Customer Feedback and Complaints Policy

Revision Record

This policy supports DHS to:

• manage customer feedback and complaints in a fair and consistent manner
• comply with State Government policy and national standards
• be responsive to the needs of its customers and clients.

Effective complaints management in government is an integral part of performance management and customer satisfaction. Customer complaints and feedback provide a mechanism for DHS to improve services by listening to the voice of the customer.

A well-managed, inclusive, and transparent complaints handling model can build trust between the public sector and the community. This policy should help identify and mitigate gaps in services and risks.

The policy responds to the requirements of Premier and Cabinet Circular PC039, Complaint Management in the South Australian Public Sector(PC039), which requires all South Australian public sector agencies to establish and maintain an effective complaint management system that conforms to the principles in the Australian Standard, AS 10002:2022 Guidelines for Complaint Management in Organizations.

DHS strives to ensure everyone in our community feels respected, represented and seen. We are steadfast in our commitment to enabling positive and enduring outcomes for Aboriginal people, people with disability and/or neurodivergence, young people, older people, culturally and/or linguistically diverse people, carers, LGBTIQA+ and gender diverse people.

This policy applies to all DHS staff and to individuals engaged as agency staff, consultants, contractors, students on placement, vendors and volunteers in DHS.

Included:

This policy applies to customer feedback received by DHS, including suggestions, compliments, and complaints.

Excluded:

This policy does not apply to:

• Minor issues raised directly with a staff member that can be addressed during a standard interaction.
• A request for or follow up of services (for example, screening).
• Complaints that are the subject of a formal or regulatory investigation, an administrative appeal, or some other form of legal redress. This includes a report to the Office for Ageing Well relating to alleged non-compliance with the Retirement Villages Act 2016 by a retirement village operator, staff member or resident, or suspected abuse of a relevant adult pursuant to section 22 of the Ageing and Adult Safeguarding Act 1995.
• Staff complaints concerned with workplace conduct. The Grievance Resolution Procedure outlines the process for DHS staff to raise work-related issues.
• Critical client incidents, which are managed under client incident processes (for example, Critical Client Incident Policy).
• Public interest disclosures concerned with corruption, misconduct or maladministration, which are managed under the Public Interest Disclosure Procedure.
• A request for an internal review of a decision pursuant to section 38 of the Ageing and Adult Safeguarding Act 1995.

DHS ensures complaints are reported to external authorities as required by legislation or relevant policy.

DHS strives to celebrate and improve the lives of people of all ages, cultures, disabilities, ethnicities, faiths, gender identities, sex characteristics and sexual orientations. DHS is committed to making our services and workplaces safe and inclusive for all people and ensuring the full diversity of the communities we serve are represented in the strategies we lead.

Under the National Agreement on Closing the Gap, specifically Priority Reform Three: Transforming Government Organisations, DHS is committed to systemic and structural transformation to improve accountability, and to respond to the needs of Aboriginal peoples. DHS reports on actions to implement the transformation elements under Priority Reform Three which includes identifying and eliminating racism and embedding and practicing meaningful cultural safety. These outcomes will be measured by the proportion of Aboriginal people reporting experiences of racism, and the proportion of Aboriginal people who identify as feeling culturally safe in dealing with DHS.

It is noted that additional considerations may be required to support and respond to feedback and complaints from Aboriginal clients. These specific factors may include, for example, the provision of information to family, next-of-kin and community, seeking specific cultural advice, and developing specific resources.

Each business unit handling complaints and feedback is required to have current information on culturally safe and inclusive practices and support services and demonstrate how its processes respond to complaints and feedback from Aboriginal people in a culturally safe manner.

The Closing the Gap Framework Policy provides guidance for developing strategies that positively impact Aboriginal people.

Advocate

Someone who may support a client/customer to make a complaint or make the complaint on behalf of a client. An advocate may be an eligible support person, a lawyer, a doctor, a professional visitor, an independent advocacy service, SA Ombudsman, Equal Opportunity Commissioner or the Health and Community Services Complaints Commissioner.

Client/Customer

Someone who has received one or more of DHS’s services or programs.

Terms customer and client are used interchangeably depending on the requirements of the business unit.

Complainant

A person, organisation or their representative/advocate making a customer complaint.

Complaint

An expression of dissatisfaction made to or about an agency related to its products, services, staff or the handling of a complaint. A response or resolution is explicitly or implicitly expected or legally required.

Complaint Management System (CMS)

Includes policies, procedures, practices, staff, hardware and software used by an agency for the management of complaints and feedback.

Feedback

An opinion, comment or expression of interest or concern, made directly or indirectly, explicitly or implicitly to or about the agency, about its products, services, employees or its handling of a complaint. A response is not explicitly or implicitly expected or legally required. Feedback can be either positive or negative.

Gov Safety

The across-government hazard and incident reporting system in South Australia. The system is also used to capture feedback and complaints.

Incident Management Unit (IMU)

The IMU is responsible for the management of a range of incidents across DHS. These can range from staff interaction with clients to the care and safety provided to clients.

Lumary

The system for managing client information in DHS Disability and Specialised Services (DaSS), including DaSS client incidents and feedback.

DHS will maintain effective customer feedback and complaint management systems to support management of feedback and complaints.

DHS values feedback and complaints and is open and responsive. DHS uses feedback to support continuous improvement.

DHS will handle complaints professionally and efficiently. Each business unit, with direct customer service responsibilities, must have a clearly defined complaint handling procedure that conforms to this policy and State Government requirements [Premier and Cabinet Circular Complaint Management in the South Australian Public Sector (PC039), page 4]. The procedure must:

• be customer-centred
• not include procedures that cause further harm or distress to individuals
• assist employees in transferring or escalating complaints in a timely and sensitive manner
• be inclusive and accessible.

Divisions should ensure that procedural fairness is awarded to complainants, and that complaints can be received and addressed anonymously.

Business units should consider the most appropriate point of contact for the person making the complaint within DHS and advise the complainant.

DHS will make information available to people on where they can seek advocacy support that may assist them in raising and resolving their feedback and/or complaints.

All complaints should be taken seriously. When complaints are received, they should be assessed, and the business unit should confirm with the complainant whether the issues raised are within the business unit’s  area of responsibility. If the complaint does not relate to that division, information should be provided to the complainant on where best to direct their query.

People should not be adversely affected because they have made a complaint.

DHS will be particularly alert to complaints that indicate potential risk to customers, gaps in service delivery, or misconduct, and will take appropriate action.

Where a complaint meets thresholds for escalation to IMU‑managed processes, the matter will be managed under relevant IMU policies and procedures.

DHS should ensure there are avenues for review and escalation of complaints internally.

If the matter cannot be resolved internally, complainants should be provided with information about avenues for seeking resolution and/or external appeal.

DHS will maintain communication with complainants throughout the process, including:

• prompt acknowledgement
• information about expected timeframes
• details of action taken and the reasons for those decisions
• outcomes
• avenues of review or appeal of decisions.

DHS will use the complainant’s preferred communication method to acknowledge the complaint. Regular and responsive communication can reduce complaint escalation.

DHS internal investigations into complaints are outcome focused. DHS will involve the customer in the resolution of a complaint where possible.

Where the complainant and the customer are not the same person, communications will be to both, to the extent that privacy laws and confidentiality obligations permit. Before any communications are shared with the complainant, the customer should be advised and given the opportunity to agree to the disclosure.

Divisions must record, document, and manage complaints and feedback using the approved system relevant to their business unit (for example, Gov SAfety or Lumary).

DHS will collect, monitor, and evaluate performance of DHS’ CMS, and look for opportunities to improve, as outlined below.

This policy requires that business units with direct customer service responsibilities have complaint handling procedures and processes that conform to this policy and DPC Circular 039 (PDF).

The following governance arrangements support this policy:

Chief Executive

Responsible for:

• Ensuring DHS maintains effective processes and systems for managing complaints and feedback.
• Promoting a culture that values complaints and feedback, takes them seriously and responds appropriately.
• Supporting the use of complaints and feedback data to inform service improvements.

Executive Leadership Team

Responsible for:

• Providing leadership and oversight to the complaints management system within their division.
• Ensuring all customer complaints and feedback are recorded, responded to and managed appropriately, consistent with this policy.
• Ensuring escalation and internal review processes are in place within their division.
• Ensuring urgent and serious matters are identified and actioned promptly and appropriately, including reporting or referral as required (to the Chief Executive, the IMU, or to external authorities).
• Identifying improvement opportunities and systemic issues and implementing updates and remedial actions respectively.
• Ensuring complaints about the Senior Authorising Officer of the Restricted Practices Unit are directed to the Executive Director responsible for the Restrictive Practices Authorisation scheme.

Director, Office of the Chief Executive and Governance

Responsible for:

• Providing central support and coordination for feedback and complaints management within DHS, including corporate policy and review.
• Ensuring complaints or feedback received by the Office of the Chief Executive (OCE) are monitored.
• Handling complaints received by the Chief Executive and Ministers’ Offices.
• Ensuring this policy is accessible to the public on the DHS website.

Directors, managers, supervisors, and senior staff

Responsible for:

• Ensuring the Closing the Gap Framework Policy and Diversity and Inclusion Strategy are considered in the development of business unit customer complaints and feedback processes.
• Ensuring complaints received are appropriately recorded in their business unit’s CMS.
• Clearly communicating their teams’ responsibilities and requirements, including policy and procedures, related to complaints and feedback.
• Providing training and support to staff to respond to complaints and feedback.
• Providing oversight of the operations of their business unit’s CMS.
• Ensuring information about how to complain or provide feedback is clearly communicated to customers, and support is provided to those who need it, including those responsible for responding to complaints and feedback in their teams.
• Ensuring their business unit report six monthly to OCE in respect of complaints data, feedback and service improvements. (covering January to June and July to December).

All staff

Responsible for:

• Ensuring they are familiar with this policy, the CMS in their business unit, and any related procedures, guidelines and processes.

OCE primarily receives complaints and feedback regarding DHS through the online feedback form or via the DHS enquiries mailbox (enquiries@dhs.sa.gov.au). Feedback received by OCE is forwarded to the appropriate division’s inbox or contact, for assessment and action in accordance with the division’s CMS procedure.

Unreasonable conduct is “any behaviour by a person which, because of its nature or frequency, raises substantial health, safety, resource or equity issues for the people involved in the complaint process”. [NSW Ombudsman 2021, Managing unreasonable conduct by a complainant] Escalation processes for unreasonable complainant behaviour should be included in business units’ CMS procedures. Responses to the customer in this situation should remain professional and consistent, with necessary support provided to staff to ensure their wellbeing and safety.

Privacy considerations should remain at the forefront of all feedback and complaint processes. Any disclosures made in the CMS process should adhere to public expectations, legislative requirements relating to confidentiality, and to Premier and Cabinet Circular PC012, Information Privacy Principles (IPPS) Instruction.

Responses to complaints or feedback that led to concerns for a person’s health or welfare should follow the Information Sharing Guidelines for Promoting Safety and Wellbeing.

All complaints and feedback should be recorded by the business unit in line with its complaints and feedback procedure.

OCE is responsible for reporting complaints data, feedback and service improvements to the DHS Executive Leadership Team every six months. The report will include:

• the number and type of complaints received
• the outcome of complaints, including matters resolved at first point of contact
• any systemic issues identified
• whether any experiences of racism or discrimination are reported
• any service improvements made resulting from customer complaints or feedback
• the number of requests received for internal and/or external review.

This information will support DHS in its commitment to continuous improvement in customer service and business operations.

Divisions should identify the types of complaints received to be able to monitor where there may be trends (e.g. program or service quality, wait time, perceived unfair discrimination or racism, online experience, such as accessing information or navigation ease).

Complaints data is also included in the DHS Annual Report.

DHS will ensure that complaints are acknowledged within five business days and aim to finalise complaints within 30 business days.

Where a complaint is not resolved within 30 business days, the person managing the complaint will explain the reason for the delay to the complainant and an interim response with an indicative timeframe as to when a full response can be expected will be negotiated, to the extent that privacy laws and confidentiality obligations permit.

Risks of non-compliance include:

• customer and community dissatisfaction and harm
• gaps in services
• litigation
• loss of reputation and staff confidence
• breach of customer/client privacy
• financial loss.

Directive documents

Guidelines for complaint management in organizations (Standards Australia AS 10002:2022)

Health and Community Services Complaints Act 2004

Independent Commission Against Corruption Act 2012

Ombudsman Act 1972

Premier and Cabinet Circular - PC 039 - Complaint Management in the South Australian Public Sector

Supporting documents

DHS feedback and complaints webpage

Grievance Resolution Procedure Flowchart

Public Interest Disclosure Procedure Flowchart

Related documents and resources

Audit Survey Report: Assessment of state agencies’ complaints managements systems - Ombudsman SA (June 2018)

Code of Ethics for the South Australian public sector - Office of the Commissioner for Public Sector Employment

Managing unreasonable conduct by a complainant - A manual for frontline staff, supervisors and senior managers - A joint project of the Australasian Parliamentary Ombudsman (2021)

Author

Greg Myers, Principal Project Officer, Office of the Chief Executive

Approval

Belinda Marsden, Director, Office of the Chief Executive and Governance

17 June 2026