This Village provides an effective service to those who wish to make a complaint to or about the Cotswolds Village.   Complaints can arise because of alleged service failures, relevant information not being readily available or being difficult to understand.   Complaints may also arise from incomplete or misleading information or things that do not appropriately address common concerns or frequently asked questions. Complaints or conflicts may also arise if one parties view differ from another, without one of the parties being willing to take a conciliatory view. Complaints or conflicts may also arise if there is a disagreement with the mode of operation of the management of the Village.

Complaints and compliments are best viewed as a positive interaction with relevant stakeholders.

Benefits of handling complaints well

Good complaint handling may provide Management and staff with knowledge which can be used to:

  • Improve products and services available or offered
  • Foster good relationships with our residents
  • Improve our bottom line in certain circumstances
  • Enable management and staff to resolve issues fairly and efficiently

Poor complaint handling can cost the Village by:

  • Poor or tarnished reputational damage
  • Direct financial expense in relation to the complaint and possible delays to its successful resolution
  • Low staff morale and a demoralising workgroup as a result of repeated complainant action

Consider the following:

  • Consider whether it is possible to resolve a complaint informally by talking to the individual and providing an explanation regarding the approach taken by the organisation.
  • Are the same issues raised repeatedly?


1.    Introduction

1.1    Purpose

This policy is intended to ensure that we handle complaints fairly, efficiently and effectively.

This policy provides guidance on the key principles and concepts of our complaint management system and its application at The Cotswolds Village.

1.2    Scope

This policy applies to all staff, our Board of Management and Trustee, receiving or managing complaints from residents made to or about us, regarding our services and staff, or our complaint handling process. The scope of this policy is extended equally to the resolution of a dispute between two residents or between a resident and the operator.  The Cotswolds Village is a non-government funded retirement village that was established in 1983 and has enjoyed a sense of community amongst its residents.  We operate with a low staff to resident ratio and there may be times when complaints cannot be responded to promptly.

Our reception staff will be able to assist with many routine or informal operational matters. Other organisational or operational complaints or formal complaints should be referred to the General Manager for resolution.  If that office is not able to resolve the issue, the matter will be referred to the Board of Management for consideration.  If the matter cannot be resolved, it will be referred to the Trustee for consideration.

1.3    Organisational commitment

The Cotswolds Village expects staff at all levels to be committed to fair and effective complaint handling. The following table outlines the nature of the commitment expected from staff and the way that commitment should be implemented.



Promote a culture that values the resolution of complaints.The Trustee will:-
- be advised of matters that remain unresolved
- provide support to staff responsible for handling complaints.
- review reports regarding complaint trends. Assess the origin of of the complaint. Are they from the same source? Is there a to trepetitive nature to the complaint?

Consider all matters raised and respond as appropriate.

May in its own discretion seek external advice to assist its ability to resolve disputes.
(as ex-officio member of the Board of Management and Trustee Representative.)
Where possible resolve matters continuing to escalate and that remain unresolved.Treat people with respect, including people who make complaints.
Comply with our agreed policy and associated procedures.

Provide regular feedback to the Board of Management and/or the Trustee on matters arising from complaints.

Consider changes arising from individual complaints and from the analysis of complaint data.

If it is of the opinion that the complainant falls into the unreasonable complainant category of repeated or vexatious correspondence then that will be referred to the Trustee.

Complaints received that are vexatious, litigious or repetitive will be acknowledged but will not continually responded to.
ALL VILLAGE STAFFUnderstand and comply with our complaint handling practices.Treat all people with respect, including people who make complaints.

Be aware of our complaint handling policies and procedures.

Be aware that complaints involving service delivery can be resolved speedily by communicating with the provider.

All complaints are to be referred to the General Manager.

2.   Terms and Definitions


An expression of dissatisfaction made to or about us, our services, staff or the handling of a complaint where a response or resolution is explicitly or implicitly expected or legally required. (AS/NZ 10002:2014)

Complaint handling / management system

All policies, procedures, practices, staff, hardware and software used by us in the management of complaints.


An unresolved complaint escalated either within or outside of our organisation.


Opinions, comments and expressions of interest or concern, made directly or indirectly, explicitly or implicitly, to or about us, about our services or complaint handling system where a response is not explicitly or implicitly expected or legally required.


A clear, formal written statement by an individual staff member about another staff member or a work-related problem.


A statement of instruction that sets out how we should fulfil our vision.


A statement or instruction that sets out how our policies will be implemented and by whom.

3.   Guiding principles

An effective complaint handling system must be modelled on the principles of fairness, accessibility, responsiveness, efficiency and integration into the culture of our organisation, with the underlying principle that supports the best interests of all residents.

3.1   Facilitate complaints

People focus

We are committed to seeking and receiving feedback, either positive or negative about our services, practices and  procedures.

Any concerns raised in feedback or complaints will be dealt with within a reasonable time frame.

People making complaints will be:

  • provided with information about our complaint handling process and how to access it
  • listened to and treated with respect and fairness
  • accordingly our staff and administration wish to be treated in an equally professional and respectful manner
  • the resident body will be provided with reasons for our decision/s.

 No detriment to people making complaints

We will take all reasonable steps to ensure that people making complaints are not adversely affected because a complaint has been made by them or on their behalf.

Anonymous complaints

We accept anonymous complaints if there is a compelling reason to do so and will carry out a confidential investigation of the issues raised where there is enough information provided.


We will ensure that information about how and where complaints may be made to or about us is well publicised and on our website. We will ensure that our system to manage complaints are easily understood.

If a person needs another person or organisation to assist or represent them in the making and/ or resolution of their complaint, we will communicate with them through their representative.  Anyone may represent a person wishing to make a complaint with their consent (e.g. family member, legal  representative, member of Parliament, another organisation).

3.2   Respond to complaints

Early resolution

Where possible, complaints will be resolved at first contact.


We will acknowledge receipt of complaints within 5 working days.

We will assess and prioritise complaints in accordance with the urgency and/or seriousness of the issues raised. If a matter concerns an immediate risk to safety or security the response will be immediate and will be escalated appropriately.

We are committed to managing people’s expectations, and will inform them as soon as possible,
of the following:

  • the expected time frames for our actions
  • the progress of the complaint
  • the possible outcome of their complaint.

Objectivity and fairness

We will address each complaint in an equitable, objective manner.

We will ensure that the person handling a complaint is different from any staff member whose conduct or service is being complained about.

Conflicts of interest, whether actual or perceived, will be considered

Responding flexibly

Our staff aim to resolve complaints promptly and with as little formality as possible. We will adopt flexible approaches to problem solving to enhance accessibility for people making complaints.

We will assess each complaint on its merits and after review and assessment by Management, Board and Trustee. The time frame applied will likely see the matter resolved and concluded within a 60-day period.


We will protect the identity of people making complaints where this is practical and appropriate.

Personal information that identifies individuals will only be disclosed or used by us as permitted under relevant privacy laws, and any relevant confidentiality obligations.

3.3   Manage the parties to a complaint

Complaints involving multiple parties.

Where a complaint involves multiple organisations, we will work with those organisations/ where possible, to ensure that communication with the person making a complaint and/or their representative is clear.

Subject to privacy and confidentiality considerations, communication and information sharing between the parties will also be organised to facilitate a timely response to the complaint.

Where our services are contracted out, we expect our  contracted service providers to have a comprehensive complaint management system. We acknowledge complaints not only about the actions of our staff but also the actions of our service providers.

Empowerment of staff

Our staff are empowered to implement our complaint management system as relevant  and appropriate to their role and responsibilities, within the Cotswolds Village.

Managing unreasonable conduct by people making complaints

We are committed to being approachable and responsive to all people, with feedback or complaints. At the same time we are dependent on:

  • our ability to do our work and perform our functions in the most effective and efficient way possible, given our responsibility for a large number of residents
  • the health, safety and security of our staff, and
  • our ability to allocate the limited resources of our organisation.
  • when people behave unreasonably in their dealings with us, their conduct can significantly affect the progress and efficiency of our work. As a result, we will take proactive and decisive action to manage any conduct that negatively and unreasonably affects us and will support our staff to do the same in accordance with this policy.

Complaints that are regarded as unreasonable, repetitive, vexatious, litigious or are regarded as unreasonable in expectations will be treated appropriately.

Alternative avenues for dealing with complaints

We will inform people who make complaints to or about us about any internal or external review options available to them (including any relevant oversight regulatory body).

The three levels of complaint handling

complaint handling process

Level 1

We aim to resolve complaints at the first level. All staff, including the General Manager take pride in their ability to solve complaints and will respond as appropriate to resolve any matter.

Level 2

Where this is not possible, we may decide to escalate the complaint to the next level which would see the complaint referred to the Board of Management via the General Manager for consideration and review. This second level of complaint handling will provide for the following internal mechanisms:

  • assessment and possible investigation of the complaint and decision/s previously made
  • consideration of all matters raised by the complainant including a review of:-
  1. what is the basis of the complaint – is it contrary to current policy
  2. the currency of the complaint
  3. is this a repetitive matter
  4. is the complaint vexatious, belligerent

Level 3

Where a person making a complaint is dissatisfied with the outcome of our review of their complaint, they may seek an alternate opinion.  As the complainant is part of an intermeshed relationship, it is important for an understanding of implications of protracted negotiations.

4.    Accountability and learning

4.1   Analysis and evaluation of complaints

We will ensure that complaints are recorded in a systematic way so that information can be easily retrieved for review and reporting.

The General Manager will provide periodic reports on:

  • the number of complaints received
  • the outcome of complaints
  • issues arising from complaints and the origin of the complaints.

4.2   Monitoring of the complaint management system

We will monitor our complaint management system to:

  • ensure its effectiveness in responding to and resolving complaints
  • identify and correct deficiencies in the operation of the system

4.3  Continuous improvement

We are committed to improving the way we operate, including our management of the effectiveness and efficiency of our complaint management system. To this end, we will:

  • support the making and appropriate resolution of complaints
  • we will ensure that staff are aware of their responsibilities in accordance with this policy
  • implement best practices in complaint handling
  • regularly review the complaint management system and complaint data
  • implement appropriate system changes arising out of our analysis of complaints data and continual monitoring of the system.
  • devote financial resources to the training of staff in the mechanisms of conflict resolution and complaint handling and how to deal with unreasonable conduct by people raising internal disputes.

4.4 – Resolving unreasonable complaints

At times complainant behaviour may become or seem  unreasonable.

We will:-

  • seek to identify ‘unreasonable complainants’ and manage their issues of concern while at the same time assessing and communicating what are fair and reasonable responses.
  • the Village will seek to distance itself from complaints that are unreasonable or vexatious.
  • if after due consideration and review of matters raised, it may be the determination of the Board of Management and the Trustee that the matters raised by the complainant are not able to be satisfactorily concluded.
  • at all times the needs of the organisation, the complainant and the person or people managing the complaint are to be considered and handled in a professional and respectful manner.
  • after reasonable review if the above matters remain unresolved given due regard to both parties opinions it will be up to the determination of the Trustee after considering the assessment of the Board of Management to then advise that the matter has now been responded to and is considered closed. Once the matter has reached this point, no further discussion or communication on this matter will be entered into.




When responding to complaints, staff  will act in accordance with complaint handling procedures as well as any other documents providing guidance on the management of complaints.

Staff should also consider any relevant legislation and/or regulations when responding to complaints and feedback.

The five key stages in our complaint management system are set out below

Investigation process

1.  Receive

Unless the complaint has been resolved at the outset, we will record the complaint and its supporting information.

The record of the complaint will document:

  • Contact information of the person making a complaint and the date received
  • Issues raised by the person making a complaint and the outcome/s they want
  • Any other relevant information, will be recorded on the ‘report form’

2.  Acknowledge

We will acknowledge receipt of each complaint in a timely manner and respond within 5 days. If appropriate we may offer an explanation or apology.

3.  Assess and investigate

3.1   Initial assessment

We will confirm whether the issue/s raised in the complaint is/are within our control.  We will also consider the outcome/s sought by the person making a complaint. When determining how a complaint will be managed, we will consider:

  • How serious, complicated or urgent the complaint is
  • Whether the complaint raises concerns about people’s health and safety
  • How the person making the complaint is being affected
  • The risks involved if resolution of the complaint is delayed, and
  • Whether a resolution requires the involvement of other organisations or other parties
  • Has this matter or a similar matter been dealt with previously
  • Is the matter operationally based or policy based

3.2   Investigating the complaint

After assessing the complaint, we will consider how to manage it. We may:

  • Give the person making a complaint information or an explanation
  • Gather information about the issue, person or area that the complaint is about
  • Investigate the claims made in the complaint.

4.   Determine outcome and provide reasons for decision

Following consideration of the complaint and any investigation into the issues raised, we will advise the person making the complaint:-

  • The outcome of the complaint and any action we took
  • The reason/s for our decision
  • The remedy or resolution/s that we have proposed or put in place and
  • Any options for review that may be available

5.    Close the complaint: document and analyse data

5.1   Document

We will keep records about:

  • The date the complaint was raised and by whom
  • How we managed the complaint and the actions taken
  • Whether the complaint was resolved, escalated or withdrawn
  • The number of complaints handled each year and their source
  • The outcome/s of the complaint (including whether it or any aspect of it was substantiated, any recommendations made to address problems identified and any decisions made on those recommendations), and
  • Any outstanding actions to be followed up.

5.2   Analyse data

The complaints review process will continue and outcomes will be communicated to the resident body as appropriate.
Ref: 27/6/19 -v3- web.