Accessible complaints policy checklist
Document Sample


National Privacy Principles worksheets
NPP Description IPP
NPP 1 and Collection—The service should only collect IPP 1, 2 and 3
10 personal information if that information is
necessary for one or more of its functions or
activities. The service must take reasonable
steps to ensure that the individual is aware of
the fact that he or she is able to gain access
to the information and the purposes for which
the information is collected.
Sensitive information—A service must not
collect sensitive information about an
individual unless they have consented, it is
required by law or it is necessary to prevent
imminent threat to life or health.
Questions:
In the disability employment sector are you allowed to collect information
on the age of the person you are supporting?
Can you collect information on their past behaviour?
Can you collect information on their health situation?
Where could you go to find out more information on unanswered questions
that you have in relation to the collection of information?
What information exactly can you collect?
What would you class as ‘sensitive information’?
What requirements are there when you collect sensitive information?
NPP 2 Use and disclosure—The service must not IPP 10 and 11
use or disclose personal information about an
individual for a purpose other than the
primary purpose of collection unless the
individual has consented to the use or
disclosure.
Questions:
Can you tell a prospective employer or Business Service about a person’s
epilepsy or their past disruptive behaviours if the individual does not
consent?
How might this principle conflict with your Duty of Care obligations?
How could you resolve this?
Case scenarios:
Centrelink rings and asks for information about a jobseeker/worker/service
recipient. What will you do?
A parent rings and asks the whereabouts of their son (your
jobseeker/worker/service recipient). What are your obligations?
The police turn up in your reception area and demand a file that you hold
on one of your jobseeker/worker/service recipients. What should you do?
NPP 3 Data quality—The service must take IPP 8 and 9
reasonable steps to make sure that the
personal information it uses or discloses is
accurate, complete and up to date.
Case scenario
You work for an organisation that has been in existence for 50 years. While
you are looking up one of your jobseeker/worker/service recipient files
regarding employment, you see information dating back 30 years. Much of
the information is irrelevant to employment and in some examples, derisive
and inflammatory about the individual.
What will you do?
What policies and procedures do you have in place to back up what you
intend to do?
NPP 4 Data security—The service must take IPP 4
reasonable steps to protect the personal
information it holds from misuse and loss and
from unauthorised access, modification or
disclosure.
Case scenario
A staff member in your organisation has been so busy that they are not up-
to-date with their information recording in the jobseeker/worker/service
recipient files. One weekend they decide to take the files home to get up-
to-date. The files are in a locked brief case and the home is well secured.
On their way home they stop to pick up a prescription at the chemist, and
the car is stolen along with the locked brief case.
What are the implications to the service?
What are the implications to the individual staff member?
What should be done in this situation?
Can you record file notes or running sheets at home or in your car?
Can you take any financial backup information home in your car?
What are the considerations in transporting jobseeker/worker/service
recipient information via USB or disk?
NPP 5 Openness—The service must set out in a IPP 5, 6 and 7
document, clearly expressed policies on its
management of personal information.
Questions
What training occurs within your organisation regarding Standard 4
(Privacy, dignity and confidentiality) for staff and jobseeker/worker/service
recipients?
How accessible and readable are the policies and procedures relating to this
Standard?
NPP 6 Access and correction—The service must IPP 5, 6 and 7
give individuals access to all personal
information that it holds about them within a
reasonable timeframe of a request.
Reasonable steps should be taken to ensure
all records are accurate, relevant, up-to-date
and not misleading.
Questions:
What are your obligations if a jobseeker/worker/service recipient cannot
read and they ask to see their file?
Do you have a policy and procedure in place for allowing
jobseekers/workers/
service recipients access to their files when requested? What does it require
you to do?
What do you do if you come across information in a file that is inaccurate,
misleading, contains opinions that are disrespectful to the
jobseeker/worker/service recipient?
What should you do with old jobseeker/worker/service recipient information
(e.g. goes back 30 years to when the individual commenced receiving a
service in your organisation)?
What is a reasonable timeframe to provide a jobseeker/worker/service
recipient with access to file information when it has been requested?
NPP 7 Identifiers—An organisation should not
No IPP
adopt, use or disclose an individual’s identifier
that has been assigned by another agency
unless it is necessary to fulfil obligations, or it
is prescribed.
Anonymity—Unless there is a good practical No IPP
or legal reason to require identification,
NPP 8
organisations must give people the option to
remain anonymous. This principle is not
intended to facilitate illegal activity.
Transborder data flows—An organisation
NPP 9 cannot disclose personal information to No IPP
someone in a foreign county that does not
have a comparable privacy scheme, except
where the individual gives consent. It does
not prevent transfers where it is to another
part of the same organisation or to the
individual concerned.
Discuss:
Tool 7.3: Compliments/complaints feedback form
While complaints forms are a handy tool, everyone in your organisation should be
trained to take complaints in any format including verbally or over the phone.
Complaints and compliments forms can be useful but shouldn’t be seen as the
sole tool in your complaints/compliments process. You may also wish to alter the
form to suit your target group, and/or to review the complaints form in Section
4: Complaints and Referrals. You may also consider a suggestion box for people
who wish to provide anonymous feedback.
About you (if you want to make an anonymous complaint or
compliment, go to the next section)
Your details—please only provide the contact details that you are happy for our
staff to use to contact you.
Name: Mr/Mrs/Miss/Ms/Dr
Mailing address:
Postcode:
Email: Mobile number:
Contact phone number during business hours: ( )
Do you have an advocate you would like us to discuss your complaint with?
Yes Name of representative :
Mailing address :
Phone:
Email:
No
Please advise our office as soon as possible if any of your contact details change.
About the respondent (who you are complimenting or complaining
about)
I am complimenting/complaining about:
Have you raised this compliment or complaint before?
If yes—what was the response, if any?
Your compliment or complaint
Please give us details of your compliment or complaint:
Please tell us what you would like to see happen as a result of your compliment or
complaint:
We undertake to respond to your compliment or complaint within one week of
receiving it. If you have raised a complaint, the timeframe for resolving your
complaint is explained in our complaints policy and procedure, which is attached
for your information.
Tool 7.4: Checklist—accessible complaints policy
Accessible complaints policy checklist
Easy English. Policy is explained in easy-to-understand English, with
clear and short sentences, and in other formats appropriate to specific
disability as required (e.g. Braille). If a complex word or term is used,
an easy English definition is also provided.
Responsive and timely. Complaint is handled quickly and timeframes
are short and clear.
Process is clearly explained and easy to follow (e.g. Step 1, Step 2…).
Demonstrated commitment to resolution is in line with the service’s
vision, aims and objectives.
Assistance is offered to jobseeker/worker/service recipients to lodge
complaints.
Follow up. Complainant is kept informed of progress.
There is a good use of pictures that are age-specific and not childlike.
Referral and contact details are provided for external services where
complaint is unresolved or complainant chooses to go elsewhere.
Advocacy and other supports are encouraged throughout the process
and referral details provided if required
Flexible. Complaints can be received in a range of formats including
verbally.
Complainants are encouraged to try and resolve issue at the most
local level (i.e. direct supervisor or co worker).
Policy has a statement about no retribution and that complaints are
welcome, will be taken seriously and will be handled honestly, fairly
and without bias.
Confidential. Privacy of complainant and details of complaint is
maintained. Permission is sought from complainant if it is necessary to
discuss details with other stakeholders.
Other opportunities for feedback, including anonymous feedback, are
encouraged (e.g. suggestion box, focus groups, surveys).
There is a commitment to use information from complaints for service
improvement.
Policy is regularly reviewed and the review date included.
Promotion. Policy is displayed and regular training is provided.
Record keeping. Policy has a statement about keeping all records of
the complaint, including file notes of discussions.
Tool 7.5: Example tracking form for complaint matter
Matter
no:
Name:
Call Date: Time: Staff:
no:
Tool 7.6: Sample Complaints Resolution and Referral Service feedback
form
Feedback Form
- Private and confidential -
As part of CRRS continuous improvement we would like feedback on your
experience with the CRRS. All feedback is greatly appreciated and can be
anonymous.
1. What type of service/support did you receive from the CRRS?
CRRS directed local or internal resolution
Conciliation or facilitated meeting
CRRS investigation
CRRS referral
Continuous improvement
Other_____________________________
2. How well did the CRRS understand and meet your individual needs?
Not at all 1 2 3 4 5 Very well
Comments:
_________________________________________________________________
_________________________________________________________________
3. How satisfied were you with the resolution of the complaint?
Very unsatisfied 1 2 3 4 5 N/A Very
satisfied
Comments:
_________________________________________________________________
_________________________________________________________________
4. How did you find the quality and accessibility of the CRRS materials
and correspondence, such as initial letters, finding reports, brochures,
and meeting documents, for local resolution?
Low quality 1 2 3 4 5 N/A High
quality
Comments:
_________________________________________________________________
_________________________________________________________________
5. How do you rate the fairness and impartiality of the CRRS?
Very unfair/impartial 1 2 3 4 5 N/A Very
fair/impartial
Comments:
_________________________________________________________________
_________________________________________________________________
6. Please rate your overall satisfaction with the CRRS
Very unsatisfied 1 2 3 4 5 Very
satisfied
Comments:
_________________________________________________________________
7. How could the CRRS improve?
Name: _______________________________________________________
Phone:
_______________________________________________________________
The CRRS may be able to use some of your comments to promote the service to
people with disability. I give the CRRS permission to use comments I have made.
Yes No Please sign: _________________________________
Please return feedback sheet in envelope to:
CRRS Locked Bag ‘REPLY PAID’ 2705 Strawberry Hills NSW 2012
or Fax: (02) 9318 1372
Thank you!
Tool 7.7: Sample Complaints Resolution and Referral Service
feedback form – pictorial
Feedback for the CRRS
Date: _________________________
1. What type of service/support did you receive from the CRRS?
CRRS directed local or internal resolution
Conciliation or facilitated meeting
Investigation
Referral
Continuous improvement
Other_____________________________
2. How well did the CRRS listen and understand you?
Very well Well Not sure Not well
Comments:___________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
3. How happy are you with how your complaint was resolved or fixed?
Very happy Happy Not sure Unhappy
Comments:___________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
4. Was the information (letters, permission form) sent to you easy to understand?
Very easy Easy Not sure Not easy
Comments: __________________________________________________
___________________________________________________________
___________________________________________________________
5. How fair did you find the CRRS?
Very fair Fair Not sure Unfair
Comments: ___________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
6. How helpful was the CRRS?
Very helpful Helpful Not sure Unhelpful
Comments: ___________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
7. How could the CRRS do things better?
__________________________________________________________________________
__________________________________________________________________________
__________________________________________________________________________
__________________________________________________________________________
__________________________________________________________________________
__________________________________________________________________________
Name: __________________________________________
Phone: __________________________ _______________
The CRRS may be able to use some of your comments to promote the
service to other people with disability. I give the CRRS permission to use
comments I have made
Yes No Please sign: _________________________________
Please return feedback sheet in envelope to:
CRRS Locked Bag ‘REPLY PAID’ 2705 Strawberry Hills NSW 2012
or Fax: (02) 9318 1372
Thank you!
Tool 8a.1: Better practice corporate governance—checklist1
You can use this checklist to review your organisation’s current features and help
to identify any weaknesses that may require action.
Better practice feature Assessment
Board roles, responsibilities and skills
Are the powers, roles, responsibilities and accountabilities of
the Board, the CEO and management clearly identified?
Are these responsibilities clearly communicated?
Who are they communicated to (e.g. each other, key
stakeholders)?
Is there a good understanding of management’s
responsibilities in relation to internal control?
Is there a sound system of procedural and financial
delegations approved by the Board?
Does it promote efficiency as well as control?
Are appropriate decision-making processes adopted by the
Board?
Is there a clear distinction between what decisions should be
made by the Board and what decisions should be made by
management?
Are decisions that should be made by the Board, clearly
documented and understood?
Are there processes governing policy development,
implementation and review, which ensure that the Board
approves new policy?
Is there a clear separation of roles and
responsibilities between the Board, the CEO and management?
Are appointments made to the Board with regard to the skill
requirements of the Board?
Are there adequate induction processes for new Board
members?
Does the Board have, collectively, a mix of appropriate skills,
knowledge and experience covering:
business acumen/expertise
the industry within which the agency operates
1
This checklist is based on the Corporate Governance handbook for the Board, Department of Family
and Community Services, 2001, available from
http://www.facsia.gov.au/internet/facsinternet.nsf/disabilities/services-
qa_resources_pubs_reports.htm
the services/products being provided by the
organisation
policy development
executive leadership skills
finance
marketing
regulatory environment
legal
vocational training
disabilities.
Independence
Is the majority of the Board independent of the CEO,
management team and commercial dealings with the
organisation?
Are there sufficient numbers on the Board to achieve
independence, but not too many to become inefficient?
Are there appropriate policies and procedures to identify any
potential conflicts of interest?
Are there adequate policies and procedures to deal with
potential conflicts of interest, once identified?
Board meetings
Are regular Board meetings held and are financial reports
tabled?
Board resources
Do Board members have access to independent professional
advice to enable them to discharge their duties?
For companies, is there a company secretary with the primary
role of supporting the Board and chairperson?
Code of conduct
Is there a written code of conduct to be followed by the Board,
CEO and staff?
Is this code of conduct communicated and understood by the
Board, CEO and staff?
Are there clear guidelines in the code of conduct in relation to
conflict of interest?
Strategy setting and planning
Is there an overall organisational plan, and is it supported by a
business plan, budgets and marketing plan (if necessary)?
Are there clearly defined performance measures (operational
and financial) incorporated into the plans?
Does the Board approve the budget set by management,
including any budget revisions ?
Risk management
Is there a risk management plan that is supported by risk
management strategies?
Does the Board regularly review the risk management
strategies?
Are there any procedures for the Board to review the
strategies and assess whether they are working effectively?
Is the risk management plan reviewed regularly to ensure new
risks are identified and risk management strategies are put
into place?
Financial and operational reporting
Are there appropriate performance measures, financial and
non-financial, which enable the efficiency and effectiveness of
the organisation to be
assessed?
Are reports tailored to particular levels of responsibility?
Do reports efficiently and effectively communicate key
financial data?
Are the financial reports prepared on a full accruals basis as
required under the Australian Accounting Standards (a
requirement of the Department of Families, Housing,
Community Services and Indigenous Affairs (FaHCSIA) Service
Agreement)?
Do financial reports show a comparison between year-to-date,
budget, last year-to-date and full-year data?
Are financial reports supported by explanations of significant
variations?
Are financial reports provided to the Board at least quarterly?
Are financial reports provided to the CEO at least monthly?
Are financial reports derived directly from the underlying
accounting systems and is there a quality assurance process
over the compilation of the reports?
Do adequate accounting systems and records support financial
reports?
Are financial reports provided to the Board in sufficient time to
enable review before meetings?
Do members of the management team brief the Board when
financial reports are tabled?
Does the management team include a person with appropriate
financial management expertise and experience?
Does that person have a direct reporting line to the Board?
Board performance
Are there mechanisms to monitor performance of the Board
and individual Board members?
Audit committee—for larger organisations
Is there an audit committee?
Is there a charter for the audit
committee covering such responsibilities
as:
management and financial
reporting
compliance with laws and
regulations
maintenance of an effective audit
function
suitable risk management and
internal control
frameworks
membership
frequency of meetings
committee authority
Board reporting obligations.
Does the audit committee include a
majority of independent (non-Executive)
Board members?
Do members of the audit committee
have adequate financial and accounting
expertise?
Does the audit committee have
unlimited access to internal and external
auditors and to senior management?
Does the audit committee have direct
access to the Chief Executive Officer,
Chief Financial Officer and external
auditor and internal audit?
Does the audit committee meet at least
quarterly?
Does the audit committee review the
status of all internal audit and external
audit recommendations and their
implementation?
Do status reports summarise
recommendations, officers responsible
and implementation dates?
Does the audit committee approve and
monitor policies for risk management,
reporting and internal control?
Statutory accountability
Is there a process that identifies all
legislation relevant to the organisation,
and monitors changes to the legislation
and new legislation impacting on the
organisation?
Does financial and management
reporting encompass reporting on critical
legislative compliance obligations?
Does the Board fully understand and
continually assess its contractual
requirements under the terms and
conditions of service agreements with
key
stakeholders, including the Department
of Families, Housing, Community
Services and Indigenous Affairs
(FaHCSIA) and the Department of
Education, Employment and Workplace
Relations (DEEWR).
Tool 8b.2: Internal audit worksheets
You can print out these internal audit worksheets and use them as templates to
plan and document continuous improvement activities for your organisation under
each KPI of the Disability Services Standards.
You may wish to distribute them among staff, management and
jobseekers/workers/service recipients. This task could be shared out, with
individuals or work groups taking on the internal audit of specific Standards.
You may wish to attach an extra page if you need more space for your response.
It is important to think about documenting evidence of your actions towards each
KPI. You may wish to refer to the name and/or number/date of relevant policies
and procedures, or append copies of these policies and procedures to your
worksheets, which could then be provided to your certification body. Evidence
should be in the form of actual outcomes and achievements.
Internal audit worksheet p. 1
Standard:
KPI:
What are our planned actions for Policies, procedures and management systems
meeting the requirements of this KPI?
What improvements have we tried or Things tried or done Key learning/insights
made in the past 12 months? in the past 12 months
What are our claims about our current Strengths (what we Weaknesses (areas to
performance in this area? do well) improve)
Do we comply with the requirements Evidence that Areas where we need
of this KPI? demonstrates our additional evidence or
compliance changes to our
management systems
What are our priorities for continuous Planned actions Anticipated results
improvement over the next 12
months?
Internal audit worksheet p. 2
Standard:
KPI:
Using the activity of the previous page, document the continuous improvement
actions your organisation plans to take in relation to this KPI. Use the column
during your regular review process to document when actions have been
completed.
Action to be taken Person responsible Timeline for action
Tool 8b.3: Sample process for developing a quality network
You can use this process in your organisation to document your planning towards
developing a quality network.
[Developed with the assistance of The Ascent Group, NSW]
1. Determine the type of quality network that you want
For example, what do we want to achieve? Do we want to:
work on developing a quality management system?
address quality assurance issues?
work with organisations with a similar work output etc?
Goals:
2. Identify potential organisations
Identify organisations that you would like to develop a quality network with.
Name: Contact information:
If you do not know any appropriate organisations to develop a network with,
contact:
Department of Families, Housing, Community Services and Indigenous
Affairs (FaHCSIA):
<www.facsia.gov.au/internet/facsinternet.nsf/disabilities/services-
nav.htm>
ACE National Network: <www.acenational.org.au>
NDS (National Disability Services): <www.nds.org.au>
3. Decide on a structure
For example, will the quality network be:
action based?
for information sharing?
for resource sharing?
Structure:
4. Set up the network
Here are some key elements to consider when developing a meeting system,
with examples of what you might choose to do.
Where: (For example, choose a mutually convenient venue, or if the
organisations in your network operate near one another, each service could take
a turn hosting the meeting at their premises.)
When: (For example, meet once every month for one day, or 4–5 hours,
allowing for travel time.)
Who is responsible: (For example, have each organisation in turn be
responsible for running the meeting and appointing a chairperson.)
What will be done at each meeting:
(For example, for a quality network focusing on the Disability Services
Standards, >you could:
Have each monthly meeting focus on a particular Disability Services
Standard. In this way, you will have achieved a complete review of the
Standards within a calendar year.
Identify which Standard will be discussed at the meeting. Request that all
attendees bring material for discussion relating to that Standard, such as
queries, barriers, obstacles, best practice examples and ideas for
evidence gathering. Request the chairperson of the meeting (or another
member of their organisation) to research and prepare an overview of the
Standard to present to the group.)
5. Conduct your meetings
(For example, for a quality network focusing on the Disability Services
Standards:
a. Chairperson presents an overview of the Standard to the group.
b. Group members discuss and share their practices and experiences
relating to this Standard.
c. Group members work through any tools or resources relating to the
Standard that services may have. One possible tool could be the FaCSIA
Disability Services Standards Workshops, which are available online at
<www.facsia.gov.au>.
d. Identify any gaps in knowledge in the group. You may wish to seek
outside help (for instance, a guest speaker, consultant or trainer) to help
your network develop in this particular area.
If organisations in your network have gone through Quality Assurance
certification before, you could invite them to come to one of your meetings
and present on their experience of the certification system.)
Agreed meeting structure:
6. Develop the network
Review the progress of your network to adapt to changes in the aims and goals
of network organisations. The focus of your network should change to reflect
new directions and changing needs. See the case study 8b.1 on p.246 for an
example of development and change in a quality network.
Document future directions:
Tool 9.1: Checklist—Wage Assessment tool for Business Services2
You can use this checklist to ensure that your organisation uses a fair and
transparent tool when assessing the wages of workers. In addition, after May
2008, all business services must be paying wages in accordance with tools
mandated by the Australian Fair Pay Commission. Failure to do so may result in
prosecution.
Indicator Yes No Comment
Key components of a good assessment tool
Does the tool comply with relevant legislation and standards? Essential
The Disability Services Act
Disability Services Standard
The Disability Discrimination Act
The Workplace Relations Act
Is the tool valid? Essential
Does it assess what it claims to be assessing?
Does it differentiate between individuals of different
work capacity?
Does the tool cover all relevant elements of productivity
and/or competency?
Is the tool reliable? Essential
Would different assessors achieve the same result when
assessing the same person (inter-rater)?
Would the same assessor achieve the same result for
similar situations or for the same person at different
times (intra-rater)?
Are there sound links to training and professional development? Essential
Does appropriate planning and administration support the tool? Essential
Are the assessors appropriately qualified and objective? Essential
Are assessors qualified in workplace assessment?
If assessors are internal, how does the service ensure
independence and transparency?
Is there clear documentation of the nature and method of Essential
assessment?
Does the assessment methodology articulate the type of work Essential
and jobs employees actually do?
Can employees confirm they do the jobs they are being assessed
against?
Is the formal Wage Assessment process based on consideration Desirable
of a training plan or policy?
2
FaHCSIA, Wage Assessment Tool Checklist
http://www.facsia.gov.au/internet/facsinternet.nsf/disabilities/services-
qa_resources_pubs_reports.htm
Is the wage outcome linked to an award or industry standard for Essential
the type of work undertaken?
Does the wage outcome reflect the capacity of the employee to Essential
complete the tasks constituting their job?
Does the wage outcome take the employees supplementary skills Essential
into account?
Is there a process in place to ensure that employees and Essential
advocates are fully aware of the way in which wages are
determined?
Does the assessment methodology provide for advocate Essential
participation, independent review and the right for employees to
raise disputes?
Is the tool productivity-based?
example includes Supported Wage Assessment tool
(SWAT)
Is the assessment process formalised? Essential
Is the assessment process objective? Essential
Are the assessors qualified in workplace assessment? Essential
How are the benchmarks set? Essential
How is output of employees measured against an
established benchmark (eg non disabled co-worker or
supervisor)?
Do employees and advocates understand the assessment Essential
process?
How often are assessments undertaken? Essential
What are the monitoring and review processes?
Is the assessment outcome linked to an Australian Pay Essential
Classification Scale?
Does the assessment produce a fair outcome? Essential
Is there an appeals/complaints mechanism? Essential
Is the tool competency-based?
How are employees assessed in accordance with industry
determined competencies?
How are competencies linked to identifying training
needs?
Does the assessed level of competency align to the wage Essential
outcome?
Does the tool assess both competency and productivity?
(commonly known as a hybrid tool)
Are there competencies from the relevant national industry- Essential
training package?
Is there a link between the assessment and training? Desirable
Tool 10.1: Competency-based job description template
You can use the fields in this template to document the skills, knowledge and
attributes required by the jobseeker/worker to fulfil their employment role. Link
this document to the training needs analysis form provided at Tool 10.2, p.317.
Name
Job title
Background
Key responsibilities
Job Skills, Knowledge and Attitudes
Skills Knowledge Attitudes/Attributes/Aptitudes
Must do Must know Must be aware of
Tool 10.2: Training needs analysis template
You can use the fields from the competency-based job description template at
Tool 10.1, p.316 to fill out this training needs analysis template, and record
where the jobseeker/worker requires further training.
Skills Yes No TNA
Knowledge
Attitudes
TRAINING NEEDS ANALYSIS
Summary
requires the following training in order to competently perform his/her job:
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