PRO-021, Version 1.0, 1 July 2015
Complaints handling procedures.
To outline procedures for the handling of complaints at the National Museum of Australia (the Museum).
The Museum recognises the value of feedback, including enquiries, suggestions, complaints and claims, in improving its programs and services. A number of Museum policies and procedures provide for feedback, claims or complaints handling, with reference to the subject matter of the relevant policy or procedure. The Museum’s Client Service Charter provides general information about how the Museum will deal with feedback, including complaints, received from Museum visitors and clients.
These procedures outline the Museum’s general processes for receiving, managing and responding to complaints and claims, including where these relate to the Museum’s commitments under the Client Service Charter or other Museum policies and procedures.
3.1 Receiving complaints
Complaints received as feedback
Most complaints are received as part of feedback provided to the Museum. Feedback can be provided in multiple ways including:
- in person, to a Museum employee
- by email (refer to email addresses listed below)
- by completing a visitor feedback form and leaving it with a Museum employee, or mailing it to the Museum
- by telephone, including via the Museum’s general information number, (02) 6208 5000
- by mail, via GPO Box 1901, Canberra, ACT, 2601.
The Museum’s website lists email addresses for various types of feedback or enquiries, including:
- firstname.lastname@example.org for comments, complaints or feedback about the Museum, including complaints under the Client Service Charter
- email@example.com for general enquiries about the Museum
- firstname.lastname@example.org for comments about the website
- email@example.com for queries about copyright or photographs
- firstname.lastname@example.org for freedom of information requests
- email@example.com for requests for access/correction of personal information or privacy complaints.
Where possible, the Museum seeks to acknowledge all feedback received. If the feedback constitutes a complaint about the Museum, these procedures will apply. In the first instance, the Museum staff member who receives the feedback will assess whether it should be handled as a complaint, with advice from the Complaints Coordinator if required. Museum staff are to notify the Complaints Coordinator as soon as possible after receiving any feedback or complaint, for the purposes of data input and tracking.
Complaints in relation to specific Museum policies and procedures
The Museum operates under various policies and procedures which govern its interactions with a broad range of stakeholders, including members of the public, staff, volunteers, donors, communities, contractors and partner organisations.
These policies and procedures deal with matters including privacy, intellectual property, information access, acquisition of collection items, return of cultural objects, Indigenous cultural rights, working with vulnerable people, access to Museum buildings, public interest disclosures, and conduct of Museum employees.
A list of relevant policies and procedures is set out in section 7.2 of this document. Some of these include contact details and/or processes in relation to complaints about matters dealt with under those policies or procedures.
Complaints about services provided by the Museum
Under the Museum’s Client Service Charter, a person who wishes to make a complaint about their experience as a visitor to the Museum and/or about services provided by the Museum, is encouraged to contact the person they have been dealing with at the Museum. If the complainant does not think that the complaint can be resolved by that person, or if the complainant has not previously dealt with someone at the Museum, they should contact the Museum via the phone number, email or mail addresses listed above, to have the matter allocated to an appropriate Museum staff member for action.
People with particular accessibility needs should advise the Museum, so that an interpreter, teletypewriter or other facilities can be provided.
3.2 How a complaint will be handled
The Museum’s complaints handling process will generally comprise these steps:
- Acknowledge all complaints quickly
- Assess the complaint and give it priority
- Plan the investigation
- Investigate the complaint
- Respond to the complainant with a clear decision
- Follow up customer concerns
- Consider if there are any systemic issues.
Complaints will be dealt with in a manner that is proportionate and appropriate to the nature of the complaint. For straightforward complaints, steps 3 and 4 may not be required. These steps are outlined in more detail below.
Step 1: acknowledge all complaints quickly
The complainant should be provided with an acknowledgement of the complaint containing the following information (if known):
- the name and contact details of the person who will be dealing with the complaint
- where appropriate, an outline of the complaints handling process
- an estimated time frame for when the complainant can expect to be contacted next.
An acknowledgement should be provided as soon as possible after the complaint is received. A written or oral acknowledgement may suffice, depending on the circumstances.
For complaints that are straightforward and can be resolved quickly, the acknowledgement, assessment and response phases may all take place ‘on the spot’ for direct resolution of the complaint, or be included in a written response to a straightforward complaint received via email or by post. This approach is reflected in the Museum’s Client Service Charter.
If a complaint cannot be resolved directly, the complainant is to be advised of the Museum’s complaints handling process, including the likely time frame for the Museum to provide a further response to their complaint. If the complaint has been made in person by a Museum visitor, they should be offered a copy of the visitor feedback form and referred to the Client Service Charter on the Museum’s website.
Complaints may be made anonymously. However in some circumstances it may be difficult to properly investigate a complaint without knowing the complainant’s identity. In such cases, and where possible, the anonymous complainant will be asked how they wish to proceed.
Step 2: assess the complaint
The Museum will assess the nature of the complaint early and decide whether:
- any further information is required from the complainant at this stage. For example, additional information could help determine whether the complaint needs to be addressed to a particular person within the Museum, or should be directed to another organisation.
- the complaint should be prioritised or dealt with in a particular way. For example, if there are statutory time frames to be met or other sensitivities.
The complaint will be allocated to a person who is impartial and has the suitable skills to consider the complaint on its merits. For example, a complaint about a privacy breach will be allocated to a person with privacy expertise. In some circumstances a person external to the Museum may be appointed to undertake an investigation.
The person to whom the complaint is allocated will be required to treat the complainant fairly, and to demonstrate impartiality, confidentiality and transparency in their investigation.
If appropriate, the complainant should be asked how they would like to see the complaint resolved and/or what outcomes they are seeking. At this point the complainant may also need to be advised about what outcomes are feasible and why.
The complainant should also be informed of the process that will be adopted for investigating the complaint and applicable time frames (see paragraph 3.3). For some types of complaint, specific complaint handling or investigation procedures may be detailed in other Museum policies or procedures. For example, a ‘whistleblower’ type of complaint may be dealt with under the Museum’s Public Interest Disclosure procedures. Section 7 of these guidelines lists a range of Museum policies and procedures which include specific provisions for complaints management or investigation.
A copy of these complaint handling procedures (and, where relevant, the specific Museum policy or procedure that relates to the subject matter of the complaint) should be provided to the complainant.
The Museum may decline to investigate a complaint if it is assessed to be unreasonable or groundless.
Steps 3 and 4: plan the investigation and investigate the complaint
For complaints which are not able to be resolved on the spot, or in the initial response to the complainant, a plan may need to be prepared, outlining what is to be investigated, the relevant steps, and the estimated time needed to undertake each step and resolve the complaint.
In some cases it may be desirable to appoint an independent investigator, who may be responsible for developing an investigation plan in consultation with the Museum. The investigator should identify and take into account Museum policies or procedures which are relevant to the subject matter of the complaint. Where possible, the plan should also take account of the remedy the complainant is seeking, and note any special considerations that apply, such as keeping the identity of the complainant private, or safeguarding sensitive or confidential information. For complex or lengthy investigations, the plan may need to be reviewed and adjusted as the matter progresses.
The person handling the complaint should seek advice from the Museum’s Legal Services section in relation to the handling of any complaint or feedback, as appropriate. The Manager, Legal Services must be consulted in relation to significant complaints or claims, for example:
- situations where legal action against the Museum or relating to Museum actions is threatened or foreshadowed
- where a decision or action of the Museum is subject to appeal or challenge lodged with an external entity, for example the Commonwealth Ombudsman or the Australian Human Rights Commission.
The person handling the complaint should undertake the investigation as quickly as possible. The way in which the complaint is to be investigated will vary depending on the nature of the complaint. It may be necessary to interview or seek further information from the complainant, Museum employees or persons external to the Museum. A written record must be kept of information provided orally.
Where appropriate, the person handling the complaint should contact the complainant to provide them with updates on progress of the investigation.
Step 5: respond to the complainant
When the investigation is complete, the complainant should be advised of the outcome of the investigation or the decision reached (subject to any privacy or confidentiality considerations that may apply). An interim explanation or preliminary view may also be given. Complainants should be given an opportunity to comment on contrary information or claims from another source before a decision is made to dismiss the complaint.
The response should deal with each part of the complaint, to ensure that the complainant is satisfied that all aspects have been fully considered. The response should indicate whether any remedy is to be provided to the complainant. Remedies may include a detailed explanation of the subject matter of the complaint, an apology, or reconsideration of a decision.
The response should offer the complainant an opportunity to follow up the complaint with the Museum, or to seek review of the decision. The response should include advice about available options for review of the decision, including review by another Museum employee (‘internal review’) or by another agency (‘external review’) such as the Commonwealth Ombudsman, the Australian Public Service Commission, or the Australian Human Rights Commission, depending on the nature of the complaint.
Steps 6 and 7: follow up
The first point of contact for follow up should be the person handling the complaint. They should offer to explain their findings and provide further information on any review options to the complainant.
Where a complainant has requested internal review of a decision, and internal review is appropriate in the circumstances, the complainant should tell the Museum which aspects of the response they would like reviewed, and why they disagree with the Museum’s response. The Museum should provide the complainant with approximate time frames for the conduct of the review and details of the person undertaking the review.
Where the person handling the complaint has identified any systemic issues that need to be addressed, such as the need for further training of staff, they should communicate these issues to their manager or the Museum’s executive. This does not necessarily need to form part of the response to the complainant.
3.3 Time frames
Straightforward complaints should be dealt with as soon as practicable, and in most cases within 10 working days. It can be difficult to estimate time frames for more complex complaints. The complainant should be advised of estimated time frames for receiving a response from the Museum, as well as time frames relating to specific stages of a complaint, for example for interviewing relevant personnel and providing a written response.
Where a complaint is being dealt with under specific procedures or legislative requirements, the time frames may be mandated by the applicable procedures or legislation. In all other cases, the Museum aims to respond to complex complaints within 60 calendar days. If the planning phase for an investigation indicates that a longer time frame will be required, or the time frames need to be revised during the course of an investigation, the Museum will advise the complainant accordingly and, if applicable, explain the reasons for delay/revisions to the time frame.
3.4 Privacy and confidentiality
The Museum will treat all complaints confidentially and take steps not to disclose details of a complaint, other than is reasonably necessary for the purpose of investigating the complaint.
Complaints involving personal information will be dealt with in accordance with the requirements of the Privacy Act 1988 (Commonwealth). A complainant’s identity or personal details will only be made available to Museum staff involved in dealing with the particular complaint or who are responsible for handling Museum complaints. Personal information about a complainant will not be disclosed to people outside the Museum unless the complainant has given their consent, or they would reasonably expect for their information to be disclosed, for example, where their complaint involves another organisation, such as a Museum supplier or contractor.
4. Definition of terms
Any expression of dissatisfaction with the Museum, including in regard to interactions with the Museum (its staff, volunteers, partners, contracted service providers or anyone else acting on its behalf) or Museum activities or products (exhibitions, events, publications, tours, programs, shop, cafe or facilities).
A formal legal claim or demand on the Museum, or a situation where legal action is threatened or foreshadowed. For example, where a person asserts that the Museum has breached or interfered with their legal rights, or has dealt with their property in an unauthorised way, and is seeking compensation, reimbursement or some other form of redress.
Any comments or suggestions (whether positive, negative or neutral) about a person’s interaction with the Museum or in response to Museum activities or products.
5. Definition of responsibilities
Responsible for maintaining the Museum’s complaints management system, coordinating data input and reporting on feedback and complaints handling, and applying the following steps for each complaint:
- acknowledging receipt of the complaint
- recording the complaint on the customer relationship management database
- distributing details of the complaint to the appropriate work area for resolution
- tracking the complaint’s status
- providing the Museum’s executive management team with analysis of feedback categories, status and trends.
Head of Visitor Services and Front of House
Manages and responds to visitor and client complaints through the Client Service Charter process. Directly resolves complaints about Visitor Services and Front of House business.
Chief Operating Officer
Responsible for making decisions regarding the investigation of suspected fraud in accordance with the Museum’s Fraud control policy, and for maintaining and disseminating Museum policies and guidelines relating to employee conduct.
Deputy Director, Collections and Content
Responsible for ensuring feedback, enquiries and complaints received in relation to the acquisition, loan, display or use of collection objects and cultural material is managed in accordance with the relevant Museum policies and procedures.
Public Interest Disclosure Authorised Officers and Supervisors
Responsible for receiving public interest disclosures under the Museum’s Public Interest Disclosure procedures, including allegations concerning suspected breaches of the code of conduct.
Manager, Human Resources
Responsible for receiving, managing or providing advice regarding complaints or claims by Museum employees or contractors and complaints under Museum guidelines or procedures administered by the Human Resources team, including complaints concerning staff conduct, or health and safety issues.
Manager, Governance and Legal Services
Responsible for providing advice on the management of complex complaints and claims as required, including where it is claimed that collection objects have been acquired or disposed of illegally or where the complaint or claim includes allegations of infringement of/interference with legal rights, threats of legal action or legal proceedings.
Privacy Contact Officer
Freedom of Information Coordinator
Responsible for receiving, coordinating and advising on freedom of information requests and internal reviews of FOI decisions.
These procedures build upon the Museum’s Client Service Charter. They were developed with regard to the principles and standards outlined in the Commonwealth Ombudsman’s Better Practice Guide to Complaint Handling, 2009.
These procedures are intended to apply to all areas of Museum activity, subject to the exclusions in paragraph 7.3.
7.2 Other related policies and procedures
The following Museum policies and procedures include provision for complaints, claims, feedback or enquiries which may be managed in accordance with these procedures:
- Assistance animal access guidelines and procedures (PRO-008)
- Client Service Charter
- Collections development policy (POL-C-005)
- Indigenous cultural rights and engagement policy (POL-C-054), and Indigenous cultural rights and engagement procedures (PRO-010)
- Loans policy (POL-C-036)
- Working with children and young people policy (POL-C-043)
- Door to Store manual, Part 1, Chapter 12: Managing claims or disputes regarding collection material.
Some complaints made by or involving employees may be dealt with more appropriately under other Museum policies or guidelines with specific investigation procedures, such as:
- Public Interest Disclosure Procedures (PRO-016)
- Code of Conduct Guidelines and Procedures (PRO-015)
- Review of Actions Guideline (POL-G-050)
- Fraud control policy (POL-G-031).
01 July 2015
20 March 2015
Public & all Museum staff, contractors and volunteers
Complaints, claims, feedback, enquiries, disputes
Manager, Executive Support Unit
01 July 2017
Client Service Charter
National Museum of Australia
GPO Box 1901
CANBERRA ACT 2601
Tel: (02) 6208 5000