Safeguarding complaints policy and procedure
The Diocese of London take complaints about our work and quality of service in all aspects of safeguarding seriously. We view complaints as an opportunity to learn and improve the support that we offer to parishes. If you are not satisfied with the service you have received, please follow the process below.
Procedure for dealing with complaints regarding the management of safeguarding concerns
- The Diocese of London aims to ensure that all safeguarding concerns are dealt with well, in line with national Practice Guidance and the Diocese of London Safeguarding Policy: Promoting a Safer Diocese.
- In line with that policy, we are committed to doing all that we reasonably can to promote and maintain a safer culture within our diocese, ensuring safer recruitment practices are in place and that safeguarding training is made available to all clergy and Church Officers.
- We are also committed to ensuring that we respond promptly to every safeguarding concern or allegation and to ensure that those who are the subject of safeguarding concerns are treated with respect and dignity and receive appropriate care and support, and that we respond well to those who may pose a present risk to others.
- Many people may be involved in the handling of such concerns or allegations – Archdeacons and Bishops and other clergy, as well as Parish Safeguarding Officers and members of the Diocesan Safeguarding Team.
- We take complaints about our work and quality of service in all aspects of safeguarding seriously. We view complaints as an opportunity to learn and improve the support that we offer to parishes and the wider diocese. If you are not satisfied with the handling of a safeguarding concern or allegation, please follow the procedure below.
- Please note that this procedure is not intended to provide a process for the resolution of safeguarding concerns or allegations. These should be reported to your incumbent, Archdeacon, Bishop, Parish Safeguarding Officer or another appropriate person who will inform the Diocesan Safeguarding Advisor of your concern within 24 hours, seeking guidance in line with House of Bishops’ Practice Guidance.
2 Aims of the procedure
2.1 The procedure laid out below aims to:
- provide a fair procedure which is clear and easy to use;
- be open and transparent about how complaints will be dealt with;
- ensure that all complaints are investigated appropriately;
- ensure that complaints are dealt with in a way that is timely and proportionate;
- ensures that lessons are learned and enable the improvement of safeguarding within the Diocese of London.
3 Guiding Principles
3.1 For the purposes of this procedure, a complaint is an expression of dissatisfaction or concern about the way in which a safeguarding matter has been dealt with by the Diocese of London.
3.2 The complainant must be the person directly affected by the issue or an interested party to the person affected (e.g. a close relative), and not an unrelated third party or wider observer.
3.3 All information will be handled sensitively, sharing information on a ‘need to know’ basis only and with due regard to our obligations under the General Data Protection Regulations.
3.4 Overall responsibility for this procedure and its implementation lies with the Diocese of London, through the Diocesan Safeguarding Steering Group (DSSG), who will receive an annual report of any concerns received, the outcomes and lessons learned.
3.5 This policy will be reviewed periodically as required.
4.1 Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work, e.g. an officer of the diocese or employee of the London Diocesan Fund breaking or proposing to break the law, acting dishonestly in any way, or otherwise seeking to cover up any wrongdoing.
4.2 Such matters should be reported to the General Secretary or the Director of HR and Safeguarding and will be dealt with under the Whistleblowing Policy.
5 Complaints procedure
5.1 In many cases, a complaint is best resolved by the person responsible for the issue that is being complained about or at the closest level to the person/organisation being complained about. For example, in the case of an issue at parish level, by following the parish complaints or safeguarding policy. If your complaint relates to the conduct of a member of the clergy, then it would be appropriate to use the Clergy Discipline Measure, further details of which can be found at https://www.churchofengland.org/about-us/structure/churchlawlegis/clergydiscipline.aspx
5.2 We expect that all reasonable efforts will have been made to resolve a concern swiftly and informally if possible and appropriate. However, we appreciate that this may not always be possible or appropriate and therefore have the following process in order to deal formally with all complaints raised.
5.3 In the first instance, the complaint should be made to the Safeguarding Manager. This can be in writing or by telephone. All telephone conversations will be recorded in writing and shared with the complainant to ensure accuracy. The Safeguarding Manager will confirm that they have received the complaints and that they will respond fully within two working weeks. A copy of this complaints procedure will be supplied.
5.4 Within this timescale, the Safeguarding Manager will do the following:
- make all necessary and appropriate enquiries to establish the substance of the complaint and any attempts already made to resolve the matter informally;
- initiate further discussions or meetings with the complainant if required, to fully understand their issue, seek clarity and be clear on what would constitute a resolution for them;
- speak with any other parties such as may be required in order to ensure that they have the necessary information available to respond to the complaint.
5.5 If it is not possible to respond to your concerns within two working weeks, they will advise you when a response can be expected.
5.6 If necessary, they will determine subsequent actions and where necessary, arrange mediation between the parties concerned.
5.7 It is hoped that an acceptable resolution will be found and that the complaint can be resolved to the complainant’s satisfaction at this level.
5.8 If the complainant is not happy with the proposed resolution of their complaint at stage one, then within two weeks of being notified of the proposed resolution they must inform the Director of Human Resources and Safeguarding of their decision to initiate stage two.
5.9 The Director of HR and Safeguarding will:
- acknowledge receipt of the stage two complaint;
- confirm when a response can be expected. The aim will be for complainants to receive a definitive reply within four working weeks. If this is not possible because, for example, an investigation has not been fully completed, a further letter or email will be sent indicating when a full reply will be given.
- review all documentation and actions taken. Discuss with the complainant the situation from their perspective and why resolution could not be reached. All conversations will be recorded in writing and shared with the complainant for accuracy.
- discuss with the Safeguarding Manager and the Diocesan Safeguarding Team (where appropriate) and consider what an appropriate response and resolution might be, including the appointment of an independent investigator to review the complaint.
- where necessary, take advice from the Diocesan Registrar and other legal and professional advice such as may be required.
5.10 The reply to the complainant within four weeks, where possible, will inform them of the action taken to investigate the complaint, the conclusions from the investigation, and any action to be taken as a result of the complaint.
6 Involvement of other parties in handling the resolution of complaints
6.1 The above process identifies the person who will usually be best placed to deal with complaints about the way in which safeguarding concerns or allegations have been dealt with. Where a complaint is in connection with the Safeguarding Manager, your complaint should be sent to the Director of HR and Safeguarding in the first instance, or if the complaint is about the person in this role then you should contact the General Secretary of the Independent Chair of the Diocesan Safeguarding Steering Group in the first instance. They will seek the guidance of the Diocesan Registrar and such other legal and professional advice as may be required to ensure that we deal with your complaint well.
7 Monitoring complaints and lessons learned
7.1 The Director of HR and Safeguarding will ensure that a log is kept of all complaints received, the timescale of the resolution process and the lessons learned.
7.2 The number, type and outcome of any complaints will be reported once a year to the DSSG so that any trends or further actions deemed necessary can be considered.
8 Referral of serious concerns to the Charity Commission
8.1 If you do not feel that the resolution of your complaint has resolved your concerns and the issues of concern pose a risk of significant harm to the beneficiaries, assets, services or reputation of the Diocese of London or the London Diocese Fund as it’s administrative umbrella, you may refer your complaint to the Charity Commission. Information about the kind of complaints the Commission will consider can be found on their website: https://www.gov.uk/government/publications/complaints-about-charities.
Version 1 approved 27.03.2019.