PRA Policy on Customer Complaints and Disengagement

1. Commitment to Quality Customer Service

The Property Registration Authority (PRA) is committed to providing a high quality service to all of its customers and service users.  While, the majority of customers are satisfied with the standard of service they receive from the PRA, there may be some who express dissatisfaction, from time to time.  This policy aims to outline how customer complaints should be handled, as well as steps that might be taken, in the event that further engagement with dissatisfied customers is no longer reasonable.

2. What is PRA practice for dealing with a complaint from a customer?

Every effort must be made at local level to deal with all customer complaints in a clear and comprehensive manner.  Customers should refer to the Complaints Procedure available on our website for details of the process to follow in making a complaint. Staff should refer to the “Complaints procedure – guidelines for staff” on the PRA’s Intranet to help them to deal with complaints regarding the standard of service received.  Staff should also follow the principles outlined in the Ombudsman’s Guide to Standards of Best Practice for Public Servants.

At all stages in handling a complaint, PRA staff should:

  1. respond to the issues raised in a systematic fashion;
  2. maintain the use of polite and professional language;
  3. ensure that we understand the issue being raised; and
  4. be clear whether the issue raised is one that is within our remit, and if it is not, notify the customer of the relevant body to contact.

If a customer is not satisfied with the way the complaint has been dealt with locally and/or by the Divisional Manager, they may lodge an official complaint to the Customer Service Officer.

3. Role of the Customer Service Officer

The role of the Customer Service 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 officer and to issue a comprehensive response.  The PRA’s Customer Service Officer is:

Anne Heneghan
Corporate Services
Chancery Street, Dublin 7
D07 T652
email: anne.heneghan@prai.ie
tel: 01 804 8125

When a complaint is received from a customer by the Customer Service Officer, they will write to the relevant Divisional Manager/Senior Manager asking for a comprehensive report on the matter which will allow them to deal with the complaint.  This report should include:

  1. the main issues raised by the complainant;
  2. the facts of the case;
  3. how we have handled / are handling the issue;
  4. any relevant correspondence issued to the complainant (copies to be included); and
  5. consideration by the Divisional Manager/Senior Manager as to whether the service given was of an acceptable standard and if not, details of the measures required to ensure that this type of incident does not re-occur.

The Customer Service Officer may also wish to see any relevant Instruments.  They will also check to see if there has been previous correspondence (e.g. a correspondence file under an S or Q reference number on ITRIS, the PRA’s internal registration system) in relation to the same or a related issue.

On receipt of a report from the Divisional Manager/Senior Manager and having reviewed all relevant Instruments/correspondence, the Customer Service Officer will respond in writing to the complainant.   A copy of this response will issue to the Divisional Manager/Senior Manager.  If the complaint is in relation to a legal issue, the matter will first be reviewed by a Divisional Manager/Senior Manager/Head of Operations, as appropriate.

4. Role of the Ombudsman

In their reply to the complainant, the Customer Service Officer will advise the customer of their entitlement to address the matter to the Ombudsman, Office of the Ombudsman, Lower Leeson Street, Dublin 2, if they feel that their complaint has not been dealt with by the PRA in a satisfactory manner.

Where the complainant writes to the Ombudsman, the Ombudsman’s Office will request a report from the PRA on the matter and will consider whether the customer has good grounds for complaint.  In such cases, it is essential that the PRA can demonstrate to the Ombudsman that all reasonable efforts were made to deal with the complaint promptly and to try to bring the matter to a satisfactory conclusion.  Any comments/reports in relation to the customer’s conduct should be purely factual.  It is important to bear in mind that all such records are subject to Data Protection and/or Freedom of Information legislation and may be the subject of an access request by the data subject.  Such records may also be requested by the Ombudsman in the investigation of a complaint.

5. Unreasonable Behaviour

Handling unreasonable behaviour can take up a disproportionate amount of time and resources which could be more productively used in the public interest. Consequently, it is important to clarify the PRA’s policy in this area.

Unreasonable behaviour may take the form of:

  1. unreasonable persistence in pursuing an argument that has already been addressed or re-framing the complaint to present it as a fresh issue or complaint;
  2. unreasonable demands and lack of cooperation – for example, 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; and making multiple queries in relation to the same issue to the same officer or to a number of officers;
  3. unreasonable arguments – for example, the customer presenting irrelevant arguments and/or insisting that their interpretation of legal or other issues should be accepted as correct and/or
  4. generally unreasonable behaviour – for example, threats of violence, verbal or physical abuse of PRA staff; rude or aggressive conduct; and threats of self-harm.

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 formal record of the phone calls will be kept. The staff member who deals with the call will complete an Incident Report Form which is available on the Intranet and pass this to their manager for logging.

6. Disengagement Process

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 onwards as follows:

 

Type of engagementLocationReferral onwards to
In personPublic officesRelevant local manager
Telephone Call(s)Received by Customer Support Unit

To staff direct line
Customer Support Unit Manager

Divisional Manager
Written Communication(s)Received in any PRA officeHead of Operations

 

  • In Person
    Staff who engage directly with the public may, at times, be required to deal with challenging or difficult interactions.  If this behaviour becomes unreasonable or abusive, the staff member should report the matter to the local manager, who may make the decision to refuse to deal with the customer in person and to restrict access to the PRA’s offices. An alternative method of contact may be suggested e. g. by letter or email.  If such a decision is made, the customer should be informed of the decision by the manager and asked to leave the office.
  • Telephone Calls
    The PRA has in place guidelines for staff for dealing with abusive telephone calls.  This involves three stages, summarised as follows:
    Stage 1 – the caller should be given one warning regarding their behaviour;
    Stage 2 – if the abuse continues, terminate the call in a controlled and polite manner;
    Stage 3 – log the incident by completing an Incident Report Form.

Where abusive/unreasonable telephone calls persist, the abusive caller will be referred to the Customer Support Unit manager or the local Divisional Manager.  Any Incident Report Forms should be forwarded to the Customer Support Unit Manager or local Divisional Manager who will make a decision on whether to consider the caller under the PRA’s Disengagement Process.  Having reviewed the Incident Report Form(s), the Customer Support Unit Manager/Divisional Manager may make the decision to restrict or refuse all telephone contact with the caller.

Where certain types of unreasonable behaviour arise (e.g. threats of self-harm), the PRA will make every effort to manage this behaviour in the most appropriate way through training staff in the SafeTALK programme.  A list of suitably trained staff will be available to Customer Support Unit and callers can be transferred to a staff member with this training when these issues arise.

  • Written Communications 
    In the case of written communications, on the recommendation of the Customer Service Officer, the Head of Operations will review the case (including correspondence and any telephone logs) and, if appropriate, may give a direction on progressing disengagement with the customer.  If appropriate, the Head of Operations will write to tell the customer why we believe their behaviour is unreasonable and the action we propose to take.Possible disengagement options that might be considered include:
  1. requesting contact in a particular form (letters only);
  2. requiring contact to take place with a named officer;
  3. restricting telephone calls to specified days and times;
  4. restricting access to the PRA’s offices; and
  5. asking the customer to enter into an agreement about their future conduct.

Ultimately, and as a last resort, where the behaviour shows no signs of improving, it may be decided to terminate all contact with the complainant – this decision will be taken by the Head of Operations.  Where the Head of Operations 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 their option to take the matter up with the Ombudsman (or, where a legal issue is concerned, appealing the matter to Court).

7. PRA Disengagement Log

Where the Head of Operations has taken a decision to limit interaction with a customer pursuant to this policy, the decision will be recorded on the Disengagement Log, which will be accessible on the PRA’s Intranet.  This will allow staff to be informed of the decision and to act accordingly.  The contents of the log are for internal reference only and will, on no account, be disclosed to anyone outside of the PRA.

8.  Public Sector Equality and Human Rights Duty

Under Section 42 of the Irish Human Rights and Equality Commission Act 2014, all public bodies have an obligation to fulfil the Public Sector Duty which seeks to eliminate all forms of discrimination, to promote equality and protect the human rights of customers, staff and service users and everyone affected by their policies and plans.

The PRA seeks to meet its obligations under the Act and has put in place mechanisms through which the protection of human rights and the promotion of equality can be achieved for customers, staff and service users.  The PRA will give continue to review and report on the fulfilment of its statutory obligations.

 

Appendix

Relevant Documents

This policy should be read in conjunction with the following

PRA Corporate Governance Framework: https://www.prai.ie/download/publications/strategic_reports/Governance%20Framework%20in%20the%20PRA.pdf

PRA Customer Charter and Action Plan 2018-2020:
https://www.prai.ie/customer-charter-and-action-plan/   

PRA Complaints Procedure
https://www.prai.ie/pra-complaints-procedure/

Ombudsman’s Guide to Standards of Best Practice for Public Servants:  https://www.ombudsman.ie/guidance-for-service-providers/guide-to-standards-of-bes/

Freedom of Information Guidelines:
https://www.prai.ie/freedom-of-information/

Data Protection Guidelines:
https://www.prai.ie/data-protection/

Irish Human Rights and Equality Commission Act 2014: http://www.irishstatutebook.ie/eli/2014/act/25/enacted/en/html