East Sussex County Council AQT Complaints Policy Procedure and Practice

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Introduction

This policy sets out how the Apprenticeship and Qualifications Team (AQT) manages, investigates and learns from complaints. It ensures that all concerns are handled promptly, fairly and consistently, in line with East Sussex County Council (ESCC) policy, the Education and Skills Funding Agency (ESFA) Funding Rules, and Ofsted expectations for employer‑providers of apprenticeships.

The purpose of this policy is to:

  • Provide clear, accessible routes for apprentices, employers, staff and stakeholders to raise concerns
  • Ensure that complaints are investigated objectively and without prejudice
  • Protect learners’ rights, welfare and safety
  • Use complaints and feedback to inform continuous quality improvement, including our Self‑Assessment Report (SAR) and Quality Improvement Plan (QIP)
  • Ensure compliance with ESFA and Ofsted requirements relating to governance, learner voice and provider accountability

This policy needs to be read in conjunction with the East Sussex County Council Complaint Handling Policy. This policy is an extension of the ESCC policy and relates to the procedures for complaints relating to the Apprenticeship and qualifications team (AQT). 

The AQT strives to ensure that all learners and employers have a successful and enjoyable experience through the apprenticeship programme.  We have a commitment to our learners and stakeholders to ensure that any complaints they may have about our service are dealt with fairly, efficiently and effectively.  We also recognise that complaints can be used actively to improve our performance.  We take all complaints very seriously whether made in writing, phone or verbally. Whilst we hope it is unlikely that managers, employers and/or apprentices will need to use the complaints procedure, it is important that all relevant parties are familiar with it at the beginning of the programme and apprenticeship coaches will check regularly with their apprentices to ensure they remember how this complaints procedure works.

At induction and through regular contact with learners we make clear to complainants how to contact us when things go wrong and will ensure that we are sensitive to issues of confidentiality.  We also set ourselves a deadline to respond to complaints – acknowledging a formal complaint within 48 hours, investigating within 10 days and responding within 14 days of the initial complaint. Any complaints received are regularly analysed and reported on to senior managers and to the apprenticeship steering group.  

All complaints will be given careful consideration and dealt with fairly, honestly and consistently. The AQT team will provide sufficient opportunity for any complaint to be fully discussed and aims to resolve it through open dialogues and mutual understanding.

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Quality Improvement and Governance

Complaints are a valuable source of feedback and are used to drive continuous improvement. The AQT will:

  • Analyse complaint themes and outcomes quarterly
  • Report findings to the AQT Management Team and Apprenticeship Steering Group
  • Use learning from complaints to inform the SAR, QIP and staff training
  • Review this policy annually to ensure it remains effective and compliant
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Data Protection, Confidentiality and Record Keeping

All complaints will be handled sensitively and in accordance with ESCC data protection policies and UK GDPR requirements.

  • Complaint records will be stored securely and accessed only by authorised staff
  • Information will be shared only where necessary to investigate the complaint or meet statutory obligations
  • Records will be retained in line with ESCC retention schedules
  • Complainants have the right to request access to their personal data

We will always balance confidentiality with our duty to safeguard learners and comply with legal requirements.

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What is a complaint?

A complaint is when you tell us that you are not happy with our services. We regard a complaint as any expression of dissatisfaction about our action or lack of action, or about the standard of service provided by us or on our behalf. Complaints can cover all parts of the services offered by the AQT team.

Informal vs Formal Complaints

We recognise that many issues can be resolved quickly and informally. An informal concern is any issue raised directly with a member of staff that can be resolved through discussion, clarification or minor adjustments.

A concern becomes a formal complaint when:

  • The complainant states they wish to make a formal complaint
  • The issue cannot be resolved informally
  • The matter is serious or involves allegations about staff conduct, safeguarding, discrimination or malpractice

Formal complaints will always be logged, investigated and responded to in line with this policy.

Anonymous Complaints

Anonymous complaints will be considered and investigated where sufficient information is provided. However, our ability to investigate fully or provide an outcome may be limited. Anonymous complaints will still be logged and reviewed as part of our quality improvement processes.

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Behaviour Expectations

We expect all parties involved in a complaint to behave respectfully and professionally. We will not tolerate abusive, discriminatory or threatening behaviour towards staff, apprentices or stakeholders.

Where behaviour becomes unreasonable, the AQT may implement measures to manage communication appropriately, in line with ESCC policy.

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Safeguarding Concerns

Any complaint or concern that suggests a learner may be at risk of harm, abuse or neglect will be treated as a safeguarding matter and managed under the AQT Safeguarding Policy. Safeguarding concerns bypass the standard complaints stages and are escalated immediately to the Designated Safeguarding Lead (DSL).

Where a safeguarding concern is raised:

  • The DSL will take immediate action in line with statutory guidance
  • The complainant will be informed that the issue is being handled under safeguarding procedures
  • Timescales and confidentiality requirements may differ from the standard complaints process
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Policy Context

When does this apply?

This policy applies to learners individually or in a group and stakeholders including members of the local community who use our services.  

It covers any expression of dissatisfaction or concern about:

  • Provisions of Apprenticeships or qualifications affecting applicants, apprentices, employers, stakeholders.
  • Actions or lack of actions by AQT team and its staff.
  • Standards of service or quality of any staff, courses or facilities provided by the AQT team.

This policy does not cover the following;

  • Matters covered by separate policies or procedures; including Equal Opportunities.
    • Where a complaint is made and there is a separate policy the procedure in the relevant policy will be followed.
  •  Assessment decision that are out of our control e.g., those made by External Performance Assessors.
    • The external providers complaints policy will be followed.
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Complaints Involving External Providers or Subcontractors

Complaints Relating to External Providers

Where a complaint relates to an external training provider, awarding organisation or subcontractor, the relevant organisation’s complaints policy will be followed. The AQT will:

  • Support the complainant to access and understand the external provider’s process
  • Monitor the progress and outcome of the complaint
  • Ensure that any themes or risks are reported to the AQT Manager and included in quality monitoring
  • Escalate concerns to the ESFA where appropriate

Location and access to the Policy 

  • For learners and employers:
    • Introduced at induction
    • Summary within the apprentice and employer handbook
    • Summary on the commitment statement
    • By email from aqt@eastsussex.gov.uk . 
  • For staff;
    • The 365 drive – Apprenticeship policies and procedures.     
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Accessibility and Reasonable Adjustments

Accessibility and Support

We are committed to ensuring that all apprentices and stakeholders can raise concerns easily and without disadvantage. We will make reasonable adjustments to support anyone who may need help to make a complaint, including:

  • Providing the policy in alternative formats (e.g., large print, easy read, audio)
  • Allowing complaints to be made verbally, in writing, or with the support of an advocate
  • Providing additional support for apprentices with SEND, learning difficulties, mental health needs or English as an additional language
  • Ensuring that communication needs are identified at induction and reviewed regularly

No complainant will be treated less favourably because they require support to raise a concern.

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ESCC AQT Complaints Procedure

Complaints procedure and how to raise a complaint

This procedure sets out the way in which the East Sussex County Council Apprenticeship and Qualifications Team deals with complaints made about its staff, services or learners, the stages and processes for the complainant and the timeline for complaints to be resolved. 

  • It is intended for use by the ESCC apprenticeship and qualifications learners, parents, employers, former learners and staff. 
  • Before using this procedure, complainants are requested (where appropriate) to talk directly about their dissatisfaction with the individual(s) involved, to see if an informal resolution is possible.  

Where informal resolution is not possible the complainant should contact the following personnel with escalation through the stages as appropriate; 

Stage 1

  • Your trainer or apprenticeship coach – Name and contact details will be given at induction;
    • Your apprentice coach can be contacted at any (reasonable) time to discuss an issue but if they are busy or cannot take your call for whatever reason then leave a message and they will get back in touch as soon as they can. In most circumstances, your workplace will let you call from there provided you seek their permission.
    • If your complaint is about an apprenticeship coach please progress from stage 2.

Stage 2

  • If not satisfied with the response from your trainer / apprenticeship coach or it is about your trainer / apprenticeship coach please contact – Becca (details below) with details of the complaint; Becca.Saiet@eastsussex.gov.uk
  • The lead will log and acknowledge the complaint within 48 hours (if on annual leave an alternative email address will be given). 
  • An investigation will be conducted by the lead within 10 working days of its receipt. 
  • The Lead will pass their finding to the AQT Manager, (who records all complaints centrally) for review, once the centre manager is satisfied that the matter has been robustly investigated, the lead will respond to the complainant within 14 days of the initial complaint with the outcome of the investigation.
  • If the complaint relates to serious staff incompetence or inappropriate behaviour, then the lead and, or the AQT manager will follow and, where appropriate, arrange for an investigation under the ESCC Disciplinary Policy, which will include interviews with the complainant, the individual(s) complained of, and witnesses. 

 Stage 3

  • If the complainant is not satisfied with the response from the relevant lead the next stage is to contact The Apprenticeship and Qualifications Team manager – Angela Wooller angela.wooller@eastsussex.gov.uk  with details of continued dissatisfaction or further information regarding the investigation.
  • The AQT Manager may seek to resolve the complaint based on any further information received.  Following investigation and within 14 days a written response will be produced detailing whether the complaint is upheld or not and detailing action(s) necessary to resolve the issue.

Some issues may be more complex and may therefore require longer to be fully investigated.  Consequently, all timescales given for handling and responding to Stages 2 and 3 may be subject to change.

 Stage 4 

  • If the complainant is not satisfied with the response from the AQT centre manager the next stage will be to contact The East Sussex County Council complaints team –

Find out further information in our Corporate Complaints Process and Policy

Stage 5

  • If the complainant is not satisfied with the response from the East Sussex County Council Complaints team the next stage is to contact The Education and Skills Funding Agency:

 Customer Help Portal.

You can also write by post to:

Complaints Team
Department for Education
Cheylesmore House
Quinton Road
Coventry
CV1 2WT

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