Complaints Policy

 Last Updated: 04/09/2026

This policy sets out Pride In Health’s commitment to handling complaints in a fair, transparent, and responsive manner. It ensures that clients, carers, and service users have a clear and accessible way to express concerns and that the organisation continuously learns and improves from the feedback received.

Complaints will be approached in a person-centred way that seeks to understand what has happened from the complainant’s perspective, the impact on them, what matters to them in resolving the concern, and any individual communication, accessibility or support needs.

Pride In Health is committed to:

• Providing clients and service users with a clear process to raise complaints
• Ensuring all complaints are handled impartially and without fear of retribution
• Promoting transparency, accountability, and service improvement
• Using complaints as an opportunity for reflective practice and service development
• Ensuring complaints are handled in a person-centred way, with complainants listened to and taken seriously, and with respect for their dignity, privacy, identity, communication needs and freedom from discrimination.

This policy applies to complaints raised by:

• Clients and carers accessing Pride In Health services
• Advocates, representatives or other people acting on behalf of a client, with consent where appropriate
• Clinicians or contractors working with Pride In Health
• Volunteers and staff involved in service delivery

Where a concern falls partly within another process, such as safeguarding, clinical incident review, data protection, refund review or another governance process, we may manage those processes alongside the complaint. We will explain this where appropriate and will continue to track the complaint through the complaints process.

• Complaint: An expression of dissatisfaction about our service, administration, communication or clinical care, including concerns about dignity, privacy, identity or discrimination, where the person asks Pride In Health to address it as a complaint or where a response or formal review is reasonably expected. We may also decide that a concern requires formal complaint handling because of its seriousness, safety implications, repetition, or because earlier attempts to resolve the issue have not been successful.
• Complainant: The individual raising the complaint, or an authorised representative (where appropriate consent applies).

• Fairness: All complaints are treated impartially and with respect
• Clarity: Clients are informed of the process and their rights
• Confidentiality: Complaint information is shared only where there is an appropriate need to know for investigation, resolution, advice, governance, safeguarding, legal or regulatory purposes.
• Support and accessibility: Clients are supported throughout the complaints process, including reasonable adjustments, accessible communication and involvement of a representative or trusted person where appropriate.
• Voice and resolution: We will seek to understand the complainant’s concerns, the impact on them and the outcome they are seeking. The requested outcome may not always be possible, but it will be considered and addressed as part of the complaint response.
• Learning: Feedback from complaints informs service improvements, training, and governance
• No disadvantage: A person will not be treated adversely simply because they have raised a complaint, concern or feedback. Making a complaint will not in itself affect access to care or services. This does not prevent Pride In Health from taking proportionate action for separate safety, safeguarding, clinical, payment or behavioural reasons. Where behaviour becomes abusive, threatening or unreasonably persistent, we may set proportionate communication boundaries while continuing to handle the complaint fairly.

• Leadership Team: Oversees complaints policy implementation, reviews themes and learning, and considers serious or escalated complaints.
• Complaints Lead (Quality Assurance role): Coordinates and manages the complaints process, ensures timescales are met, maintains accurate records, and ensures learning and improvements are captured.
• Investigating Lead:For each complaint, Pride In Health will appoint an appropriate Investigating Lead. Depending on the subject of the complaint, this may be the Quality Assurance and Improvement Lead, Operations Lead, relevant department lead, Clinical Lead or another suitably senior person.As a small organisation, we may not always be able to appoint a fully independent investigator. We will manage conflicts of interest and support impartial handling by:
  
  • appointing an investigator who was not directly involved in the matter being complained about wherever possible
  • escalating the investigation to another senior role, including a member of leadership or the Founder, where the Complaints Lead or relevant department lead is implicated or there is a perceived conflict
  • obtaining appropriate senior clinical review for clinical complaints where needed
    Where a complaint concerns clinical assessment, prescribing, monitoring, treatment or another regulated clinical decision, the clinical aspects of the complaint must be reviewed by an appropriately qualified professional with relevant competence and professional authority for the matter concerned. The complaints process does not transfer accountability for clinical judgement to a non-clinical investigator.
  • ensuring that a person does not make findings about their own actions without appropriate independent or senior review
  • documenting any conflict of interest considerations and the steps taken to manage them
• Post-investigation review (internal): If a complainant asks for a review of our handling or decision, a senior team member who was not involved in the initial investigation will conduct that review where possible. 
• Staff and Contractors: Responsible for cooperating with investigations, providing requested information in a timely manner, and supporting a culture of openness and respect.
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We ensure that the complaints process is accessible to all. Reasonable support will be provided to anyone who may need assistance in making a complaint due to language, disability, digital access needs, or other barriers.

Clients can raise a complaint in the following ways:

• Via our online “Share a Concern or Make a Complaint” form (linked in staff email signatures and provided on request)
• By email to: services@prideinhealth.co.uk 
• In another format if required, with support from the team
• If your concern is about privacy or personal data, you can select Privacy/data protection on our complaints form so it is handled under our data protection complaints process.

If a complaint is raised through another Pride In Health communication route, we will take reasonable steps to bring it into the complaints process so that it can be appropriately logged and managed. A person should not have to restart their complaint simply because it was initially raised through a different route.

A client may ask an advocate, representative, family member, friend or other trusted person to support them with their complaint or communicate on their behalf. We may need to confirm the client's consent before discussing confidential information with that person.

We will make reasonable adjustments where needed, including considering communication format, method of contact, accessibility needs or advocate involvement.

Where reasonably practicable, we will ask the complainant how they would prefer us to communicate with them during the process and whether there are any adjustments or support arrangements that would help them participate. We will avoid asking a person to repeat information unnecessarily where it is already available to us.

Anonymous complaints: We will review anonymous complaints and act on them where possible, but we may be limited in what we can investigate or update without contact details.

We aim to respond promptly and keep complainants updated. HIS sets benchmarks for acknowledgement, assessment, and written response timescales, which we mirror for good practice.

Complaints may involve service or administrative matters, clinical care, or both.

Service and administrative complaints may include matters such as appointments, booking, communication, delays, fees and invoicing, accessibility, administration, service delivery or complaint handling.

Clinical complaints may include matters such as assessment, prescribing or monitoring decisions, clinical advice, clinical communication, safety, clinical records or professional standards.

Where a complaint contains both service and clinical issues, we will coordinate the investigation so that the complainant receives a joined-up response, with appropriate clinical input where required.
 

Pride In Health will:

• Acknowledge a complaint within 2 working days of receipt where possible, and no later than 3 working days. Where possible, we will explain who is managing the complaint and what will happen next.
• Triage and assess the complaint within 5 working days of receipt, including identifying whether it concerns service or administration, clinical care, or both. Where the matter can reasonably be resolved quickly, we will aim to support early resolution during this period.
• Provide a written response within 20 working days of receipt where an investigation is required.
• If more time is needed, explain why, provide a revised timescale and keep the complainant appropriately updated. In exceptional circumstances, an extension of up to 10 additional working days may be used where justified.
• Where we need further information from the complainant or another relevant source, explain any effect this has on the investigation timescale and provide an updated expected response date.
• Where a complaint is specifically a data protection complaint, we will also meet the requirements that apply to data protection complaints. Our usual complaint acknowledgement target remains within 2 working days.

Where it would be helpful, we may offer the complainant a call, meeting or written opportunity to clarify their concerns, the impact on them and the outcome they are seeking, and to confirm the issues that will be reviewed. The complainant will not be required to use a telephone or meeting route where they prefer to communicate in writing.

The level of investigation will be proportionate to the nature and seriousness of the complaint.

Where appropriate, we may:

1. clarify the complaint issues, the complainant’s perspective and any impact they have described, the outcome they are seeking, and any relevant communication or accessibility needs
2. review relevant records and evidence, such as correspondence, appointment information, system records, payment information or clinical records
3. seek information from team members, clinicians, contractors or providers involved
4. obtain clinical, safeguarding, information governance or other specialist input where needed
5. consider whether any immediate action is required to protect safety or prevent recurrence
6. make findings and identify any appropriate remedy, learning or improvement action

Where a complaint concerns clinical care, the clinical review should take account of the standards, professional requirements, clinical protocols and guidance relevant to the activity being reviewed. For gender identity healthcare this may include, according to the subject of the complaint, the Healthcare Improvement Scotland Gender identity healthcare Standards, NHS Scotland Gender Identity Healthcare Protocol, NHS Education for Scotland Transgender Care Knowledge and Skills Framework, relevant national endocrine or fertility guidance, and applicable professional regulatory guidance.

These sources will be considered only where relevant to the clinical activity concerned; detailed clinical requirements are not duplicated within this Complaints Policy.

Our response will address the complaint points in clear and respectful language and explain our findings and the reasons for them. Where appropriate, it will acknowledge the impact described by the complainant, explain any remedy, action or learning arising from the complaint, and identify any relevant next steps.

Where something has gone wrong, we will apologise where appropriate. An apology does not in itself amount to an admission of legal liability.

The complaints process is not an emergency or urgent healthcare service.

If there is an immediate risk to life or safety, emergency or urgent healthcare services should be contacted rather than waiting for the complaints process.

Where a complaint identifies an immediate clinical risk, safeguarding concern or other serious safety issue, we may take urgent action alongside the complaint investigation. This may include escalation to the Clinical Lead, Safeguarding Lead or another appropriate senior person, and contact with emergency, safeguarding or other appropriate services where necessary.

A safety, safeguarding or incident review may run alongside the complaint process where appropriate.

Urgent action or referral taken to protect safety does not, by itself, close the complaint. The complaint should continue to be tracked and responded to unless the complainant agrees otherwise or there is another justified reason to close it.

All complaint-related information is managed in accordance with data protection, confidentiality and information governance requirements. Access will be limited to people who need the information to investigate, manage, advise on or oversee the complaint.

Where necessary and lawful, limited information may also be shared with relevant external organisations or advisers, such as insurers, legal advisers, regulators, safeguarding bodies or other organisations involved in resolving or reviewing the matter.

We will:

• Record complaints in our complaints tracker (with restricted access for complaints and governance roles)
• Retain relevant correspondence and evidence in line with our retention approach and data protection requirements
• Separate or restrict access further where a complaint includes particularly sensitive information

Where a complaint identifies a possible factual error in a clinical record, we will review the information and correct it where appropriate.

A disagreement with a clinician's professional opinion does not necessarily mean that the original clinical record should be removed or changed. Where appropriate, additional information or the client's perspective may be added to the record so that the disagreement is appropriately documented.

The complaints record is not a substitute for the clinical record. Where information identified through a complaint materially affects ongoing care, clinical risk or a clinical decision, the responsible clinician must ensure that the relevant information, assessment or outcome is appropriately reflected in the clinical record.

Requests concerning the accuracy of personal data may also be handled under the rights described in our Privacy Policy.

Themes, outcomes and learning from complaints are reviewed through Pride In Health's governance and quality assurance and improvement arrangements, including leadership review where appropriate.

Complaint learning may contribute to service improvement, clinical governance, staff or contractor training, policy or process changes, audit activity and other quality improvement work. Where an improvement action is agreed, this should be recorded and tracked to completion. 

Complaint themes and agreed improvement actions should be linked, where appropriate, to the Service Improvement Log or equivalent quality-improvement record. Relevant clinical learning may also be considered through clinical governance, supervision or multidisciplinary learning arrangements where this can be done appropriately and without unnecessary disclosure of personal information.

This policy will be formally reviewed every 12 months. An earlier review will be considered where a material legal or regulatory change, relevant Healthcare Improvement Scotland or other regulatory finding, significant or recurring complaint theme, or organisational learning materially affects the arrangements set out in this policy or identifies a need for amendment.

Changes will be proportionate to the issue identified.

If we cannot resolve a complaint internally, we will explain any relevant remaining options clearly.

Where Pride In Health is required, able or willing to use an Alternative Dispute Resolution (ADR) process, we will provide appropriate information about that option and explain whether Pride In Health will participate.

Using or declining ADR does not remove any statutory rights or other routes that may be available.

Healthcare Improvement Scotland (HIS) can handle complaints about independent healthcare providers and services that it regulates.

Where Pride In Health or the service concerned is regulated by HIS and this external complaints route applies, a complainant may contact HIS directly. They do not have to complete Pride In Health's internal complaints process before contacting HIS.

Where the HIS external complaints route does not apply to the particular service or circumstances, Pride In Health will explain any other relevant external routes that are available.

Healthcare Improvement Scotland (Independent Healthcare Team)
Gyle Square, 1 South Gyle Crescent, Edinburgh EH12 9EB
Telephone: 0131 623 4342
Email: his.ihcregulation@nhs.scot 

For privacy and data protection complaints, you can also raise a concern with the Information Commissioner’s Office (ICO). Further information about Pride In Health's data protection complaints process, information rights and the ICO route is available in our Privacy Policy.

Pride In Health Complaints form

Data Protection Policy