1. Purpose

The purpose of this policy and procedure is to ensure:

• information about how to provide feedback and make complaints is publicly available and easily accessible
• complainants are supported to provide feedback and make complaints
• persons making a complaint are afforded procedural fairness
• we handle complaints within a reasonable timeframe for responding to and resolving complaints
• we provide options for further action through relevant third parties where complaints are not resolved
• outcomes of complaints are documented and communicated
• feedback and complaints are used to inform continuous improvement to prevent the reoccurrenceDefinitions

Complainant means the person making a complaint, this may be a student, employer, trainer or any other person making a complaint. It is not limited to complaints made by students only.

Complaint generally means negative feedback about services or people which has not been resolved locally.

Policy statement

• Approach to complaints 

International Institute of Technology are open to receiving feedback and complaints. We are committed to providing a fair and transparent complaint handling process. We do this by:

• ensuring there is no detriment to people who complain
• fostering a receptive, blame-free culture that is open to feedback and improvement
• providing a range of avenues through which people may make complaints – e.g. via email or verbally to trainers, the Student Support Officer or other relevant staff.
• Making information on our complaints handling process publicly available on our website and in our Student Handbook providing transparency regarding how complaints and feedback are handled, what complainants can expect and expected timeframes for resolution of complaints.

• Ensuring procedural fairness

International Institute of Technology implement the following mechanisms to ensure procedural fairness when handling complaints:

• the complaint is handled by an unbiased person
• both the complainant and the subject of the complaint (where this is a person) are given an opportunity to be heard and to provide relevant information
• similar complaints are treated in a consistent manner to ensure fairness and reliability in the resolution process
• a person making a complaint will be informed of any outcome or decision before the decision is implemented and will have the option to respond
• The privacy of complainants is protected, and the information included in a complaint is kept confidential.

• Early Resolution of Complaints

In all cases, issues that arise during training and assessment that are the source of frustration or are in dispute, should be resolved at the time they occur between the persons involved. It is often the case that complaints can be avoided by proper communication and respect between persons involved. Where the issue cannot be resolved locally and needs to be appropriately addressed, the complaint is to be made in accordance with the following section.

• Making a Complaint

A complaint may be received by International Institute of Technology in any form and does not need to be formally documented by the complainant in order to be acted on. Complaints may be made by any person. 

The complaints policy must be publicly available. This means that the complaints policy and procedure will be published on the International Institute of Technology website and will be communicated to complainants within the Student Handbook.

Complaints are to be handled in the strictest confidence. No International Institute of Technology representative is to disclose information to any person without the permission of the CEO. A decision to release information to third parties can only be made after the complainant has given permission for this to occur. This permission should be given by providing written consent.

International Institute of Technology shall maintain the enrolment of the complainant during the complaint handling process.

The complainant is entitled to be heard with access to all relevant information and with the right of reply ensuring procedural fairness is applied at every stage of the complaint process.

The complainant may be accompanied and/or assisted by a support person at any relevant meeting. Where the complainant is a child or young complainant, they may be accompanied by a family member or carer at any relevant meeting.

• Communicating the Complaint Handling Policy and Procedure

The complaints handling policy will be:

• Publicly available on the International Institute of Technology Website
• Integrated into the International Institute of Technology Student Handbook
• Included in the International Institute of Technology Policy and Procedure

Complainants are also encouraged to provide feedback to their Trainer, the Student Support Officer or any other International Institute of Technology staff member at any time, as outlined in the Student Handbook and PP4.7 – Continuous Improvement.

• Complaint Handling Timeframe

We are committed to resolving complaints in a reasonable timeframe and without unnecessary delay. While we will respond to all complaints in a timely manner, some complaints may require more urgent attention than others, and some complaints may take longer to resolve than others. 

• Written Acknowledgement – The first step is written acknowledgement by International Institute of Technology no later than 24 hours from the time the complaint is received. This acknowledgement is intended to provide the complainant assurance that International Institute of Technology has received the complaint and will review the relevant issues and provide a response as soon as practical. The acknowledgement must inform the person that they will receive a written response.

• Initial Assessment and Categorisation – International Institute of Technology will triage complaints by classifying complaints based on severity, urgency, and nature, and prioritising cases that need immediate attention. An initial assessment and categorisation of the complaint will be conducted within 2 working days based on:

• Severity: Determine if the complaint involves safety, harassment, discrimination, or legal concerns, which would necessitate urgent action. Less severe complaints could involve general dissatisfaction or requests for improvement.
• Urgency: Consider how soon the issue needs to be resolved. Complaints that could impact ongoing training sessions or reputation may need to be escalated.
• Nature of Complaint: Identify if it’s related to training and assessment, trainer behaviour, administrative issues, or facilities.

Prioritisation
Assign a priority level (e.g., critical, high, medium, low) based on the assessment. For instance:

• Critical: Complaints with legal or safety implications, or those that could harm complainants’ well-being.
• High: Issues with significant impact on training quality or participant experience, such as trainer behaviour or course content.
• Medium: Less urgent issues, like scheduling or minor logistical concerns.
• Low: Minor complaints, often administrative or preference-based, which don’t require immediate resolution.

• Handling the complaint – Complaints that have been categorised as Severe, with a Critical priority rating, will be acted on immediately. The handling of all complaints will commence within seven (7) calendar days of the lodgement of the complaint and all reasonable measures will be taken to finalise the process as soon as practicable. A written response must be provided to the complainant within fourteen (14) calendar days of the lodgement of the complaint.

• As a benchmark, International Institute of Technology should attempt to resolve complaints as soon as possible. A timeframe to resolve a complaint within thirty (30) calendar days is considered acceptable and in the best interest of International Institute of Technology and the complainant.  
• A complainant should also be provided with regular updates to inform them of the process of the complaint handling. Updates should be provided to the complainant at a minimum of two (2) weekly intervals.

Complaints must be resolved to a final outcome within thirty (30) calendar days of the complaint being initially received. Where International Institute of Technology Chief Executive Officer considers that more than 30 calendar days are required to process and finalise the complaint, the CEO must inform the complainant in writing, including reasons why more than 30 calendar days are required, and maintain regular fortnightly contact with the complainant including to explain any further delays.

• Principles of Natural Justice and Procedural Fairness

A complainant is to be provided an opportunity to formally present his or her case at no cost. The principles of Natural Justice and Procedural Fairness must be incorporated into the complaint handling process to ensure that decision-making is fair and reasonable. Natural justice must be observed when it affects the rights, interests or legitimate expectations of individuals. The following principles are to be applied: 

CEO and bias. Where the CEO feels that they may have bias or there is a perception of bias or where the person making the complaint is not satisfied with how the matter has been handled, the complainant is to be referred directly to an independent third-party for consideration and response.

Responding to Allegations. Where a complaint involves one person making allegations about another person, it is a requirement for International Institute of Technology to hear both sides of the matter before making any judgements about the complaint. A person who will be affected by a decision made by International Institute of Technology as a result of a complaint has the right to be fully informed of any allegations and to be provided adequate opportunity to be heard and respond. The person has the right to: 

• Put forward arguments in their favour,
• Show cause why a proposed action should not be taken,
• Deny allegations,
• Call for evidence to disprove allegations and claims,
• Explain allegations or present an innocent explanation, and
• Provide mitigating circumstances (information aimed at reducing the severity, seriousness of something).

International Institute of Technology also has an obligation to fully consider the substance of allegations and the response provided by parties before making a decision. Decisions must be communicated to the complainant and relevant person’s subject of allegations in writing. This is to include advising these persons of their right to seek a third-party review of decisions made by International Institute of Technology.

Referring matters to authorities. Where an allegation is made that involves alleged criminal or illegal activity and it is considered outside the scope and expertise of International Institute of Technology to investigate the matter, then in these circumstances International Institute of Technology reserves the right to report these allegations to law enforcement authorities. Persons related to the matter involving alleged criminal or illegal activity will be advised in writing if this course of action is being taken. 

Third Party Review. Where the person making a complaint is not satisfied with the handling of the matter by International Institute of Technology, they have the opportunity for a body or person that is independent of International Institute of Technology to review his or her complaint following the internal completion of the complaint handling process. Before a person seeks a review by an independent third party, they are requested to first allow International Institute of Technology to fully consider the nature of the complaint and to respond to the person in writing. If, after this has occurred, the person is not satisfied with the outcome, they have the right to then seek a review by an independent third party. To request a review by an independent third party, the complainant should inform the Office Manager of their request who will initiate the process with the Chief Executive Officer. 

In these circumstances, the International Institute of Technology Chief Executive Officer will advise of an appropriate party independent of International Institute of Technology to review the complaint outcome (and its subsequent handling) and provide advice to International Institute of Technology in regard to the recommended outcomes. The independent third-party is required to respond with their recommendations within fourteen (14) working days of their review being requested. This advice is to be accepted by International Institute of Technology as final, advised to the person making a complaint in writing and implemented without prejudice.

Where the International Institute of Technology appoints or engages an appropriate independent person to review a complaint, the International Institute of Technology will meet the full cost to facilitate the independent review. 

• Unresolved Complaints

Once the complaint handling process has concluded, where the person making a complaint is dissatisfied with the outcome of the complaint handling procedure, the person is to be advised that they have the right to refer the matter to any external authority/agency that may be relevant to their complaint. 

The following external agencies are nominated in the first instance as relevant points of referral the person may consider:

• In relation to consumer related issues, the person may refer their complaint to the Office of Fair Trading.
• In relation to the delivery of training and assessment services, the person may refer their complaint to the National Training Complaints Service via the following phone number: 13 38 73 or visit the website at  https://www.dewr.gov.au/national-training-complaints-hotline or alternatively to the Australian Skills Quality Authority at the following website  https://asqaportal.asqa.gov.au/Make-a-Report//?from=tip-off
• In relation to matters relating to privacy, the person may refer their complaint to the Office of the Australian Information Commissioner via the following details: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint  or call on 1300 363 992

This guidance is also communicated to complainants within the Student Handbook and also within the publicly available policies and procedures on International Institute of Technology website. It is expected that the above agencies will investigate the person’s concerns and contact the International Institute of Technology for information. External agencies will typically request a copy of any record of how the complaint was handled from the person. International Institute of Technology is to ensure that the person is provided with a written response that they may use for this purpose.

The International Institute of Technology is to cooperate fully with agencies such as the National Training Complaints Service, the Office of Fair Trading or ASQA that may investigate the handling of a complaint. International Institute of Technology considers that it would be extremely unlikely that a complaint is not able to be resolved quickly within International Institute of Technology internal arrangements.

• Record Management of Complaint Records

Records relating to complaints will be presented in two formats. There will be electronic records in the form of email correspondence and other documents which are communicated electronically and hard copy records which are submitted by the complainant or generated by International Institute of Technology. There is also a record of the complaint maintained within the International Institute of Technology complainant management system. This includes the details about the complaint and a diary log which records the progress of the complaint handling and closure. This record also records identified opportunities for improvement that result from complaints handling. 

All records regardless of their format will be saved in a digital format into a secure folder located on the International Institute of Technology file storage. Each file is to be clearly labelled with the document title or subject and the date of which the document was received or generated. This folder must only be accessible to persons authorised by the Chief Executive Officer. Records stored on the complainant management system are to be accessible only to administrators and managers. 

To ensure records are maintained in a safe and suitable condition, the following is to apply:

• Records must be kept securely to prevent them being accessed by any non-authorised personnel.
• Records must be kept confidential to safeguard information and to protect the privacy of complainants.
• Records must be kept secure to avoid damage by fire, flood, termites or any other pests.
• Electronic data storage must be safe from destruction by fire or flood and should take account of the risk of component failure of a single storage device. Electronic data is also to be backed-up off site.

A correspondence record must be made for each complainant making a complaint. All email and letter communication should be retained with the complainant correspondence record within the complaint handling file.

• Period of retention of Complaints Records

International Institute of Technology is to retain records relating to complaints handling for a minimum of five (5) years. 

• Destruction of Complaints Records

The CEO is the only person who can authorise (in writing) the destruction of complaint handling records. Records are only to be authorised for destruction after the retention period has lapsed. 

Considerations

Procedure

Student Complaint form