Complaint Management Policy

1. Policy Statement

SMCT is committed to ensuring that any person or organisation using services provided by SMCT or affected by its operations has the right to lodge a complaint and to have their concerns addressed in ways that ensure access and equity, fairness, accountability and transparency.

This policy outlines and facilitates SMCT’s best practice approach to complaint management, ensuring objective outcomes for individuals and SMCT. It defines an open and transparent approach to complaint management to ensure the effective, timely, consistent and appropriate response to complaints.

SMCT promotes a culture that encourages feedback and complaints, learning from issues to continually improve the customer experience.

This policy aligns and supports achievement of SMCT’s Strategic Plan, focusing on the strategic pillar of Relationships - Understanding our customers, communities, and stakeholders is crucial for delivering excellent products and services and strengthening the broader industry. We will consolidate and deepen our understanding of customers and community while focusing on improving customer experience.

2. Scope

This policy applies to all complaints received by SMCT, regardless of the method in which the complaint is received. It includes complaints about third parties, such as contractors. It applies to all SMCT staff and contractors.

Where a complaint involves a risk to the safety of staff, customers or contractors, an incident report will also be raised, following SMCT’s internal Incident Reporting Procedure.

3. Definitions

4. Policy Standards

This policy is based on the following seven principles:

4.1 Commitment

We are committed to resolving complaints and have a culture that recognises an individual’s right to complain. We value complaints and recognise them as being part of our business of serving our communities and improving service delivery.

4.2 Accessibility

SMCT’s Complaint Management Policy is simple in practice, inclusive, and provides detailed and clear communications.

4.3 Transparency

We make it clear how to complain, where to complain and how the complaint will be handled. The steps taken to respond to a complaint are recorded and will stand up to scrutiny.

4.4 Objectivity and fairness

Complaints are dealt with courteously, impartially, within established timeframes and are assessed on merit.

4.5 Privacy

Complaint information is handled according to privacy laws and other relevant legislation. We provide clear information about how we handle personal information. Complaint data is de-identified if reported on more widely.

4.6 Accountability

We are accountable internally and externally for our decision making and complaint handling performance. We provide explanations and reasons for decisions and ensure that our decisions are subject to appropriate review processes.

4.7 Continuous Improvement

Acting on, learning from and using complaint data helps us identify problems and improve services.

5. Roles and Responsibilities of SMCT staff

6. How to make a complaint

A person can make a complaint in a number of ways:

7. Accessibility

Anyone who has been affected by a decision or action (including a failure to make a decision or take action) can make a complaint.

SMCT encourages the use of The National Relay Service (https://www.accesshub.gov.au/External site) to support those with a hearing or speech impairment to make a complaint or provide feedback.

People who would like to make a complaint or provide feedback in a language other than English (LOTE) can do so in writing and SMCT will translate this communication.

We accept and respond to anonymous complaints, provided we have received enough information to do so.

Complaints can be submitted to SMCT via any of the channels listed above (Section 6). 

8. Complaint handling procedure

Overview

We take a four-tiered approach to complaint handling, as follows:

1. Frontline resolution: frontline staff receive the complaint, assess it, and resolve it immediately, if possible.
2. Investigation (if required): if frontline staff cannot resolve the complaint, they will refer it to the Customer Resolutions Team for investigation and triage (if required).
3. Internal review: if the complainant is aggrieved with the process or outcome of the frontline resolution/investigation, they can request an internal review.
4. Access to external review: if the complainant is aggrieved with the process or outcome of the internal review, we inform them of any available external review options.

Procedures

Details of how complaints are managed from receipt through to resolution/closure are detailed in SMCT’s internal Client Feedback Process & Procedure.

The procedure has four stages:

1. Record & Acknowledge
2. Investigation & Discover
3. Internal review & recommendations
4. Resolve & Close

9. Complaints about contractors

We recognise that we retain a level of responsibility for services carried out by contractors on behalf of others (i.e. where SMCT has engaged the contractor to provide the services to the customer). In this case, SMCT will coordinate the complaint on behalf of the customer and make all reasonable attempts to resolve the complaint, following the Complaint Management Policy.

10. Complaints alleging corrupt conduct

Where a complaint involves allegations of corrupt conduct, it will be handled in accordance with SMCT’s Fraud and Corruption Management Policy, and Public Interests Disclosure Policy.

11. Remedies

Where we have found that we have made an error, we will take steps to redress the situation. Possible actions include, but are not limited to:

• an explanation of why the error occurred and the steps taken to prevent it happening again
• a reversal of a decision/action taken
• refund of payment(s) made or waiving of costs incurred (full or partial)
• addressing error with staff member in line with SMCT procedures
• providing the means of redress requested by the complainant or as deemed appropriate.

Where we identify an error, we will consider offering an apology to the complainant, in addition to any other remedies offered, irrespective of whether the complainant specifically requests this.

12. Privacy

When gathering information to respond to a complaint, we will only:

• use it to deal with the complaint or to address systemic issues arising from the complaint;
• disclose it in a de-identified format when disclosing data to the public;
• share it with staff on a need-to-know basis.

When responding to a complaint, SMCT will not disclose any sensitive information regarding services, products or transactions to anyone other than the Holder of Right of Interment (HOR) or an authorised person(s), as expressed in writing by the HOR.

13. Recording complaints

All customer complaints are recorded in SMCT’s complaint database, in accordance with the internal Client Feedback Process & Procedure. SMCT’s Database access is restricted to employees who require the necessary information to service the customer appropriately.

We record the following information for each complaint:

• the complainant’s name, email address, contact phone number
• how the complaint was received
• a description of the complaint
• the complainant’s desired outcome (if known)
• the team member(s) responsible for handling the complaint
• communications sent/received from complainant
• summary of outbound/inbound telephone calls with complainant
• any action taken, including contact with the complainant, response times and the outcome
• when the complaint was resolved/closed
• relevant demographic information that could help improve services

Any queries regarding the recording of complaints should be directed to:

SMCT Privacy Officer
PO Box 1159
Clayton VIC 3169
Phone - 1300 466 904
Email - privacy@smct.org.au

14. Reporting on performance

To measure our performance, we have the following key performance indicators (KPIs):

These KPIs may be related to:

• complaints upheld, partially upheld, not upheld
• complaints received per interaction (average)
• performance against timelines (to resolve/close, and to respond on receipt of complaint)
• number of complaint outcomes overturned on internal review
• customer satisfaction with the complaint handling system
• complaints escalated to the Victorian Ombudsman’s office where the agency’s original decision has been overturned and/or proposals for action have been made by the Ombudsman.

Ongoing reporting of the complaint data is accessible to the Executive Leadership Team, Executive Manager – Business Optimisation, and Manager – Customer Resolutions.

Formal (de-identified & summarised) reports are compiled periodically and provided to the SMCT Trust, SMCT Finance, Risk & Audit Committee, and ELT, and provide recommendations on how we can reduce complaints and improve services. The ELT is responsible for acting on the recommendations in these reports.

15. References and related materials

Legislation and Regulations

• Cemeteries & Crematoria Act 2003 (Vic)
• Cemeteries & Crematoria Regulations 2015 (Vic)
• Charter of Human Rights and Responsibilities Act 2006
• Freedom of Information Act 1982
• Privacy and Data Protection Act 2014

SMCT Documents

• Client Feedback Process & Procedure
• Code of Conduct for Employees
• Community Consultation Policy
• Delegation of Authority Policy
• Fraud and Corruption Management Policy
• Incident Reporting Procedure
• Issue Resolution Procedure
• Media Policy
• Public Interests Disclosure Policy

We’re committed to addressing your concerns and will provide an initial response within 48 business hours.