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HMRC internal manual

Complaint Handling Guidance

Defining and recognising a complaint: General

We define a complaint as:

“Any expression of dissatisfaction that is not resolved at initial contact and requires a response”.

It is very important that every business area respects this definition so that all staff identify and handle complaints properly, in line with our standards. This in turn will facilitate a consistent approach to recording complaints. Consistent recording gives us and Ministers confidence that the information we collect and publish on complaints is robust and provides an accurate measure of customer satisfaction with the quality of our service.

“Resolved at initial contact” should be interpreted as meaning that the matter can be sorted out quickly and informally with the customer, usually at the initial point of contact, and usually (but not necessarily) without the need to write to the customer. It can include matters referred by contact centres to a local office for resolution, even if that involves telephoning the customer back after you have gathered their details and prepared yourself to deal with the matter. The “resolved at initial contact” distinction does not mean that we are pretending that the customer has not told us they are unhappy. Rather, it is to ensure that our complaints procedures are manageable, make best use of our limited resources, and are simple for the customer. Remember, however, that there may be lessons to be learned from issues resolved at initial contact (ie before something becomes a tier 1 complaint), and you should have procedures in place to identify and share them.

Sometimes a customer will express a degree of dissatisfaction, but not in the sense that it “requires a response”. An example may be where a customer accepts that they owe tax, expresses an opinion about the fairness of the system, but encloses full payment. In many cases like this, the customer is not expecting a response, but merely wishes to take the opportunity to “let us know what they think”. We would not regard that as a complaint and would not treat it as such. But in any case of doubt, ask the customer to clarify their intentions. Never simply assume that no response is required.

In practice, it can sometimes be difficult to distinguish between what is an enquiry, a question, a request for clarification, and a complaint. To help you make informed decisions on defining and recognising complaints, always consider the following:

  • if the customer uses the word complaint, or it is otherwise clear from the customer’s contact with us that they are unhappy with the way their affairs have been handled, then treat it as a complaint and record it as such unless it is genuinely “resolved at initial contact” (see above)
  • regardless of the clarity of the customer’s intentions as regards the status of their contact with us, if the issue is not “resolved at initial contact” but requires a second bite, either by the same reviewer or by someone else, this is an indication that the issue should be treated as a complaint
  • use your judgement: some customers resent being told that they are making a complaint, when that was not their intention
  • do not be averse to defining an issue as a complaint: complaints data can give you early warning that something is not going as smoothly as expected, and offers the opportunity to fix things before they escalate and become a major problem.
  • If you or the customer consider that financial redress may be due for a mistake that we have made, this must be treated as a complaint.