Complaints policy
1. Purpose
This policy explains how a person can raise a concern or complaint about SSAH services, conduct, fees, privacy or another aspect of the practice, and how SSAH receives, investigates, resolves, records and learns from complaints.
2. Scope
This policy applies to complaints made by clients, representatives, families, carers, advocates, referrers, employees, contractors and other stakeholders. A complaint may be made verbally, in writing, anonymously or through a representative.
3. Principles
Accessible. SSAH will provide communication support, reasonable adjustments and assistance to make a complaint where needed.
Respectful and trauma-informed. The person's dignity, safety, culture, identity and preferred communication are considered.
No retaliation. A good-faith complaint will not adversely affect access to services, fees or treatment.
Confidential. Information is shared only with people who need it to assess, respond, meet legal duties or manage risk.
Fair. The complainant and any person whose conduct is questioned have a reasonable opportunity to provide relevant information.
Timely and accountable. Complaints are acknowledged, triaged, investigated proportionately and concluded with reasons and actions where appropriate.
4. Definitions
Complaint: an expression of dissatisfaction about SSAH, a service, decision, action, omission, worker, contractor or privacy practice where a response or resolution is expected.
Feedback: a comment, compliment, concern or suggestion that may not require a formal investigation.
Complainant: the person making the complaint, including an authorised representative or advocate.
5. Legal, ethical and professional framework
SSAH applies this policy consistently with the following requirements, where relevant:
Privacy Act 1988 (Cth) and the Australian Privacy Principles.
Health Complaints Act 2016 (Vic) and the General Code of Conduct for general health service providers.
National Disability Insurance Scheme Act 2013 (Cth), the NDIS Code of Conduct and the National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018, where applicable.
Australian Human Rights Commission Act 1986 (Cth) and applicable anti-discrimination law.
AASW Code of Ethics 2020 and current AASW Practice Standards.
6. How to make a complaint
A person may raise a complaint directly with the clinician or contact the Complaints Officer / Director, SSAH:
by post: Social Sense Allied Health, PO Box 212, Brunswick VIC 3056;
by email: hello@socialsense.com.au; or
by telephone or text: 0435 005 669.
The person may use an advocate, support person or interpreter, request a reasonable adjustment, or make a complaint anonymously. Anonymous complaints will be assessed, although anonymity may limit investigation or response.
7. Receipt, triage and acknowledgement
SSAH will acknowledge a complaint within five business days. Immediate safety, abuse, neglect, violence, privacy, reportable incident, safeguarding or other urgent risks will be triaged and acted on without waiting for the ordinary process.
SSAH will confirm the issues, desired outcome, preferred communication method, any support needs and whether another body must be notified. The complainant will receive progress updates if the matter cannot be resolved promptly.
8. Assessment and investigation
Identify the issues, relevant policies, people, records, legal duties and conflicts of interest.
Assign a person with sufficient independence and authority. If the complaint concerns the Director, SSAH will use an appropriate external adviser, insurer, mediator or regulator pathway.
Gather and securely retain relevant information, while limiting disclosure to what is reasonably necessary.
Give affected parties a fair opportunity to respond to adverse information, subject to safety and legal constraints.
Assess the evidence proportionately and identify findings, risks, corrective actions and service improvements.
Communicate the outcome in accessible language, including reasons, actions that can be disclosed, and internal or external review options.
9. Outcomes and remedies
Depending on the complaint, an outcome may include an explanation, apology, correction, refund or account adjustment, service change, referral, additional support, supervision, training, policy improvement, disciplinary action, incident notification or another proportionate remedy. Privacy complaints are also managed under the Privacy Policy.
10. External escalation
A person may contact an external body at any time and does not need to complete SSAH's process first. Relevant options include:
Australian Association of Social Workers: complaint form and Ethics Office, 03 9320 1000, where the social worker is an AASW member;
Health Complaints Commissioner Victoria: 1300 582 113;
NSW Health Care Complaints Commission: 1800 043 159;
NDIS Quality and Safeguards Commission: online complaint form or 1800 035 544 for NDIS supports and services;
Services Australia Complaints and Feedback: online through myGov or 1800 132 468 for Medicare-related administration;
NSW Department of Communities and Justice complaints and feedback, or Victims Access Line on 1800 633 063 for Victims Services matters; and
Office of the Australian Information Commissioner for unresolved privacy complaints.
11. Records, privacy and continuous improvement
SSAH keeps a confidential complaint record containing the issues, communications, evidence, assessment, outcome and actions. Complaint information is retained and disclosed in accordance with privacy, health-record, funding, insurance and legal obligations.
The Director, SSAH reviews complaint themes, timeliness, outcomes and corrective actions to identify systemic risks and opportunities for continuous improvement. This policy is reviewed at least annually.
References
Health Complaints Act 2016 (Vic). https://www.legislation.vic.gov.au/in-force/acts/health-complaints-act-2016
Health Complaints Commissioner Victoria. General Code of Conduct for general health service providers. https://hcc.vic.gov.au/providers/general-health-service-providers-code-conduct
National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018. https://www.legislation.gov.au/F2018L00634/latest
NDIS Quality and Safeguards Commission. Report an issue or make a complaint. https://www.ndiscommission.gov.au/complaints/report
Australian Association of Social Workers. Making a complaint. https://www.aasw.asn.au/about-aasw/ethics-standards/making-a-complaint/
Office of the Australian Information Commissioner. Lodge a privacy complaint with us. https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us
Document contact
For questions or concerns about feedback or the complaints process, contact the Director, SSAH on 0435 005 669 or hello@socialsense.com.au. Correspondence may also be sent to PO Box 212, Brunswick VIC 3056.