We are all complainers now

I'm quite interested in those little, boring bits of policy and governance that often go overlooked in the big stories of the day - like my interest in Community Planning in Scotland. One aspect of this is the public service reform agenda in Scotland. Public sector managers are all over it, but I think outside of their bubble, even politicians aren't that up to speed with it. This includes big things like the creation of the Police Scotland, where it looks like, just as the critics said, the service is being cut and standardised across Scotland. 

As aspect of this I've bumped into is the Public Service Reform (Scotland) Act 2010 (stay with me here, it will get marginally more interesting). This was mainly to do with the creation of Creative Scotland and getting rid of another few commissions. It also gave Scottish Ministers rather sweeping powers to create or destroy various public services in Scotland, but that was kept a bit quiet at the time. However, Part 8 of the Act is now coming home to roost - Scrutiny and Complaints. As you'll guess I'll be focusing on the latter bit.

I first came across this when the the housing association I am on the management committee of had to change its complaints handling procedure. Why did we have to do this. Well, if you scroll down to section 119 you'll discover that the act gives the Scottish Public Services Ombudsman power to create "Complaint Handling Procedures" for services which then have to be adopted. Last year the SPSO "consulted" with housing associations on this. By consulted, I mean they told us this was the procedure we must have. The higher education sector is now waking up to the fact the SPSO have done the same for us and so I spent 45 minutes this morning being told about it.

Basically, this complaints handling procedure is three stage - level 1 deal with it there and then; level 2 escalation to management, level 3 ombudsman. At all levels complaints have to be recorded and then reported. Where this gets interesting is the SPSO's attitude. They've been saying that they expect a lot more level 1 complaints and a lot more complaints ending up with them because of the simplified procedures. This is what a lot of people struggle to understand, but what I find particularly interesting.

The beguiling management logic behind this is the view that "complaints are the best thing we get" which I've heard said by quite a few managers in the private sector and public sector. The logic is that, if we get complaints, we know where our processes and service are not right, so we can improve it. In their attitude to the new complaints procedure the SPSO are applying this to all public services in Scotland. We are all now expected to identify and record level 1 complaints, and the SPSO will be all over us if our reporting levels are low. That their website is valuingcomplaints.org.uk says everything you need to know. As such it's another governance tool being applied in a managerial way; another facet of that suite of targets, outcomes, that are meant to make us all pull our socks up and deliver a better service. The trouble is, the SPSO does not seem to have realised the immense administrative burden on organisations, reeling from staff cuts, that this will cause.

The other interesting aspect of this is what it does to citizenship. The SPSO also expect public services to publicise our complaints procedure, using their standardised wording, and enable complaints to be taken. The three-stage procedure also short-cuts many traditional governance institutions within organisations that had a role intervening in complaints - the Council or a committee; management board; University Court etc. Complaints are now a matter of business administration to be adjudicated by the ombudsman. This is creating us a citizen-complainers. We are all expected to read our standardised complaints leaflets and immediately leap to the nearest person and complain heartily. And you'll no doubt guess what my feelings are about this. 

Beyond those questions of equity though, there is a bigger point about governance in the Foucauldian sense. Now, the SPSO are very clear on what is not a complaint - for example matters of academic judgement are not a complaint, although there may be elements of complaint in, say, a student's appeal. Fair enough. But their definition of a complaint is staggeringly broad:

'An expression of dissatisfaction by one or more individuals about the standard of service, action or lack of action by or on behalf of the Institution'

As with my views on the outcomes focus in the National Performance Framework, I do worry that this is depoliticising what should be political decision-making. The standard of service may be a political decision and to not offer it may be a political decision with implications for equity and outcomes. Reducing these to managerial procedures and processes is very dangerous. Yes, an organisation should listen to the views of service users, but our citizenship should not be based on whether we complain about something.