Unacceptable Client Behaviour Policy

UCBP1.0 Unacceptable client behaviour Policy

1.0 Overview

1.1 At Money Advice Hub, we believe that our clients have a right to be heard, understood and respected.

1.2 We also believe that our staff have the right to work in a safe environment, free from any abuse or harm caused by others.

1.3 We expect all clients to treat our staff with courtesy and respect at all times. This applies to all means of communication, such as verbal, in person and written.

1.4 In a small number of cases the actions of some clients become unacceptable because they involve abuse of our staff and/or our processes.

1.5 We do not view an action as unacceptable, just because a person is forceful or determined. However, we do consider actions that result in unreasonable demands and/or abusive behaviour to be unacceptable.

1.6 All of our staff are supported and encouraged to make individual assessments about any situation arising with a client that they feel uncomfortable in.

1.7 Money Advice Hub promotes a wellbeing culture among its staff, and does not expect any member of staff to feel uncomfortable doing their job.

1.8 There are a range of actions we consider to be unacceptable, which can be best grouped as follows:

  • Aggressive or abusive behaviour;

  • Unreasonable demands and/or unreasonable levels of contact, and;

  • Complaints that are unsubstantiated, vexatious, and/or intentionally disruptive

2.0 Aggressive or abusive behaviour

2.1 We understand that people can become angry when they feel that matters about which they feel strongly are not being dealt with as they wish. If that anger escalates into aggression or abuse towards our staff, we consider that unacceptable.

2.2 Aggressive or abusive behaviour includes language (whether verbal or written) that may cause staff to feel afraid, threatened or abused and may include threats, personal verbal abuse, derogatory remarks and rudeness. We also consider inflammatory statements, remarks of a discriminatory nature and unsubstantiated allegations, to be abusive behaviour. Where a client is aggressive or abusive, we may decide to:

  • Advise the client that we consider their actions offensive, unnecessary and unhelpful and ask them to stop

  • End telephone calls / appointments / meetings

  • Terminate all direct contact with the client

  • Use blocking restrictions on social media platforms

  • Withdraw our service

  • Refer to another organisation

  • Notify the police. This will always be the case if physical violence is used or threatened.

  • Take any other action that we consider appropriate to the circumstances

3.0 Unreasonable demands and / or unreasonable levels of contact

3.1 A demand becomes unacceptable when it starts to impact excessively on the work of our staff, or when dealing with the matter takes up an excessive amount of time and in so doing, disadvantages other clients.

3.2 Where a client is unreasonably demanding, repeatedly contacts us in person, by phone, email etc., contacts various officers about the same issue, raises the same issue repeatedly, or sends us large numbers of documents about which the relevance is not clear, we may decide to:

  • Limit contact to telephone calls from the person at set times on set days

  • Restrict contact to a nominated member of staff who will deal with future calls or correspondence

  • See the person by appointment only

  • Restrict contact to written correspondence only

  • Refuse to deal with further correspondence and return any documents

  • Use blocking restrictions on social media platforms

  • Advise the person that further irrelevant documentation will be destroyed

  • Withdraw our service

  • Refer to another organisation

  • Take any other action that we consider appropriate to the circumstance

4.0 Unreasonable complaints

4.1 Unreasonably persistent complainants may have legitimate complaints but be pursuing them in inappropriate ways, or they may be intent on pursuing complaints which appear to have no substance or which have already been investigated and determined.

4.2 Money Advice Hub will distinguish between people who make a number of complaints because they really think things have gone wrong as a result of a series of service failures, and people who are being unreasonably persistent or otherwise behaving unreasonably.

4.3 We understand that complainants can be frustrated and aggrieved and it is therefore important to consider the substance of the complaint. However, clients sometimes pursue complaints or other issues that treat staff in a way that is unacceptable.

4.4 While we recognise that some complaints may relate to serious and distressing incidents, Money Advice Hub does not tolerate abusive, offensive or threatening behaviour and will take steps to protect staff who are subject to unreasonable behaviour.

4.5 These are some examples of the types of actions and behaviours that might be identified as unreasonable complainant behaviour:

  • Refusing to specify the grounds of a complaint, despite offers of assistance

  • Refusing to cooperate with the complaints investigation process while still wishing their complaint to be resolved

  • Refusing to accept that certain issues are not within the scope of a complaints procedure

  • Insisting on the complaint being dealt with in ways which are incompatible with the adopted complaints procedure or within good practice

  • Making what appear to be groundless complaints about the staff dealing with the complaints, and seeking to have them replaced

  • Changing the basis of the complaint as the investigation proceeds and/or denying statements they have made at an earlier stage. At the same time, we acknowledge that a complainant has a right to challenge our recollection/recording and to clarify how this could be resolved before we categorise the complainant’s behaviour as denying the matter

  • Introducing new information, at a late stage, which the complainant expects to be taken into account and commented on, or raising large numbers of detailed, but unimportant, questions and insisting they are all fully answered

  • Covertly recording meetings and conversations

  • Submitting falsified documents from themselves or others

  • Bringing complaints designed to cause disruption or annoyance or lacking any serious purpose or value

  • Adopting a 'scattergun' approach: pursuing parallel complaints on the same issue with the Money Advice Hub Compliments and Complaints team and a variety of other organisations.

  • Making excessive demands on the time and resources of staff and members with lengthy and/or repeated telephone calls, emails to numerous staff, or detailed letters every few days and expecting immediate responses

  • Behaviour that appears to be deliberately targeted over a significant period of time at one or more members of Money Advice Hub, without good cause

  • Submitting repeat complaints, with minor additions/variations, so the complainant insists they are 'new' complaints which should be put through the full complaints procedure

  • Refusing to accept the outcome decision of a complaint – repeatedly arguing the point and complaining about the decision, with no new evidence

  • Insisting on pursuing unjustified complaints and/or unrealistic outcomes to legitimate complaints. Taking actions that are out of proportion to the nature of the complaint, even when the complaints procedure has been exhausted

  • Behaviour which has a significant and disproportionate adverse effect on Money Advice Hub’s resources and other residents

  • Inappropriate behaviour towards Money Advice Hub staff investigating or involved in the complaint such as inappropriate use of language, aggression or violence

  • Combinations of some or all of the above

4.6 If unreasonable complainant behaviour is identified, we may decide to:

  • Conclude not to uphold a complaint

  • Refuse to accept complaints that are not new complaints

  • Withdraw our service to stop an unhealthy relationship cycle

  • Prevent future access to our service

4.7 This policy does not override any regulatory responsibilities to investigate or report eligible complaints.

5.0 Taking action

5.1 Before we take any action, we will give the client the opportunity to modify their behaviour. If the behaviour continues, we will take action as set out in this document.

5.2 Clients will be told in writing why a decision has been made, what the alternative arrangements will be and the length of time that these restrictions will be in place.

6.0 Who will make a decision?

6.1 In most circumstances, the Chief Executive will make authoritative and final decisions to deal with unacceptable behaviour from a client. Final decisions will only be made after fully analysing the facts of a situation, and hearing from all parties involved. The Chief Executive might also confer with the Treating Customers Fairly (TCF) Director before issuing a decision in writing.

6.2 If it would be inappropriate for the Chief Executive to intervene, such as a conflict of interest, the TCF Director will make authoritative and final decisions to deal with unacceptable behaviour from a client, and may confer with another experienced senior member of staff, or a director of their choosing, if deemed necessary.

7.0 Appeal

7.1 There is no internal right to appeal final decisions regarding unacceptable behaviour, however, any client accessing our regulated debt advice service can escalate a complaint that has exhausted Money Advice Hub’s complaints process to the Financial Ombudsman Service, and/or the CIC Regulator.

7.2 We will cooperate fully with any third parties with legitimate jurisdiction to investigate complaints from its users, regardless of its own final decisions.

8.0 Keeping records

8.1 We will document and internally report all incidents that are relevant to this policy.

8.2 Records will be stored for a minimum of 6 years, any requests for erasure from a client prior to this time frame will be accepted as an anonymisation of your data record, but will not be erased before its expiry date.

9.0 Version Control

Policy Reference UCBP

Version 1.0

Date: Dec 2020

Review Date: Dec 2022

Responsible: CEO