker or by a person not previously involved. A final written review outcome will normally be issued within 20 working days.

7.2 External Escalation Routes

Depending on the nature of the complaint, complainants may also contact the appropriate external body. This policy does not remove any statutory right to do so at any stage.

Complaints about recruitment agency / employment business compliance:

Employment Agency Standards Inspectorate (EAS)
EAS is the government regulator for private recruitment agencies in England, Scotland and Wales. Complaints can be made via the GOV.UK online form, by email to eas@businessandtrade.gov.uk, by telephone on 020 4566 5333, or via the Acas helpline on 0300 123 1100.

Agency Workers Regulations 2010 equal treatment complaints:

Where the issue concerns equal treatment under the Agency Workers Regulations 2010, including day-one rights or 12-week equal treatment rights, the complainant should seek advice from Acas and may have rights to pursue the matter through the appropriate legal route. EAS states that it does not investigate complaints that relate to AWR equal treatment claims.

Data protection complaints:

A person who is dissatisfied with how {{org_field_name}} has handled personal data may first complain to {{org_field_name}} using this policy and may then complain to the Information Commissioner’s Office (ICO).

Health and safety concerns:

Serious health and safety concerns may be reported internally and, where appropriate, to the relevant client/hirer and to the Health and Safety Executive (HSE).

Safeguarding concerns:

Safeguarding concerns should be escalated immediately in accordance with the Safeguarding Policy and may be referred to the relevant local authority safeguarding team, the police or other appropriate agency.

Whistleblowing / public interest concerns:

Concerns amounting to whistleblowing should be raised under the Whistleblowing Policy. {{org_field_name}} will not subject any person to detriment for raising a protected disclosure in good faith.

8. Special Categories of Complaint

Where a complaint includes any allegation of safeguarding risk, abuse, neglect, exploitation, discrimination, harassment, victimisation, whistleblowing, serious health and safety risk, data breach, modern slavery, illegal working, fraud or criminal conduct, {{org_field_name}} may:

• bypass some standard complaint stages in order to take urgent protective action;
• refer the matter immediately to the appropriate senior lead, client, regulator or authority;
• investigate under another internal policy where that is more appropriate; and
• limit the detail shared with the complainant where necessary to protect confidentiality, legal privilege, safeguarding or another ongoing investigation.

The use of this policy does not prevent {{org_field_name}} from complying with any immediate safeguarding, legal or regulatory duty.

9. Responsibilities

Directors

Directors and senior managers are responsible for ensuring that {{org_field_name}} has an effective complaints system, that serious risks are escalated promptly, and that lessons learned are implemented.

Complaints Lead

The Complaints Lead is responsible for acknowledging, logging, risk-assessing, coordinating and monitoring complaints, appointing an appropriate investigator, communicating with the complainant and maintaining the complaints register.

Investigating Manager

The Investigating Manager is responsible for carrying out a fair, proportionate and evidence-based investigation, documenting findings and recommending appropriate action.

Data Protection Officer / Privacy Lead

Where a complaint involves personal data, confidentiality, records handling or a potential personal data breach, the matter must be referred promptly to the Data Protection Officer.

All Staff, Workers and Representatives

All staff, workers and representatives of {{org_field_name}} must cooperate with complaint investigations, preserve relevant evidence, maintain confidentiality, refrain from retaliation and comply with any improvement actions arising from complaint outcomes.

10. Learning from Complaints

All complaints, outcomes, actions and themes will be recorded and reviewed periodically by senior management to identify patterns, recurring risks and opportunities for improvement.

Where appropriate, {{org_field_name}} will:

• update policies, procedures, templates or contractual documentation;
• improve recruitment, onboarding, pay or assignment processes;
• provide additional training, supervision or audits;
• improve communication with candidates, workers and clients; and
• review whether safeguarding, data protection, equality or health and safety controls remain effective.

Serious complaints and repeated themes will be escalated to directors for oversight and action tracking.

11. Confidentiality & Data Protection

{{org_field_name}} will process personal data connected with complaints in accordance with the UK GDPR, the Data Protection Act 2018 and its Data Protection and Records Management policies.

Complaint information will be:

• used only for legitimate complaint handling, safeguarding, legal, regulatory, insurance, audit or employment-related purposes;
• accessible only to those who need the information to investigate, decide or act;
• stored securely and protected against unauthorised access, loss, misuse or disclosure; and
• retained in accordance with the organisation’s retention schedule and legal obligations.

12. Record Keeping

{{org_field_name}} will maintain a complaints register containing, as appropriate:

• complaint reference number;
• date received;
• complainant details;
• subject category;
• persons involved;
• risk rating;
• actions taken;
• outcome;
• date closed; and
• lessons learned / follow-up actions.

Records must be accurate, contemporaneous and retained securely in accordance with the organisation’s retention policy and legal obligations.

13. Related Policies

This policy should be read together with, where applicable:

• Recruitment and Selection Policy
• Safer Recruitment / Vetting Policy
• Safeguarding Policy
• Whistleblowing Policy
• Equality, Diversity and Inclusion Policy
• Anti-Harassment and Bullying Policy
• Agency Worker / Temporary Worker Terms
• Client Terms of Business
• Right to Work Check Procedure
• Data Protection and Privacy Policy
• Records Retention Policy
• Pay, Timesheets and Holiday Pay Procedure
• Health and Safety Policy
• Disciplinary Policy
• Grievance Policy

14. Policy Review

This policy will be reviewed at least annually and sooner if required by changes to legislation, regulatory guidance, case law, business model, complaint trends or operational learning.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.