www.publicinvolvement.org.uk

As a partnership we take a close interest in developments in the world of complaint handling in all markets and organisations – not just health. The Partners’ expertise ranges from professional organisations, government departments as well as for-profit organisations.

We research and benchmark different organisations’ approaches to make sure that we are in touch with what is going on in the UK and elsewhere. The brief article below deals with the BBC’s initiative last year where the organisation gave its new complaint handling arrangements considerable publicity to create (or indeed post-Hutton to re-create) confidence less amongst the public than the political class and regulators in both its systems of governance and the quality of its response to individual complainants. Some interesting shifts in power and changes in process emerged. Now read on…

The BBC received by its own account contacts from about 45,000 people complaining about swearing and religious themes before it went ahead and screened the Jerry Springer opera.( By the day after, the Corporation had received 317 calls – half of them in favour.) If it counted these contacts as complaints (after all, the show had not even been broadcast), this would have been quite a test for its relatively new and untested complaint handling system.

The BBC revamped its complaint system in 2004, announcing what it called ‘radical reforms in the way the BBC deals with complaints’. These reforms were to be underpinned by ‘greater transparency, objectivity and accountability’. The reforms maintain the basic shape of the previous complaint handling process offering two entry points and a three stage escalation:-

• Programme/ Audience Services
• Central Complaint Unit
• Governors

and adds some new process and management features.

These are focussed on speed e.g. automatic escalation from the programme after two exchanges of correspondence and early recognition of seriousness giving both the complainant the right to escalate early and the right of the Editorial Complaints Unit (ECU) to take over a complaint – what the BBC called ‘red-flagging’ of complaints “when a complaint is of such gravity that complaints-handling areas may judge it to be in the BBC’s interest to advance to fast track independent investigation by the ECU at an early stage”.

The word ‘independent’ seems to be mis-used in this context – ‘away from the defiant or defensive programme maker’ i.e. ‘more detached’ would be more accurate. However there is a real power of decision given to the Editorial Complaint Unit whose decisions are binding on programme making or output departments.

The concept of independence as it applied to complaint handling was much discussed within the BBC – should the Deputy Director General be the complaints supremo reporting directly to the Board of Governors? Should there be an Ombudsman? The new arrangements reflect a decision to split the management function from the governance function.

The Governors will have their own complaints adviser in the form of the Head of Complaints (Governance) who will monitor the effectiveness of the complaints processes and report directly to the Governor. The Governors’ Programme Complaints Committee (GPCC) will be the final court of appeal.

The BBC management control is now overseen by a new Complaints Management Board chaired by the Deputy Director-General. Its role is to “ensure best practice and that learning from complaints is shared at a senior level”.

The BBC did not choose to appointment an independent ombudsman because the role would duplicate that of the Board of Governors, which represents the public interest.

Learning Points

• Recovering Reputation
  The BBC had in 2004 been in a place where it is to be hoped that any of the organisations you or I work for, never finds itself. The broadcaster post-Hutton had to re-establish political and public credibility and safeguard its own system of governance in the new regulatory environment for broadcasting. In seeking to do this it has certainly adopted a high-profile set of measures that seek to differentiate between management and Governors but do not include a court of final appeal operating wholly outside the organisation. The organisation wishes to be transparent and accountable.
  
  
• Early Diagnosis and Urgent Action
  The new operational measures emphasise early diagnosis of ‘red flag’ cases which can be taken over and managed by a fast track process. This emphasis on correct diagnosis/ differentiation and management of subsequent treatment in a complex organisation with many ‘producers’ is a key feature of best practice complaint handling in this sort of environment.
  
  
• A New Power of Decision
  Equally important is the decision to give a power of decision to the main central complaint handling body which are binding on others such as programme makers. Previously, the Head of the Unit had to get the agreement of the programme-making or output department before finalising any decision to uphold a complaint. Organisational learning will be in the hands of the new Complaints Board backed up by a new central logging system. The BBC Governors as we have commented earlier are the custodians of the broader public interest.
  
  
• A Question of Numbers
  What sort of numbers will this system have to deal with, Jerry Springer-type lobbying campaigns aside? The April to June 2004 report of the BBC Programme Complaints Unit (now the Editorial Complaints Unit) recorded 402 complaints about 210 ‘items’ – an annualised rate of about 1600 per year. This seems low given the high numbers of outputs and large audiences. However the investment in the new system is not just driven by the numbers. The real issue is credibility and the new system in its complexity and (I would guess) expense, reflects that political reality.