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Complaints Management Policy


Transport and Main Roads is committed to respecting, protecting and promoting human rights within our decision-making and actions. Aboriginal peoples and Torres Strait Islander peoples hold distinct cultural rights; therefore, we want to continue promoting respect for human rights and freedoms, enhance access to services and supports, and lead changes to improve the lives of Aboriginal and Torres Strait Islander Queenslanders.

As part of this commitment, we want to acknowledge and display our connections with First Nations Australians which builds respect and helps us develop policies, services and programs that reflect the diversity in our communities and the needs of our customers.

Transport and Main Roads artwork—Travelling by Gilimbaa

"Travelling" by Gilimbaa

Meandering pathways wind their way across the land to the sea, opening up country and connecting people. Trade lines are established, knowledge is gained, and new ways of learning and living are passed on to the next generation.

We live together in understanding, sharing our cultures, our customs and stories. The Transport and Main Roads artwork “Travelling” essentially reads as a “road map” of the State of Queensland. Orientated to portrait format with the Rainbow Serpent facing upwards, this artwork explores both the cultural and geographical landscape of Aboriginal and Torres Strait Islander Peoples in Queensland.

Beginning from the bottom of the artwork the Rainbow Serpent slowly meanders its way northwards creating and forming the landscape. The bold red rectangular motifs represent the built up urban city-scape of the South-East Queensland region.

The bright golden dotted strip is indicative of our beautiful coastline and magnificent beaches. Moving out west over the great divide into dry arid country then up into River country before being engulfed by the Rainforest region of the Cape.

Finally arriving at the tip of Queensland to the pristine turquoise waters of the Torres Strait Islands.

The Transport and Main Roads artwork is Connecting Queensland.

We pay our respects to the Aboriginal peoples and Torres Strait Islander peoples of this land, their spirits and their legacy.

1. Policy statement

At Transport and Main Roads, we place the customer at the centre of everything we do. We’re committed to building a culture of customer service excellence and encourage a people focussed and proactive approach to complaints management. We value all complaints and ensure our complaints management process is accessible, fair and responsive, where we work together with our customers to drive business decisions and improvements.

2. Objectives

This policy aims to ensure our complaints management system:

  • is customer friendly and responsive to address customer concerns effectively
  • respects, protects and promotes human rights
  • is delivered meaningfully to build our knowledge and continuously improve our business.

3. Scope

A complaint is the verbal or written expression of dissatisfaction about the policies, products, projects or services provided by us and/or our staff.

This includes:

  • past, current or proposed policies, products, projects or services
  • past or current staff, including the customer service provided by staff
  • actions or decisions made, including proposing an action, making a recommendation and
    failing to take an action or make a decision.

This policy covers external complaints made to us by members of the public, stakeholders or staff members acting as members of the community. Certain specific complaints are excluded from the scope of this policy as they’re managed under particular legislative or contractual requirements and therefore are out of scope.

This policy is supported by departmental Complaints Management Procedures and local complaints processes which include further guidance on specific complaints excluded from the scope of this policy. Local processes are required to be compliant with this policy, the Public Service Act 20081, the Human Rights Act 2019 and the guiding principles of the Australian Standard2.

4. Benefits

We take complaints seriously as they provide us with an opportunity to understand the needs of our customers, increase customer satisfaction and improve service delivery and performance.

We're committed to providing and maintaining a best practice complaints management system.

5. Applicability

This policy applies to all staff including temporary and permanent employees, consultants, contractors, students or any other person who provides us with services on a paid or voluntary basis.

6. Compliance

Compliance with this policy is mandatory.

7. Authority

Our complaints management system complies with the Public Service Act 20081, is compatible with the Human Rights Act 2019 and meets the guiding principles of the Australian Standard2.

1Section 219A Departments to have complaints management system for customer complaints.

2AS 10002:2022 Guidelines for complaints management in organizations.

8. Responsibility

8.1 Functional responsibility

The General Manager, Governance Branch is our nominated Complaints Management Manager. This role is supported by the Complaints Management Team (RTI, Privacy and Complaints Management, Governance Branch) and the departmental Branch Complaints Coordinator Network. Staff may also have complaints handling responsibilities as defined in the Complaints Management Procedures.

9. Complaints management model

Step 1: Initial resolution

Initial resolution consists of handling the complaint by the frontline receiving officer and early resolution of the customer complaint at the point of receipt, where possible. The customer will raise the issue/s with the department, whether in writing, over the phone, in person or online.

a) Frontline Receiving Officer

The frontline receiving officer will:

  • solve or address the issue/s in the first phone or face to face contact.
  • record the details and resolution of the complaint, if needed
  • report the complaint and any issues, actions or improvements, if needed.

If the customer issue/s remain unresolved and if required, the frontline receiving officer will refer the complaint to a Receiving/Investigating Officer for action.

b) Receiving/Investigating Officer

The receiving/investigation officer will:

  • help the customer with making their complaint.
  • assess and classify the complaint.
  • investigate and take action.
  • offer remedies or solutions that are fair and reasonable to all involved.
  • communicate with the customer and meet service standards.
  • explain the process for an internal review or external review, if needed
  • record the complaint from when it was received to when it was finalised.
  • close the complaint and any corrective actions identified.
  • report the complaint and any issues, actions or improvements.

Step 2: Internal review

If the customer is unhappy with the decision made in the first stage, they can request an internal review with us. This request should be submitted within 28 days of receiving the complaint outcome (unless there are reasonable grounds to accept it later) and should be in writing, though we can receive it verbally if necessary.

a) Internal Review Officer

Manages the complaint as outlined in Step 1 and will also:

  • ensure they’re independent of and more senior than the original decision maker.
  • clarify the grounds for the review.
  • undertakes a merits review.
  • explain the process for an external review, if needed.
  • provide the customer with details of external review agencies (such as the Queensland Ombudsman or Queensland Human Rights Commission), if needed.

Step 3: External review

If a customer is unhappy with an internal review decision, they should be advised of their right to contact the Queensland Ombudsman, Human Rights Commission or other relevant external review body (such as the Crime and Corruption Commission) to request consideration of an external review.

a) Nominated staff member

If an external review agency accepts the request and requests information from the department to enable an external review to be conducted, a nominated staff member will:

  • assist the Queensland Ombudsman’s Office, the Queensland Human Rights Commission or other relevant external review body.
  • provide any requested information or copies of complaint documents.

10. Complaints management principles

To achieve our objectives, our complaints management system is based on the following principles.

10.1 People focus

This means we:

  • Treat customers and staff with respect.
  • Recognise that everyone has a right to complain.
  • Recognise that customers have the right to be supported by a friend, advocate, interpreter or community elder.
  • Accept complaints made anonymously and on behalf of someone.
  • Involve the customer in the process if possible and appropriate.
  • Protect privacy and confidentiality.
  • Respect and protect human rights.
  • Ensure customers do not suffer reprisal.

10.2 Visibility and access

This means we:

  • Accept complaints verbally and in writing via a range of formats.
  • Assist customers to make a complaint, in particular children, people with a disability or impairment or from a culturally and linguistically diverse background.
  • Ensure there’s no charge to make a complaint.
  • Publish information about how and where to complain on our website.
  • Ensure complaints information is available upon request from staff and in our public offices.
  • Provide information to staff and raise awareness via a range of communication channels.

10.3 Objectivity and fairness

This means we:

  • Systematically and consistently assess and classify complaints.
  • Disclose any conflict of interest.
  • Identify if any human rights may be relevant to a complaint.
  • Give proper consideration to any relevant human rights before we make a decision.
  • Gather sufficient and relevant evidence to make a decision.
  • Apply natural justice during the investigation.
  • Offer remedies that are fair and reasonable to all parties.
  • Offer similar remedies to all customers in a similar situation.
  • Advise customers about their internal and external review options, if needed.
  • Nominate an independent and more senior officer to conduct an internal review, if needed.
  • May decline or refuse to investigate a complaint that is abusive, trivial or unreasonable.

10.4 Responsiveness

This means we:

  • Where possible, resolve complaints early and informally at the point of service.
  • Take reasonable steps to understand the complaint and assess how best to manage it.
  • Provide an acknowledgement, progress update or response in a timely manner.
  • Provide a clear explanation of any decisions or actions taken.
  • Monitor and record a complaint until it’s finalised.

10.5 Feedback and reporting

This means we:

  • Use complaints information for business and staff development.
  • Undertake quarterly and annual reporting to identify trends and issues.
  • Publish complaints information on our website annually.
  • Seek regular feedback about our complaints management process.

10.6 Accountability

This means we:

  • Ensure responsibilities are clearly outlined to staff.
  • Ensure adequate resources and training are available to staff.

11. Service standards

We aim to address complaints as quickly as reasonably possible.

Where needed, we provide an acknowledgement within five working days and a response within 15 working days. If an issue is complex or involves a human rights complaint, a more detailed investigation may be needed. This may take up to 45 working days and we will keep you informed of progress during that time, as needed.

12. Implementation and review

This policy takes effect 01 April 2022. This policy is reviewed at least triennially to ensure it continues to meet business needs and best practice guidelines. We consider feedback from customers, stakeholders and staff. Ad hoc reviews and audits may occur outside of the scheduled review period in order to evaluate the performance of our complaint management system as set out in the Australia Standard.

We undertake department wide consultation with staff and the Queensland Ombudsman’s Office to obtain suggestions for improvement on this policy

13. Definitions

The following definitions apply to this policy.

Anonymous complaint: The identity of the person making the complaint is unknown.

Branch Complaints Coordinator Network: A complaints management network made up of one or more representatives from each branch.

Complaint: The verbal or written expression of dissatisfaction about the policies, products, projects or services provided by us and/or our staff.

This includes:

  • past, current or proposed policies, products, projects or services
  • past or current staff, including the customer service provided by staff
  • actions or decisions made, including proposing an action, making a recommendation and failing to take an action or make a decision.

Human Rights Complaint: A complaint about an alleged contravention of section 58(1) of the Human Rights Act 2019, that we have:

  • acted or made a decision that is not compatible with human rights; or
  • in making a decision, failed to give proper consideration to a human right relevant to the decision.

Customer: Any person or organisation who would like to make a complaint. This includes a member of the public, stakeholder or staff member acting as a member of the community.

Officer - Internal Review: The staff member nominated to conduct an internal review investigation. They should be independent of and at a more senior level than the original decision maker. They should have the appropriate authority and expertise in their role to:

  • examine, take action on and respond to the grounds of the internal review request; and
  • be able to conduct a merits review (make a fresh determination and decide what is the correct and/or preferable decision); and
  • use judgement or discretion to confirm a previous decision, overturn a previous decision or make a different decision.

Officer - Investigating: The staff member with the appropriate authority and expertise in their role to examine, action and respond to a complaint. They can also be the Receiving Officer.

Officer - Receiving: The staff member that receives and initially assesses a complaint. They determine the likely Investigating Officer/area or can also be the Investigating Officer themselves.

Specific complaint: A complaint that has been categorised as out of scope and excluded from the scope of this policy as it has another avenue for review under particular legislative or contractual requirements.

Staff or staff member: All temporary and permanent employees, consultants, contractors, students or any other person who provides us with services on a paid or voluntary basis.

14. References

  • Commonwealth Ombudsman
    • (2009) Better Practice Guide to Complaint Handling
  • Human Rights Act 2019
  • Human Rights Bill explanatory notes
  • Public Sector Ethics Act 1994
  • Public Service Act 2008
  • Public Service Commission
    • Code of Conduct for the Queensland Public Service (2011)
  • Queensland Human Rights Commission
    • (2019) Guide: Act and make decisions compatible with human rights
    • (2019) Guide: Handling human rights complaints
    • (2019) Guide: How to review policy and procedures for compatibility with human rights
    • (2019) Guide: Nature and scope of the rights
    • (2019) Guide: When human rights may be limited
  • Queensland Ombudsman
    • (2008) Complaints Management Training - Internal Review Officers Workbook
    • (2012) Managing Unreasonable Complainant Conduct Practice Manual, 2nd edition
    • (2005) Practical Administrative Investigation Training Workbook
  • Standards Australia
    • Customer Satisfaction – Guidelines for complaint handling in organizations (AS ISO 10002:2014)
    • Handbook (HB 229-2006) The why and how of complaints handling
  • Transport and Main Roads
    • Employee Complaints Framework
    • Ethics Framework
    • Integrity Framework
    • People Performance Management Framework
    • Recordkeeping Framework
    • Right to Information and Information Privacy Frameworks
    • Risk Management Framework
    • Safety and Wellbeing Framework
Last updated
24 June 2022