Complaints Policy

Introduction

This Complaints Policy defines CTHS’s (“we”, “us” or “our”) approach to complaint handling and how STAR delivers the expectations of STAR Participants (“you”) in respect of the provision of the services delivered under STAR. These services specifically relate to:

1. The maintenance of the STAR MI defined process steps,
2. Associated STAR SLA definitions,
3. STAR MI & Reporting,
4. And the STAR Accreditation process.

Complaints covered by this policy

A complaint is any expression of dissatisfaction, from a STAR participant organisation, about the provision of, or failure to provide, the agreed services under STAR.

A complaint may, for example, concern:

• Whether a specific STAR Accreditation Award threshold is representative of the underlying SLA it seeks to measure across the STAR Participants;
• Where interpretation of a STAR Participant’s Management Information, in determination of their STAR Accreditation Award, is deemed, by the STAR Participant, to be inaccurate or misrepresents their organisations actual performance (against the STAR SLAs);
• Applications of the STAR programme’s rules and procedures in relation to one or more specific Accreditation Award determination(s);
• Decisions made by the STAR programme in relation to a STAR Accreditation determination.

Complaints not covered by this Policy

Please note that this Complaints Policy does not cover:

• Matters that have already been fully investigated through this complaints procedure, unless new evidence is available
• Concerns about possible wrongdoing or malpractice relating to a STAR Accreditation Award, which we will handle in accordance with our Whistleblowing Policy.
• Complaints about access to information where procedures and remedies are set out in legislation including, without limitation, the GDPR, the Privacy and Electronic Communications Regulations 2003 (as amended by SI 2011 no. 6),  the Data Protection Act 2018 (“DPA”) and the GDPR as amended in accordance with the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (as amended by SI 2020 no, 1586) and incorporated into UK law under the UK European Union (Withdrawal) Act 2018, (“UK GDPR”), which will be handled in accordance with the procedures set out in the applicable legislation.

Handling complaints

We will accept receipt of complaints made by any reasonable means. If a complaint is not in writing, we may ask for the details to be put in writing or we may write to you by letter or email setting out our understanding of the complaint.

A complainant may write directly to the Chair of STAR or to the CTHS Executive Team at the address provided for on the STAR website.

On receipt of a complaint:

1. We will write to you within two (2) business days of receiving it to acknowledge the complaint and confirm that we are dealing with it.
2. We will investigate the complaint carefully, diligently and impartially. This will be done by a senior member of the STAR programme who was not directly involved in the matter giving rise to your complaint. We may escalate the complaint as appropriate to the STAR Steering Group or the STAR Accreditation Steering Group depending on the nature and severity of the complaint, in the manner further described in the process flow set out at Appendix 1.
3. We will decide whether we think that the complaint is justified.
4. If in our view the complaint is justified, we will decide what remedial action is appropriate.
5. We will write to you as soon as possible with our decision and clearly explain our assessment of the complaint, our decision on it and whether we propose any remedial action. If we cannot send you a final response within 8 weeks of receiving the complaint, we will write to you to explain why and to let you know when we expect to be able to complete the review and provide our final response.
6. If we uphold a complaint, we will consider whether others who have not complained to us nevertheless may have had cause to complain.

Investigating the complaint

To help us to review your complaint , we ask you to be clear about what the complaint is, to supply as much evidence as you can regarding the complaint and also to let us know what action you are looking for us to take.

Factors that may be relevant in our assessment of a complaint include:

• All of the evidence available;
• Details of the particular circumstances of the complaint;
• Similarities with other complaints received by us; and
• During our review of the complaint, we may need to get further information from you and/or from others. We may also need to get clarification of the information you have provided to us. If we ask you for further information or validation, please respond to us as soon as possible as we may be unable to continue to review the complaint in the meantime.

Confidentiality

We will keep the matter of your complaint confidential as far as possible but it may be necessary for us to contact third parties for information. We will endeavour to do this without identifying you if this is possible. You may advise us that you will not allow us to identify you as the complainant but in such circumstances, you acknowledge that it may be impossible for us to complete our review of your complaint.

Recording complaints

We will retain all complaints records for at least 5 years.

Contact Information

Complaints should be sent to complaints@star-transfers.co.uk.

Review

This Complaints Policy is reviewed at least annually by the CTHS Board.