Best Practice No. BP21 (version 1.0 June 2012)
1.1 Communication Matters has various types of membership including Associate members (e.g. AAC users, family members, professionals etc), and Organisational members (e.g. not for profit organisations involved in AAC, businesses selling communication aids and/or services).
1.2 Communication Matters (CM) has its own Code of Conduct which all Institutional, Commercial and Corporate members sign up to as part of their membership.
2. Policy statement
Communication Matters is not a regulatory organisation, but believes complaints need to be taken seriously and brought to a satisfactory conclusion for all involved parties. Communication Matters recognises that many of its members are also members of Professional bodies, Trade Associations, etc, which have their own Complaints Procedures in place. It is therefore the policy of Communication Matters, wherever possible, to refer complainants to the relevant Professional regulatory body or Trade Organisation.
3. Complaints process
Complaints about a CM member of Communication Matters, whether to an individual Trustee or direct to the Trustee Board, will be handled as follows:
3.1 The complainant will be advised to contact the other party, in writing if necessary, to request a resolution to the problem.
3.2 If no resolution has been achieved by step 3.1, the complainant will be advised to take their complaint to the next level of authority:
3.2.1 If the complaint is about a commercial or corporate organisation, the complaint should be made, in writing, to the British Healthcare Trades Association (BHTA) at New Loom House, Suite 4.06, 101, Back Church Lane, London E1 1LU (www.bhta.net). The BHTA give guidance on how to complain on their website – or you can complete an online form. The organisation against whom the complaint is being made does NOT have to be a BHTA member for BHTA to handle the complaint. If the organisation is a member of BHTA, BHTA will try to use its authority to produce a satisfactory resolution. If the organisation is not a member, BHTA will advise the organisation concerned and pass the details onto the relevant legal body e.g. the Office of Fair Trading, local Trading Standards etc.
3.2.2 If the complaint is about an individual professional member the complaint should be made to the relevant regulatory body, e.g. Health Professions Council (HPC), Park House, 184 Kennington Park Road, London SE11 4BU (www.hpc-uk.org) for Allied Health Professionals.
3.2.3 If the complaint is about an institutional member it should be directed to the Board of Trustees, Management Board or equivalent of that institutional member. The complainant will then need to deal directly with that governing body.
3.2.4 If the complaint is about a private individual who is not covered by any of the above, the complainant should be advised that their only recourse is through the statutory legal process.
4. Breach of Code of Conduct
4.1 Should the complainant specifically state that they wish Communication Matters to deal with their complaint as a breach of CM’s Code of Conduct, the complainant must provide the following before their complaint will be reviewed:
4.1.1 A copy of the complaint as sent to the other party (e.g. letter or email)
4.1.2 A copy of the response that shows or indicates that the complaint has not been dealt with satisfactorily. Should the other party have responded verbally, a copy of a letter or email sent to the other party, confirming the verbal conversation, will be accepted as evidence.
4.1.3 A copy of a letter or email from the complainant to the other party advising that they are not satisfied with the response and that they intend to inform CM that they believe there has been a breach of the CM’s Code of Conduct.
4.1.4 Any other documentary evidence.
4.2 Once all the documentation has been received an Investigative Trustee (IT), who has no conflict of interest with either party and who has been authorised by the full Board of Trustees, will be appointed to consider the evidence. If the IT concludes that a breach has taken place then the IT will contact the other party requesting them to instigate a resolution. If no resolution is reached then the complaint will be referred to the Board of Trustees. If the IT concludes that no breach has taken place then the IT will contact the complainant and advise of their findings. The complainant can appeal within 30 days against this decision by writing to the Chair of CM. The appeal will be heard by the Board of Trustees, who will make the final decision.
4.3 Should there be no satisfactory outcome from these actions the IT will refer the matter to the full Board of Trustees, for review, at their next meeting and the full Board will make the final decision on what action to take. For complaints that are upheld as justified, the Board may take one of the following actions:
4.3.1 A letter to the offending party advising that a repeat of the breach may lead to their membership being suspended or cancelled. This is a “warning” and may be used even if the offending party has resolved the complaint but the Board still feel a warning is justified.
4.3.2 The suspension of the offending party’s membership until they take the necessary actions required to resolve the complaint.
4.3.3 The cancellation of the offending party’s membership if the Board consider the complaint was serious enough to warrant such action.