PRA Policy on dealing with unreasonable complaints
Commitment to Quality Customer Service & Complaints Procedure
Commitment to quality customer service
The Property Registration Authority (PRA) is committed to providing a Quality Customer Service to all our customers. If a customer is dissatisfied with the service provided s/he may follow our established complaints procedure which is published on our website.
Every effort will be made at local level to deal with the customer’s complaint in a clear and comprehensive manner.
If a customer is not satisfied with the way the complaint has been dealt with locally and/or by the Divisional Manager, s/he may lodge an official complaint to the Customer Services Officer, Property Registration Authority, Corporate Services Section, Chancery Street, Dublin 7. The role of the Customer Services Officer in these cases is to facilitate any member of the public in making a complaint, to ensure that the complaint is dealt with by the most appropriate/senior officer and to issue a comprehensive response.
When a complaint is received by the Customer Services Officer, s/he will write to the Divisional Manager/Senior Manager concerned asking for a comprehensive report on the matter which will allow him/her to deal with the complaint. S/he will then write to the complainant responding to the complaint and cc a copy to the Divisional Manager/ Senior Manager. If the complaint is in relation to a legal issue, s/he will ensure that the matter is first reviewed by a Divisional Manager/Senior Manager/Deputy Registrar as appropriate.
The Customer Services Officer will also advise the customer of their entitlement to address their complaint to the Ombudsman, at Office of the Ombudsman, Lower Leeson Street, Dublin 2, if they feel that their complaint has not been dealt with in a satisfactory manner.
Dealing with Unreasonable Complaints
In a very small number of cases the customer’s behaviour in persisting with their query at Section level or with the Customer Services Officer may become unreasonable. Unreasonable behaviour may take the form of:
- unreasonable persistence in pursuing an argument that has already been addressed or re-framing the complaint to present it as a fresh complaint
- unreasonable demands – examples include seeking an alternative decision on a case that can only be appealed further by taking the case to court, demanding that their case is not to be dealt with by a particular officer (where that officer is the most appropriate officer to deal with the case), demanding that the opening hours of the public office be changed to facilitate their requirements, etc.
- unreasonable lack of co-operation – examples include making multiple queries in relation to the same issue to the same officer or to a number of officers and/or expecting an almost instantaneous response to correspondence
- unreasonable arguments – examples include the customer presenting irrelevant arguments and/or insisting that their interpretation of legal or other issues should be accepted as fact
- unreasonable behaviour – examples include threats of violence, abuse of the PRA’s staff, rude or aggressive conduct, and threats of self-harm.
Such cases can expend a disproportionate amount of time and resources which might be used more effectively.
- If the unreasonable behaviour consists of abusive phone calls or repeated phone calls in relation to a matter that has already been dealt with, a record of the phone calls will be kept in a telephone log.
- Where the customer persists with an issue which has been fully dealt with or behaves in an unreasonable fashion, examples of which are described above, the matter will be referred to a Deputy Registrar (DR).The DR will review the correspondence and the telephone log in relation to the matter and, if appropriate, may decide to commence a progressive disengagement with the customer. If appropriate, the DR will write to tell the customer saying why we believe their behaviour is unreasonable and what action we propose to take. The options we are most likely to consider are:
- requesting contact in a particular form (letters only),
- requiring contact to take place with a named officer,
- restricting telephone calls to specified days and times,
- restricting access to the Office,
- asking the customer to enter into an agreement about their future conduct, and,
- ultimately, terminating all contact with the complainant where the behaviour shows no signs of abating (this decision will be taken at Deputy Registrar (DR) level)
- Where the DR has made a decision to disengage with the customer all PRA staff will be informed of the decision.
All correspondence to the customer will advise the complainant of his/her option to take the matter up with the Ombudsman (or, where a legal matter is concerned, appealing the matter to court).