Our policy and procedure on complaints management has been developed in accordance with the criteria and framework described in the following sources:

Australian Council for Safety and Quality in Health Care. Better Practice Guidelines for Complaints Management for Health Care Services, July 2004.

International Standard. ISO 10002:2004(E). Quality management – Customer satisfaction – Guidelines for complaints handling in organizations, First edition, July 2004.

MP Safety Management is committed to providing health services that are accessible, responsive to needs, safe and cost-effective. In doing so, we aim to control risks to clients, customers and the broader community.

Our approach to health service delivery places the needs and expectations of our clients and customers at the centre – we harness their experiences to evaluate our services and to drive service improvements. Complaints are, therefore, an essential source of information about the quality of our services.

MP Safety Management is committed to the efficient and effective management of complaints for the purposes of:

• Improving our understanding of, and responses to, consumer needs and expectations;
• Managing risks to consumer safety, health, productivity and economic security;
• Controlling the risk of disputation; and
• Building and maintaining trust and consumer confidence in our services.

In upholding our commitment, we have a procedure that makes it easy for consumers to raise concerns about our services, and to provide suggestions for improvement.

We also actively seek consumer feedback to inform improvements in service delivery.

Melanie Parker-Doney

B.App.Sc.OT
Grad. Dip. Ergonomics
Associate Fellow-Personal Injury Education Foundation
Workplace Occupational Therapist
Comcare ID No. 1256

25/08/2020

This email address is being protected from spambots. You need JavaScript enabled to view it.
http://www.mpsm.com.au/

0407 952 731

Complaints Management Procedure

What is a complaint?

A complaint is an expression of dissatisfaction or concern with an aspect of our service.

Who is responsible for managing the complaints management system?

The Managing Director of MP Safety Management is responsible for managing all aspects of the complaints management system.

Who is responsible for implementing the complaints management system?

All MP Safety Management personnel are responsible for meeting consumer needs and assuring service quality. That responsibility extends to identifying and responding to complaints.

Who can make a complaint?

A complaint may be made by:

1. the person or agency receiving the service,
2. the authorised representative of that person or agency, or
3. another person or agency that may be affected by the service.

Complaints can also be made anonymously.

How do we inform consumers about the process for making a complaint?

Our complaints management policy and procedure is publicly available in both hard copy and on the internet.

At the commencement of services, clients and customers are made aware of our policy and procedure for managing complaints.

Complaints Management – Key Elements

1. Identifying Complaints

Expressions of dissatisfaction or concern about our services may be evident in the:

• Views raised at the point of service;
• Lodgement of formal verbal or written complaints; and
• Views expressed through client and customer surveys.Point of service response

2. Point of service response

In the interest of preventing conflict or disputes and maintaining the continuum of care, MP Safety Management personnel are required to respond to complaints at the point of service. This involves:

1. acknowledging the nature of the complaint;
2. verifying concerns and expectations with the people involved;
3. gaining participation of the person(s) concerned in problem solving and decision making;
4. agreeing on the action to be taken to resolve the complaint;
5. setting target times in which to complete the agreed action; and
6. keeping case records that describe all of the above.

Complaints that cannot be resolved at the point of service must be referred to the Managing Director.

Complaints that seriously or imminently threaten the safety and/or continuity of service delivery to a given client or customer must be referred to the Managing Director.

3. Internal resolution

a. Acknowledgement of complaint within one working day

Complaints that are not resolved at the point of service or that are lodged formally or by survey are acknowledged with one working day hours of identification.

The Managing Director acknowledges the complaint verbally and then in writing. The acknowledgement describes (i) the nature of the complaint received, and (ii) the complaints management process and what to expect.

b. Gather information from key people

First, the Managing Director consults with the complainant to:

1. explain the Privacy Policy and the nature of information that is required in order to manage the complaint;
2. explain the complaints management process and the action required to make an accurate assessment of the complaint, including timeframes for that action;
3. gather information about the nature of the complaint;
4. establish the person(s) who are central to the complaint;
5. verify the complainant’s concerns and expectations;
6. agree on suitable methods of communication to be used during the complaints management process.

Second, the Managing Director consults with the health professional who was/is responsible for providing the service concerned to:

1. explain/verify the nature of the complaint;
2. convey the complainant’s concerns and expectations;
3. gather information related to the complaint;
4. verify the person(s) who are central to the complaint;
5. review the case file records;
6. establish the concerns and expectations of the health professional; and
7. determine the action to be taken in order resolve the complaint, including timeframes for that action.

Third, the Managing Director will consult with any other person or agency that is central to the dispute to:

1. explain/verify the nature of the complaint;
2. explain the Privacy Policy and the nature of information that is required in order to manage the complaint;
3. explain the complaints management process and the action required to make an accurate assessment of the complaint, including timeframes for that action;
4. gather information about the nature of the complaint; and
5. agree on suitable methods of communication to be used during the complaints management process.

c. Establish resolution Pathway

The Managing Director consults with the complainant to agree on the action to be taken to resolve the dispute.  Where necessary, the Managing director will convene a meeting between the complainant, the health professional delivering the service, and any other key person or agency to negotiate a resolution.

The Managing Director documents the agreed action plan, including the background to the complaint, agreed timeframes for action, review points and communication/feedback methods.

The options available in the event that intended outcomes are not achieved and/or dissatisfaction persists are also explained and documented. Those options include:

• Review of the resolution pathway in consultation with the persons concerned and renegotiation of action to resolve the complaint; and/or
• External resolution
  
  

d. Resolution Outcomes

The Managing Director provides each party with a copy of the agreed action plan.

In cases where the complaint has implications for service delivery broadly, the Managing Director will inform all MP Safety Management personnel of the factors contributing to the complaint and the agreed action. A collective response to controlling the risks associated with the complaint will be developed in the next scheduled team meeting.

e. Complaints management records

All personal and health information is collected and stored in accordance with the MP Safety Management Privacy Policy.

The Managing Director establishes and maintains a record of the complaint on the MP Safety Management complaints database.

Information recorded includes a description of:

1. The complainant’s details;
2. The nature of the complaint;
3. When, where and with whom consultations were held, and details of information gathered;
4. Any case records reviewed;
5. Assessments and decisions made;
6. The reasoning behind those assessments/decisions;
7. Agreed actions and timeframes;
8. Action taken and the outcome of that action.

4. External resolution

Complaints that cannot be resolved internally may be referred to an external body, agency or authority for resolution.

5. Continuous improvement

The MP Safety Management complaints database provides a credible source of information about service quality that assists us with:

• Managing individual and team performance;
• Enhancing clinical governance; and
• Planning and implementing system and service improvements.

PERSONAL INFORMATION PRIVACY POLICY

1. Committed to protecting the privacy of your personal information

MP Safety Management is committed to protecting your privacy and maintaining the confidentiality, currency, accuracy and security of your personal information. It is fundamental to the way we develop trusting and beneficial relationships.

Our commitment is guided by the:

• Commonwealth Privacy Act 1988 and the Australian Privacy Principles;
• Privacy and health records laws of each State and Territory within which we operate; and
• Australian Health Practitioner Regulations and Professional Codes of Conduct.

2. Open & transparent management of your personal information

MP Safety Management will take all reasonable steps to ensure that you are informed about:

• The purposes of collecting, holding, using and disclosing your personal information;
• The type of personal information we are lawfully required to collect from you and any person, organisation or agency; and how we go about collecting that information;
• How we securely hold and use your personal information;
• Any person, organisation or agency to which we are lawfully required to disclose your personal information;
• How you can access your information and, where necessary, have it corrected; and
• How you can make a complaint about how we manage your personal information.

Our Personal Information Privacy Policy is available and can be downloaded from the MP Safety Management website (www.mpsm.com.au)

3. What is Personal Information?

Personal information is any information (including an opinion, photograph or image) that identifies you and is about you. It includes information that may or may not be true; and may or may not be recorded. Common examples of personal information are your name, date of birth, address and phone number, employment history and medical records. Information is no longer personal when it has been de-identified (i.e. when it is no longer possible to identify you).

4. What is Health Information?

Health information is a form of personal information and includes details of your past, present and future physical and mental health or disability.

5. What is Sensitive Information?

Sensitive information is a form of personal information that requires additional privacy protections. It includes information or opinions about your ethnic origin, political and religious beliefs, sexual preferences and criminal history. Health information is sensitive information.

6. Why do we need to collect, hold, use & disclose your personal information?

MP Safety Management is required to collect, hold, use and disclose personal information for the purposes of providing services that conform to the regulations, standards and principles that govern the practices of health practitioners in Australia.

Collection and management of your personal information enables us to:

• Accurately assess your needs;
• Undertake effective activities and services that best meet your needs and interests;
• Continuously improve what we do; and
• Control risks to the safety and health affecting you, other persons and the public.

7. What kinds of personal information do we need to collect?

MP Safety Management is required to collect and hold personal information that is reasonably necessary for and directly relevant to the services we provide.

When collecting your personal information, we will:

• Specify the kinds of information we require;
• Explain the specific purposes of collecting it; and
• Specify the period of time that we will require your information.

We will obtain your consent to collect your personal information.

8. How do we collect & hold your personal information?

Information may be collected by phone or face-to-face interview with you or other authorised persons, use of questionnaires, observation or examination, and review of documents. We then establish and maintain a private and confidential record in both hard copy and electronic form.

Our secure health information management system protects your record against:

• Misuse, interference and loss; and
• Unauthorised access, modification or disclosure.

Protection is ensured through the use of our:

• Secure filing and archiving facilities; and
• Password-encrypted and firewall-secured information and communication system.

9. For how long will your personal information be held?

Your private and confidential record will be securely held and retained for a minimum period of seven years. If, during that time, your record needs to be handed over or transferred to another person, organisation or agency, we will ensure that:

• You are made aware of the reasons for the handover or transfer;
• Unauthorised access, modification or disclosure of your record is prevented; and
• Your record is up to date, accurate and complete.

After seven years, in most cases, we are permitted to either destroy or de-identify your record. For all other non-sensitive personal information, we may destroy or de-identify it when the purposes for which it was collected have expired.

10. How do we use and disclose personal information?

MP Safety Management will only use personal information to conduct business activities and deliver services that meet your needs and interests. This may involve disclosing information (verbally, in printed/written form or electronically) to persons, organisations or agencies that have a legitimate and lawful role in the provision of our services. They may include:

• Medical and health practitioners;
• Your employers – past and present;
• Our contracted advisors and service providers;
• Legal practitioners;
• Government departments and their agencies; and
• Law enforcement agencies.

We will only disclose personal information when:

• You have been made aware and have given us consent to do so; or
• We are lawfully required or authorised to do so; or
• It is necessary to prevent or lessen a serious and/or imminent threat to your life or health (or the life and health of another person).

We shall take all reasonable steps to ensure that the personal information we collect, hold, use and disclose is:

• Accurate;
• Up to date;
• Complete; and
• Relevant to the business activities and services that meet your needs and interests.

11. Giving your consent to the collection, use & disclosure of your personal information

We will seek your express consent to collect and handle your personal information. Express consent means giving your agreement or permission either verbally or in writing. We will keep the record of your consent on your private and confidential record.

When you provide consent, you should be confident that:

• You understand what giving consent means;
• You have been adequately informed about our policy and how it relates to you;
• You are aware of the specific information we require, the specific purposes for which it will be used, and for how long we will require it;
• You are giving your consent on a voluntary basis;
• You are able communicate clearly how you would like us to handle your personal information and any concerns about your privacy.

12. Refusing or withdrawing your consent to collect, hold, use & disclose your personal information

You may refuse or withdraw your consent at any time. You can do this by giving a written or verbal statement, which should include your concerns and reasons. If you are considering refusing or withdrawing your consent, we will discuss your concerns and reasons with you. We will explain your rights and the consequences, if any, of refusing or withdrawing consent for you and other persons, including members of your family. We will discuss alternatives with you in order to address your privacy concerns. For example, you may prefer to specify the kinds of information we can collect, hold, use and disclose, and from/with whom we can collect and disclose your personal information.

If, thereafter, you choose to refuse or withdraw your consent, we cannot rely on your past consent for any future use or disclosure of your personal information. MP Safety Management will be unable to proceed to provide services without consent.

13. How you can access your personal information

MP Safety Management will provide you with access to your personal information on receiving your written or verbal request. First, we will verify your identity. Second, where reasonable and practicable, we will supply the information in the form requested. If we cannot supply the information in the requested form, we will give you a written notice to explain why and the alternatives available.

Exceptions

In certain circumstances, MP Safety Management may be lawfully required or authorised to withhold access to your personal information. For example, we may refuse access to some or all of your personal information when giving access would:

• Be prohibited or denied by Australian law or a court order; or
• Impose a serious and imminent risk to the life, safety or health of any individual and/or to the public; or
• Unreasonably impact the privacy of other persons; or
• Prejudice current or forthcoming legal proceedings or negotiations;
• Prejudice an investigation into unlawful activity or serious misconduct.

We may refuse access if your request for information is found to be frivolous or vexatious.  

If we refuse your request for access, we will give you a written notice to explain:

• The reasons for our decision;
• The kinds of information that can be provided without risk and how, where or from whom they can be appropriately accessed; and
• How a complaint can be made if you are dissatisfied with our response.

14. Correcting your personal information

MP Safety Management will make appropriate corrections to your personal information to ensure that it is accurate, up to date, complete, relevant and not misleading. You may request the correction of your personal information at any time, either verbally or in writing. In doing so, you must provide reasons for the corrections to be made.

Exceptions

In certain circumstances, we may refuse to correct the information as requested. If so, we will give you a written notice to explain the reasons for our decision.

15. For complaints about the privacy of your information

If there is a concern about how we have handled your privacy; and you have been unable to resolve it through discussion with our consultant, you can take your complaint to the Managing Director:

You can lodge your complaint verbally, in writing or by email. The Managing Director will implement our Complaints Management Policy & Procedures to work with you on an agreeable resolution. The Complaint Management Policy & Procedures will be explained to you in full. You can access a copy of them on request. If your complaint cannot be resolved to your satisfaction with the Managing Director, you may lodge your complaint with the Privacy Commissioner through the Office of the Australian Information Commissioner.

Melanie Parker-Doney

B.App.Sc.OT

Grad. Dip. Ergonomics

Associate Fellow-Personal Injury Education Foundation

Workplace Occupational Therapist

Comcare ID No. 1256

Director

This email address is being protected from spambots. You need JavaScript enabled to view it.

www.mpsm.com.au

0407 952 731

25/8/2020