BEHAVIOUR POLICY

Our policy on behaviour which might affect our staff or our work

Introduction

1. We are committed to providing a fair, consistent and accessible service. We believe that everyone who contacts us has the right to be heard, understood and respected. We believe that our staff have the same rights, and we must provide a safe working environment for our staff. We must also ensure the efficient and effective operation of our Scheme, so that we can provide a good service to everyone who is using the Scheme.
2. We may decide to restrict access to our service where we consider someone’s actions or behaviour are likely to have a negative effect on our staff or our work.
3. This policy sets out the kinds of actions and behaviour that may have a negative effect, and what we will do in these circumstances. This policy applies to everyone who interacts or communicates with us, including students, their representatives and higher education providers.
4. We recognise that some people may have difficulties in expressing themselves or communicating clearly, especially when anxious or upset. We also understand that some people may find it difficult to identify what impact their behaviour might have on other people. We will always consider making reasonable adjustments for a disabled person if we are asked to do so - but we may still use the policy if there are actions or behaviours which are having a negative effect on our staff or our work.

Examples of actions or behaviour which may have a negative effect on our staff or our work

Aggressive, offensive or abusive actions or behaviour

5. All our staff have the right not to be subjected to aggressive, offensive or abusive actions, language or behaviour, regardless of the circumstances.
6. These include, but are not limited to: threats, physical violence, personal verbal abuse, derogatory remarks, inappropriate conduct in a video call, and rudeness – whether made to the member of staff directly or elsewhere (including online bullying). Deliberately provocative or inflammatory statements and unsubstantiated allegations can also amount to abusive actions or behaviour. Any behaviour that makes a member of staff feel threatened or uncomfortable during a video call is considered inappropriate.
7. Violence is not restricted to acts of aggression that may result in physical harm. It also includes behaviour or language, whether oral or written, that may cause staff to feel afraid, threatened or abused.

Unreasonable demands or persistence

8. If someone makes unreasonable demands on us or our staff, or is unreasonably persistent, that may have an impact on our ability to review the person's complaint, or the complaints of other people who are using the Scheme.
9. Examples of unreasonable demands may include: requesting responses within an unreasonable timescale; insisting on speaking to or corresponding with a particular member of staff, frequent phone calls, emails, or letters; repeatedly changing the substance of the complaint or raising unrelated concerns; or attending our offices without an agreed appointment.
10. Examples of unreasonable persistence include: continual refusal to accept that a decision has been made in relation to a complaint; insisting that we answer questions when we have done so or explained why we will not; persistent refusal to accept explanations relating to what we can or can't do; sending emails to multiple members of staff; or repeatedly trying to revisit a case through our internal processes, once those processes have come to an end.

Our approach

11. When we consider that a person's actions or behaviour are likely to have a negative effect, we will tell them why and we will give them the opportunity to modify their actions or behaviour. If the actions or behaviour continue, we will take steps to prevent or minimise the negative effects. Wherever possible, we will continue with our review of the person's complaint. We will try to ensure that any action we take is the minimum required to protect our staff and to ensure that they can work effectively.
12. Our staff may either place a caller on hold or end the telephone call if the caller is aggressive, offensive or abusive, or is making unreasonable demands. Staff are accountable for their actions and are required to log all instances of when calls have been terminated, noting the reason(s) for ending the call. All telephone calls to us are recorded for service and training purposes. Our staff may end a video call at any point if they consider conduct or behaviour to be inappropriate or threatening.
13. It may be necessary to apply restrictions to someone’s contact with us. A decision to do this may be taken by any OIA manager. Some of the options that we may consider are:

13.1. To restrict or block future contact from a person. For example, we may:

13.1.1. Limit the person to making telephone calls on a specified day and time per week;

13.1.2. Require that contact is with a specified member of staff only;

13.1.3. Not accept any further telephone or video calls from the person – we will keep at least one other form of contact.

13.2. Require the person to communicate with us through a representative - or a different representative where it is the representative whose behaviour is causing concern.

13.3. Read and file future correspondence but acknowledge or respond to it only if the person is raising new information or making a new complaint.

13.4. Suspend or terminate consideration of a complaint in accordance with the Rules of the Scheme (Rule 16). The person may request reconsideration by another reviewer of a decision to suspend or terminate consideration of a complaint (Rule 16.3). In exceptional cases, we may also decide not to consider a future complaint from the person. We will take into account the impact on them and also whether there is a broader public interest in considering the complaint further.

13.5. Report the matter to the Police or appropriate governing body, or take legal action. In such cases, we may not give the person prior warning of taking that action.

14. We will record any incidents which lead us to take action under this policy, and what action we have taken to address the issue.
15. Anyone who is unhappy with a decision we have made under this policy may submit a complaint to the Head of Leadership Office. S/he will consider it in line with our 'complaints about our service' policy. If the person has requested a decision to suspend or terminate be reconsidered under Rule 16.3, that request will be considered before the Head of Leadership Office considers the service complaint.

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