Part 6: Managing and learning from complaints

In addition to the remedies in Part 4, ACC will address the wider implications of breaches that arise by –

a) analysing and monitoring issues arising from the complaints process; and

b) identifying concerns with operational policies and processes; and

c) subsequently undertaking and remedying concerns associated with operational policies and processes as appropriate; and

d) informing the claimant that the situation has been addressed.

Code of ACC Claimants' Rights, Part 5

6.1
In this Part, we discuss:

• the need for ACC to be more committed to handling complaints;
• ACC's lack of learning from complaints; and
• ACC's strong approach to privacy.

Summary

6.2
Most of the staff we spoke to show a commitment to customer service and the principles that ACC was founded on. However, the complaints system is not performing as well as it should. Apart from privacy complaints, ACC does not learn from complaints data, which is a Code obligation. ACC has been aware of this for some time but has not made improving this a priority.

6.3
In our view, ACC needs a more strategic approach to all complaints. ACC's board and executive need to lead a better approach to complaints if ACC is to show a commitment to handling complaints. The Shaping Our Future initiative offers an opportunity to make significant improvements.

6.4
ACC has a stronger commitment to privacy than it does to the other seven rights covered by the Code. This shows that ACC can improve when it puts the necessary measures in place.

Need for stronger commitment to handling complaints well

Stronger organisational leadership and a strategic approach to managing complaints are needed if ACC is to show that it is committed to handling complaints well. The Shaping Our Future initiative offers an opportunity to make significant improvements to ACC's complaints system.

6.5
Good leadership on complaints is vital. Valuing complaints must begin at the top of an organisation and complaints must be welcomed. Good leaders understand that more complaints are not always a result of deteriorating service. As we said in paragraph 1.4, increases in complaints can arise from better public awareness of the right to complain and better handling of complaints.

6.6
The external consultant who reviewed ACC's approaches to complaints found that introducing service recovery was a positive step. We estimate that about 90% of all complaints are resolved by local offices. This is efficient but service recovery's effectiveness has not been evaluated.

6.7
The ACC staff we spoke to in the complaints system are dedicated, conscientious, and mostly aware of the limits of the current system. Many parts of the wider complaints system are outside their control, and they lack the power to change matters. Changes will require organisational commitment and leadership.

6.8
In the past, there was no overarching ACC-wide vision or strategy for the wider complaints system, although CSS and OCI have had clearer direction. In our view, the current system has evolved in an unco-ordinated way. The result is a fragmented, overlapping, and inconsistent system for handling complaints.

6.9
This fragmentation means that the wider complaints system lacks a single point of oversight and governance below the chief executive. For example, when we carried out our audit work all the different teams that handle complaints reported to different senior executives:

• the core of the complaints system – local offices, CSS, and OCI – reported to the General Manager Claims Management (part of a large portfolio of responsibilities);
• the government services team reported to the General Manager Governance, Legal, Policy, and Research; and
• the privacy team reported to the Chief Privacy Officer and Change Director.

6.10
There was no single point of oversight, co-ordination, or collection of information. When coupled with the low organisational profile of complaints, system-wide improvements are difficult to achieve. As part of Shaping our Future, ACC announced in May 2014 a new executive structure, including a new role of chief customer officer. This is intended to be the single point of contact and authority on customer experience matters throughout ACC. In our view, this is a positive step.

6.11
We reviewed ACC's board and executive team papers for 2013 and found little time scheduled for complaints matters. Privacy is a much more visible concern among ACC's board and senior executives. The board and executive team each scheduled about 3% of their agenda time for complaints matters. The corresponding figures for privacy matters were 20% (board) and 15% (executive team).

6.12
In the past decade, ACC's response to internal and external reviews of the complaints system has been patchy. The most significant reviews of the complaints system were in 2005 and 2008 (see paragraphs - ). The biggest change arising from one of these reviews was the service recovery approach – an emphasis on resolving complaints early and rebuilding the relationship with the person who had complained.

6.13
Service recovery also included more communication with the complainant and more focus on establishing early in the process what outcome the complainant sought. The last review of the service recovery approach, in 2007, highlighted that local offices had adopted the service recovery approach to varying degrees.

6.14
The external reviews generated other findings and recommendations, but many were not acted on. They included several recommendations about organisational practices, including:

• moving away from relying on an apology letter as the main remedy, because it was not enough to restore the relationship with the person who had complained;
• training for frontline staff in how to handle complaints;
• reorganising the complaints system to provide clearer sorting of all complaints; and
• mandatory follow-up of complaints to check that the changes promised were put into effect.

6.15
The 2008 National Issues Management strategy, designed to bring more coherence to the complaints system, was only partially successful. It brought together OCI, CSS, cultural services, and other technical teams into one management structure to help them work more closely together. However, its intention to ensure that service and decision problems were considered together, with an emphasis on resolution for the complainant, has not been fully realised.

6.16
ACC's research team has carried out several pieces of analysis, but there is little evidence that this has led to improvements. Senior managers could not explain why many previous reviews had not resulted in more improvements.

6.17
In 2012, ACC's assurance team reviewed organisational learning from complaints. This included identifying:

• a lack of visibility of complaints at the executive level;
• the absence of a quality reporting function for complaints; and
• no formalised training content for managing complaints and reviews.

We were told that complaints investigators refuse to investigate systemic problems.

6.18
Some work is under way to address these weaknesses, but our audit work has shown that room for improvement remains.

6.19
Our discussions with staff and observations of practice around the country show that ACC has a devolved organisational culture. The local office manager significantly influences culture and practice at each local office. Most staff told us that they identify more strongly with the local office than with ACC as a whole. This is a risk to consistent practice in handling complaints that needs to be mitigated.

6.20
Shaping our Future, which aims to change ACC into an organisation that focuses more on "customers", offers a significant opportunity to prepare and implement a strategic approach to complaints. The initiative also offers an opportunity to simplify and embed lasting improvements in the complaints system. There are risks to successful implementation of this initiative if there is not strong leadership and a strategic approach to the changes.

Limited organisational learning from complaints

Apart from privacy, ACC does not learn from complaints data, which is a Code obligation. ACC has been aware of this for some time but has not made remedying this a priority.

6.21
Part 5 of the Code states that ACC will address the wider implications of breaches by analysing and monitoring matters arising from the complaints process, and using that information to make any necessary improvements. In our view, ACC is meeting this Code requirement only for matters of privacy.

6.22
Except for privacy matters, ACC does not systematically learn from Code complaints. ACC is aware of this and some work is under way but ACC has yet to implement a solution. ACC is reporting some data about complaints better but needs detailed data so that it can identify ways to improve services.

6.23
ACC's information technology systems have hampered efforts to improve analyses of complaints. In 2007, ACC introduced Eos, its claims management software. Since then, improving its information technology systems to help with complaints has not been a high priority for ACC.

6.24
Information technology problems prevent co-ordinated analysis and reporting of common complaints. For example:

• In 2010, the CSS and OCI teams began using Eos. Before 2010, they used a different information technology system, the data from which is no longer easily accessible. Eos does not categorise complaints in detail, so produces less useful data than required.
• Eos does not allow frontline staff to record their interactions with complainants in a way that provides useful data. This means that the complaints system is effectively blind to most people's complaints.
• The government services team and the privacy team use different software to record their work.

6.25
ACC is making some improvements to its information technology. A modification of Eos aims to collect more detailed data. The software to do this was being tested and evaluated at the time of our audit. We have not audited this work so cannot provide any assurance about its potential effectiveness.

6.26
The best organisations think of complaints services as adding value, not as just an overhead cost. Complaints can be an important source of information about people's experiences and can help to identify systemic problems and poor service. Analysing past complaints can help organisations respond and adapt to prevent future complaints.

6.27
ACC has a research and analysis team that can analyse data about complaints as required, but only after an internal request. Some research has been carried out, such as the 2012 analysis of complaints to the 0800 telephone line. This identified that communication problems were a common source of complaints and indicated the need to review frontline staff's communication skills. The report recommended regular analyses of complaints data to identify themes that might change. The research team told us that the report resulted in no significant changes.

6.28
We found no evidence of systematic analysis of complaints data leading to improvements in service. We found examples of local offices responding to complaints, such as with staff training or coaching, but this action was begun locally.

Stronger approach to privacy than complaints

ACC has a strong approach to privacy compared with how it approaches other Code rights.

6.29
Privacy is one of the eight rights in the Code. In response to an independent review of privacy and security of information in 2012, ACC adopted a different approach to matters of privacy. We have not audited ACC's approach to privacy other than where it touches on ACC's approach to complaints.

6.30
Some of the difference in approach to complaints and privacy matters is due to the effect of a major privacy breach becoming public in 2012. Staff told us that privacy is a main organisational commitment and a "hot button" for top managers. Our site visits confirmed that privacy has high visibility throughout ACC. In comparison, complaints have a low profile. Staff do not give complaints the same attention as they give privacy matters.

6.31
In our view, privacy matters benefit from corporate leadership and a strategic approach. Figure 24 lists the differences in ACC's approach to privacy and the other seven Code complaint areas.

Figure 24
How ACC approaches privacy and the other Code complaints

Criteria	Privacy complaints	Other Code complaints
Documented clear expectations from the board		x
Designated executive lead		x
Frequent board and executive reporting		x
Approach formalised in a set of principles or Code
High organisational visibility		x
Relevant strategy based on best practice		x
Arrangements for regular follow up and audit of strategy implementation		x
Balanced scorecard type targets		x
Public reporting
Internal custom web-based reporting tool		x
Detailed data collection including logging "near misses" and non-compliance		x
Relevant objective in staff performance agreements		x
Comprehensive staff training and education programme		x
Part of staff induction training
Internal communication campaigns		x
Regular banner page slot on internal intranet		x
Surveys of relevant staff		x
Formal "road show" programme of local office visits		Visits whenever feasible
End-to-end process review and process re-engineering where identified		x

Source: Accident Compensation Corporation.

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