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Welcome to the Imara Complaints Policy

1. Policy

1.1 Introduction

Imara views complaints as an opportunity to learn and improve for the future, as well as a chance to put things right for the person that has made the complaint.  Imara is committed to providing a high level of service  to clients , children , young people and their families/carers as well as from external agencies.  It is also committed to governing and running the organisation in an ethical manner in line with the requirements of the Charities Commission, the Health & Care Professions Council (HCPC), Play Therapy UK (PTUK), British Association of Art Therapists (BAAT). the Association for Dance Movement Psychotherapy UK (ADMP UK) and the British Association for Counselling and Psychotherapy (BACP)

1.2 Policy Statement

Our policy is:

  • to provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint
  • to publicise the existence of our complaints procedure so that people know how to contact us to make a complaint
  • to make sure everyone at Imara knows what to do if a complaint is received
  • to make sure all complaints are investigated fairly and in a timely way
  • to make sure that complaints are, wherever possible, resolved and that relationships are repaired
  • to gather information which helps us to improve what we do

1.3 Definition of a complaint

A complaint is an expression of dissatisfaction, whether justified or not, about any aspect of Imara

1.4 Complaints covered by this policy

This policy is intended to cover any complaints from individuals external to the organisation about the service provided by the organisation or its representatives.  Complaints may come from any person or organisation who has a legitimate interest in Imara 

This policy is also intended to be used by staff, trustees or volunteers who have a complaint about issues associated with the governance of the organisation. 

Complaints against staff performance or behaviour that are raised by other members of staff, trustees or volunteers are expected to be managed through the appropriate discipline and grievance procedures

1.5 Confidentiality

All complaint information will be handled sensitively, telling only those who need to know and following any relevant data protection requirements

1.6 Responsibility

The Board of Trustees is responsible for ensuring that the Complaints Policy is robust and that it is executed in line with the procedures. The Board is also responsible for managing Stage Two of the Complaints procedure.

Whoever in the organisation received the initial complaint is responsible for ensuring that the complaint is recorded as set out in the procedures below.  Where they can resolve the complaint, they should endeavour to do so.  They are also responsible for ensuring that the CEO of Imara is notified that a complaint has been received.

The CEO is responsible for identifying who will investigate the complaint and for updating the Board that a complaint has been raised.

All staff, volunteers, trustees, and applicants are responsible for participating in the investigation of any complaint:

  • In line with the Complaints Procedure.
  • In as speedy a time as is practicable whilst ensuring that the complaint is thoroughly and effectively managed.
  • Showing integrity and empathy when dealing with complaints.

1.7 Review

This policy is reviewed every 2 years and updated as needed.

2 Implementation of Policy – Complaints Procedure

2.1 Informing individuals of how to complain

The Contact Us page of the Imara website has a section detailing how individuals can raise a complaint with the organisation.  

All clients will be issued with details of how to raise a complaint and the complaints policy.

2.2 Receiving Complaints

Complaints may reach Imara through a variety of channels.  Complaints may be received in writing (by post or email), by telephone or in person.  Whoever receives the initial complaint must attempt to resolve it.  If the complaint has been received by telephone or in person, the person receiving the complaint must:

  • Write down the detailed facts of the complaint.
  • Take the complainant’s name, address, and telephone number.
  • Note down the relationship of the complainant to Imara (for example: client, stakeholder).
  • Tell the complainant that we have a complaints procedure.
  • Tell the complainant what will happen next and how long it will take.
  • Where appropriate, ask the complainant to send a written account by post or by email so that the complaint is recorded in the complainant’s own words.
  • Notify the CEO that a complaint has been received

For further guidelines about handling verbal complaints, see Appendix 1.

2.3 Resolving Complaints

Stage One

In many cases, a complaint is best resolved by the person responsible for the issue being complained about.  If the complaint has been received by that person, they may be able to resolve it swiftly and should do so if possible and appropriate.

Whether or not the complaint has been resolved, the complaint information should be passed to the CEO in the first instance, followed by the Chair of the Board of Trustees within one week.  The CEO should take a decision as to whether the complaint is sufficiently serious to warrant reporting to any external professional bodies or funders e.g. Health Care Professions Council.

On receiving the complaint, the CEO records it in the complaints log.  If it has not already been resolved, they delegate an appropriate person to investigate it and to take appropriate action (the complaint investigator).

If the complaint relates to a specific member of staff, volunteer, or trustee, they should be informed and given a fair opportunity to respond.

Complaints should be acknowledged by the complaint investigator within a week. The acknowledgement should say who is dealing with the complaint and when the person complaining can expect a reply.  A copy of this complaints procedure should be attached.

Ideally the complaint investigator should provide a definitive reply to the complainant within four weeks.  If this is not possible because for example, an investigation has not been fully completed, the complaint investigator should send a progress report to the complainant with an indication of when a full reply will be given.

Whether the complaint is justified or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken because of the complaint.

If a complaint is received from a child/family currently using the Imara service, a decision will be made by the child/family together with Imara as to whether the support from Imara should be suspended whilst the complaint is being investigated. Wherever possible alternative support, internal or external, will be suggested.

Stage Two

If the complainant feels that the problem has not been satisfactorily resolved at Stage One, they can request that the complaint is reviewed at Board level.  At this stage, the complaint will be passed to the Chair of the Board of Trustees.

The Chair of the Board of Trustees should acknowledge to the complainant that the complaint has been escalated within two weeks of receiving the request.  The acknowledgement should say who will deal with the case and when the complainant can expect a reply.

The Chair may investigate the facts of the case themselves or delegate a suitably senior trustee to do so (the trustee investigator).  This may involve reviewing the paperwork of the case and speaking with the person who dealt with the complaint at Stage One.

If the complaint relates to a specific member of staff, volunteer or trustee, the trustee investigator should inform that member of staff etc. that the complaint has been escalated to stage two and given a further opportunity to respond.  They should also inform the person who dealt with the original complaint at Stage One.

Ideally the trustee investigator should respond to the escalated complaint within four weeks.  If this is not possible because for example, an investigation has not been fully completed, the trustee investigator should send a progress report with an indication of when a full reply will be given.

Whether the complaint is upheld or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken because of the complaint.

The decision taken at this stage is final, unless the Board decides it is appropriate to seek external assistance with resolution, for example, British Association of Counselling and Psychotherapy.

If the complaint is of sufficient severity for the Stage One investigation to be completed by a trustee, the Chair of the Board of Trustees may take the decision to provide second stage of complaint investigation.  Where this decision is taken, those involved in the second stage investigation will have not been involved in the first stage investigation.

Stage Three (External Stage)

If complainants wish to pursue a complaint external to Imara there are several options.

i. Complaining to the Charities Commission

Details of how to complain to the Charities Commission can be found at https://www.gov.uk/government/publications/complaints-about-charities/complaints-about-charities.

The Charities Commission expects complainants to raise any concerns with the charity directly and will not get involved in complaints related to:

  • where complainants disagree with decisions made by the trustees and those decisions have been properly made within the law and the provisions of the charity’s governing document
  • to resolve internal disagreements over a charity’s policy or strategy because those involved are responsible for settling the issues themselves
  • about incidents of poor service from a charity where there is no general risk to its services, its clients, or its resources
  • where the complaint arises from a charity dispute and there are properly appointed trustees whose responsibility it is to deal with the issues reported
  • where the issue reported does not pose a serious risk to the charity, its assets, or beneficiaries
  • where the issue is being dealt with by, or is the responsibility of, another statutory or supervisory body
  • where there is a disagreement about the terms or delivery of a contract
  • where legal proceedings are being taken by another party against a charity, including those for the collection of debts (except in a few very rare cases where the Attorney General has specifically asked the commission to do so)

The Charities Commission will consider complaints related to:

  • significant financial loss to the charity
  • serious harm to beneficiaries and vulnerable beneficiaries
  • misuse of a charity for terrorist purposes (including links with or support for terrorism, financial or otherwise, connections to proscribed organisations, misuse of a charity to foster extremism)
  • serious criminality and/or illegal activity within or involving a charity (including fraud and money laundering)
  • charities set up for an illegal or improper purpose
  • charities deliberately being used for significant private advantage
  • where a charity’s independence is seriously called into question
  • other significant non-compliance breaches of trust or abuses that otherwise impact significantly on public trust and confidence in the charity and charities generally

ii. Complaining to a Professional Body

Details of complaining to the Health & Care Professions Council can be found at https://www.hcpc-uk.org/concerns/raising-concerns/

Details of complaining to Play Therapy UK can be found at https://playtherapy.org.uk/About-PTUK/Complaints/PTUKComplaintProcedures

Details of complaining to the Association for Dance Movement Psychotherapy UK can be found at https://admp.org.uk/about-us/membership/documents/

Details of complaining to the British Association for Counselling and Psychotherapy can be found at http://www.bacp.co.uk/prof_conduct/.

2.4 Variation of the Complaints Procedure

The Board may vary the complaints procedure for good reason.  This may be necessary to avoid a conflict of interest, for example, a complaint about the Chair should not also have the Chair as the person leading a Stage Two review.

2.5 Monitoring and Learning from Complaints

Where a complaint has been reported to the CEO, once the complaints procedure has been completed, those involved in the complaints process and as least one other member of staff will undertake a reflective practice session to identify any learning from the complaint.  The conclusions of this session will be documented and where necessary, processes and procedures will be amended to implement any recommendations.  During this review a decision will be taken as to whether any external organisation now needs to be notified that a complaint has been raised or needs to be notified that it has been resolved.

Once a year, the CEO will review all complaints to identify any trends which may indicate a need to take further action.


  1. Complaints about Imara’s therapeutic services should be made within three years of the incident. All other complaints should be made within six months of the incident.
  • In the absence of the CEO, the Chair of Trustees will be forwarded any information received about a complaint.
  • Imara may contact external agencies such as ACAS (Advisory, Conciliation and Arbitration Service) for guidance and support about best practice for dealing with a particular concern or complaint.

Date agreed:  11.09.2021

Review Date: 11.09.2023

Appendix 1 – Practical Guidance for Handling Verbal Complaints

  • Remain calm and respectful throughout the conversation.
  • Listen – allow the person to talk about the complaint in their own words.
  • Don’t debate the facts in the first instance, especially if the person is angry.
  • Show an interest in what is being said.
  • Obtain details about the complaint before any personal details.
  • Ask for clarification wherever necessary.
  • Show that you have understood the complaint by reflecting back what you have noted down.
  • Acknowledge the person’s feelings – you can do this without making a comment on the complaint itself or making any admission of fault on behalf of the organisation e.g. “I understand that this situation is frustrating for you”.
  • However, if you feel that an apology is deserved for something that was the responsibility of the organisation, then apologise.
  • Ask the person what they would like done to resolve the issue.
  • Be clear about what you can do, how long it will take and what it will involve.
  • Don’t promise things you can’t deliver.
  • Give clear and valid reasons why requests cannot be met.
  • Make sure that the person understands what they have been told.
  • Wherever appropriate, inform the person about the available avenues of review or appeal.