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Insights·Policies & Compliance1 Sept 20266 min readintermediate

Complaints policy for charities and CICs: what funders expect

The minimum viable complaints policy for a small charity or CIC, and why funders now ask for it as standard.

Quick answer

A funder-ready complaints policy names who complaints go to, timescales for response, escalation to the board, external routes (Charity Commission, Fundraising Regulator) and how you learn from complaints. Review every two years.

Why your charity needs a robust complaints policy

As a charity or Community Interest Company (CIC), your primary focus is on delivering a positive impact. Whether you're supporting vulnerable people, protecting the environment, or advocating for a cause, your work is vital. However, even the most well-intentioned organisations can encounter issues. Sometimes, things go wrong, or a service user, volunteer, or member of the public might feel let down.

This is where a robust complaints policy becomes indispensable. It's not just a bureaucratic hoop to jump through; it's a fundamental aspect of good governance, accountability, and continuous improvement. Funders increasingly recognise this and now view a clear, accessible complaints policy as a standard requirement for any organisation they support. It demonstrates that you are professional, transparent, and committed to learning from your experiences.

Think of your complaints policy as a safety net. It provides a structured process for addressing concerns fairly and promptly, turning potential crises into opportunities for growth. It protects your beneficiaries, your staff, your volunteers, and ultimately, your organisation's reputation and mission.

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How this guide is structured

Key takeaways

  • A complaints policy is now a standard funder expectation, signaling good governance and accountability.
  • It provides a structured process for addressing concerns fairly and promptly.
  • Learning from complaints helps improve services and prevent future issues.
  • Review your policy at least every two years, or sooner if significant changes occur.

The core components of a funder-ready complaints policy

At its heart, a complaints policy needs to be clear, concise, and accessible. It shouldn't be overly complex, especially for smaller organisations. Funders aren't necessarily looking for a sprawling document, but rather one that effectively covers key operational elements. The aim is to ensure that anyone with a complaint knows how to raise it, what to expect, and who to turn to if they're not satisfied.

Complaints policy for charities and CICs: what funders expect illustration
Illustration by Serin

Here are the minimum vital components that funders expect to see:

  1. Who to complain to: Clearly state the primary contact person or role for receiving complaints. This could be a specific named individual, a senior staff member, or a dedicated email address. For very small organisations, it might be the Trustee Board itself, initially.
  2. How to make a complaint: Provide clear instructions on how a complaint can be submitted. Options should typically include email, postal address, and potentially a phone number for initial contact. Ensure these methods are easy to find and use.
  3. Timescales for acknowledgement and resolution: Set realistic and clear timelines. For example, complaints should be acknowledged within 3-5 working days and a full response aimed for within 10-20 working days. If more time is needed, commit to explaining why and providing an updated timeline.
  4. What information to include: Guide the complainant on what details will help you investigate effectively, such as their contact information, the nature of the complaint, who is involved, and when the incident occurred.
  5. Confidentiality and GDPR: State that complaints will be handled confidentially, with information shared only on a 'need-to-know' basis. Assure complainants that their data will be processed in line with UK GDPR regulations.
  6. Escalation process (internal): Explain what happens if the complainant is not satisfied with the initial resolution. This typically involves escalating the complaint to a more senior staff member, or for significant matters, directly to the Trustee Board or a designated trustee.
  7. External escalation routes: Clearly signpost external bodies for further recourse, appropriate to your organisation's regulatory framework. This is a crucial element funders look for.
  8. How you learn from complaints: Outline your commitment to using complaints as a learning opportunity. Explain how they are reviewed, what changes might be implemented as a result, and how this feedback loop helps improve services and operations.
  9. Policy review date: Indicate when the policy was last reviewed and when the next review is due. This demonstrates that it's a living document, not just something written once and forgotten.

Signposting external regulatory bodies

One of the most critical elements funders look for is robust external accountability. This means clearly signposting where a complainant can go if they remain dissatisfied after your internal processes are exhausted. The relevant bodies depend on the nature of your organisation and the complaint itself:

Here's a table outlining the primary external routes:

Body Relevant for What they do
Charity Commission (England & Wales) Registered charities / Trustees Oversees registered charities, ensures compliance with charity law. Typically handles serious governance concerns or breaches of trust.
Office of the Scottish Charity Regulator (OSCR) Registered charities in Scotland Similar role to the Charity Commission, but for Scottish charities.
The Charity Commission for Northern Ireland Registered charities in Northern Ireland Oversees charities operating in Northern Ireland.
Fundraising Regulator (England, Wales, NI) Charities that carry out public fundraising Sets and enforces standards for charitable fundraising. Investigates complaints about fundraising practices.
Scottish Fundraising Adjudication Panel Charities fundraising in Scotland Independent body that handles complaints about fundraising practices in Scotland.
Information Commissioner's Office (ICO) All organisations handling personal data Deals with complaints about data protection (GDPR) and freedom of information.
Companies House CIC Limited by Guarantee / Company related concerns Administers company registration, but less involved in service complaints. Relevant for serious company governance issues.

Clearly stating these options demonstrates your commitment to transparency and adherence to UK regulatory frameworks, which greatly reassures potential funders.

Learning and improving: beyond simple resolution

"A complaint is a gift. It's an opportunity to learn, improve, and rebuild trust. Organisations that embrace complaints robustly are often those that flourish long-term."

Serin Insight

A charity that treats complaints merely as problems to be 'got rid of' misses a crucial opportunity. The most successful organisations view complaints as valuable feedback. Each complaint, whether justified or not, offers an insight into your operations, services, or communication.

Your complaints policy should explicitly state how your organisation commits to learning from complaints. This might involve:

  • Regular review of complaint trends by senior management or the Board.
  • Identifying root causes of recurring issues and implementing preventative measures.
  • Using anonymised feedback to inform service delivery improvements or policy changes.
  • Training staff and volunteers based on lessons learned from specific complaints.
  • Reporting on complaint statistics and lessons internally (e.g., to the Board of Trustees) and, where appropriate, externally (e.g., in annual reports, if significant).

Demonstrating this commitment to continuous improvement is a powerful signal to funders that you are a well-managed and adaptive organisation.

Review and accessibility

Why regular reviews are crucial

Charities and CICs evolve. So do regulations, best practices, and your own services. A complaints policy written five years ago might no longer be fit for purpose. Funders expect to see evidence that your policy is a living document, not just something you dusted off from your files.

Your policy should clearly state the date it was last reviewed and when the next review is due. A good practice is to review it at least every two years, or sooner if:

  • There are significant changes to your organisation's services or structure.
  • There are changes in relevant legislation (e.g., data protection, charity law).
  • You identify systemic issues from complaint trends.
  • A new regulatory body emerges or changes its remit.

Making your policy accessible

A fantastic complaints policy is useless if nobody can find it or understand it. Funders will also assess how accessible your complaints policy is. Ensure it is:

  • Easily locatable: Prominently displayed on your website, ideally under a 'Contact Us', 'About Us', or 'Policies' section.
  • Clear and concise: Written in plain English, avoiding jargon.
  • Available in alternative formats: Consider offering it in large print, different languages, or verbally if appropriate for your beneficiaries.
  • Communicated to staff and volunteers: Everyone in your organisation should know where the policy is and understand their role in the complaints process.

An accessible policy reassures funders that you are genuinely committed to resolving issues for all stakeholders.

Next steps

If your charity or CIC doesn't have a modern, comprehensive complaints policy, now is the time to create or update one. Use this guidance to draft a policy that not only meets funder expectations but also strengthens your organisation's accountability and commitment to service excellence. Consider involving a trustee with governance experience in the review process to ensure it's robust and reflects best practice. Getting this right demonstrates professionalism and a foundational commitment to your mission.

Step-by-step

How to do this, step by step

  1. Step 1

    Draft a Simple Policy Statement

    Start with a clear statement that your organisation is committed to handling complaints fairly, promptly, and confidentially. State that all complaints will be taken seriously and used to improve services. This sets a positive and accountable tone.

  2. Step 2

    Outline the Complaints Process

    Describe the step-by-step process for making a complaint, including who to contact initially and what information to provide. Include a timeframe for acknowledging receipt and for providing a full response, typically within 5-10 working days for acknowledgement and 20-30 working days for a full response.

  3. Step 3

    Define Escalation and Review

    Explain what happens if a complainant is not satisfied with the initial response. This should include an option for a senior member of staff or a trustee to review the complaint. Detail how the final decision will be communicated.

  4. Step 4

    Ensure Accessibility and Communication

    State where the policy can be found (e.g., website, office) and how it will be communicated to beneficiaries and stakeholders. Consider offering alternative formats or assistance for individuals who may have difficulty accessing or understanding the policy.

  5. Step 5

    Commit to Learning and Improvement

    Include a section on how complaints data will be recorded, reviewed, and used to identify trends and improve your organisation's services and processes. This demonstrates a commitment to continuous improvement, which funders value.

Practical examples

Simple, Accessible Policy Statement

Our organisation is committed to providing high-quality services. If you are unhappy with any aspect of our work, please let us know so we can put things right and learn for the future. Your complaint will be handled fairly, promptly, and in confidence.

Clear Escalation Process

If you are not satisfied with the initial response to your complaint, you can ask for it to be reviewed by a member of our Board of Trustees. Please make this request in writing within 10 working days of receiving the initial response, explaining why you remain dissatisfied.

Common mistakes to avoid

  • No written policy at all
  • Unclear process for making a complaint
  • Lack of defined timescales for response
  • No escalation route for unresolved complaints
  • Policy not easily accessible to beneficiaries
  • No evidence of learning from past complaints
FAQ

Frequently asked questions

Why do funders care about our complaints policy?+

Funders view a robust complaints policy as evidence of good governance, accountability, and risk management. It demonstrates that your organisation is well-run and takes feedback seriously, protecting both beneficiaries and the funder's investment.

Do we need a formal complaints policy if we're very small?+

Yes, even very small organisations should have a clear, written complaints policy. While it can be simple, it shows commitment to transparency and accountability, which is increasingly a standard expectation from funders regardless of size.

What's the difference between a complaint and feedback?+

A complaint typically involves dissatisfaction with a service, action, or lack of action, requiring a formal resolution process. Feedback is broader, often informal, and can include suggestions or observations that don't necessarily require a formal investigation.

Who should handle complaints in a small charity?+

Initially, a designated staff member or volunteer should handle complaints. For escalation, it's best for a trustee or a senior, independent person to review the matter to ensure impartiality and a fair resolution.

How often should we review our complaints policy?+

Your complaints policy should be reviewed at least annually, or whenever there are significant changes to your services or regulatory requirements. This ensures it remains relevant and effective, and demonstrates good practice.

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