Complaints Policy

1. Policy Statement

Raiys regards every complaint, concern, or expression of dissatisfaction received from a service user, their representative, or any other person affected by its services as an important and genuinely valuable source of information about the quality, safety, and experience of the care it provides. Raiys is firmly committed to a culture in which feedback of all kinds — including critical feedback — is welcomed, respected, and acted upon, and in which the process of raising a complaint is never experienced as burdensome, intimidating, or futile.

Raiys recognises that for many individuals accessing neurodevelopmental services — particularly those with ADHD or Autism Spectrum Condition, who may have extensive histories of being dismissed, misunderstood, or pathologised — the act of raising a complaint requires considerable courage. Raiys therefore commits to ensuring that its complaints handling processes are designed and delivered in a manner that is trauma-informed, neuro-affirming, accessible, and fully respectful of the dignity and communication needs of every complainant.

Complaints are not a threat to Raiys — they are an opportunity. Every complaint received is an opportunity to understand the experience of our service users more fully, to identify where our services have fallen short of the standards we aspire to, and to make the improvements that will benefit every person who accesses our care in the future.

2. Purpose

The purpose of this policy is to establish a comprehensive, clear, and legally compliant framework governing the receipt, acknowledgement, investigation, response, and learning from all complaints received in relation to Raiys services. This policy ensures that:

• Every service user, carer, representative, or other person who wishes to raise a complaint is able to do so easily, safely, and without any fear of adverse consequences for their care or their relationship with Raiys.
• All complaints are handled in a manner that is fair, impartial, prompt, transparent, and proportionate, with every complainant treated with dignity, respect, and compassion throughout the process.
• Complaints processes are accessible and inclusive, with reasonable adjustments made wherever necessary to ensure that neurodivergent complainants — and all other complainants with particular communication or support needs — are not disadvantaged in their ability to raise and pursue a complaint.
• Learning from complaints is systematically captured, shared, and integrated into service improvement processes, in accordance with Raiys commitment to continuous quality improvement.
• Raiys meets and demonstrably evidences compliance with all applicable legal and regulatory requirements relating to complaints handling, including the requirements of HIS, the CQC, and the Patient Rights (Scotland) Act 2011.

3. Scope and Application

This policy applies comprehensively to all complaints received in relation to any aspect of Raiys services. It applies to:

• All service users who are in receipt of, or who have received, any clinical or administrative service from Raiys.
• Representatives, advocates, or carers acting on behalf of a service user, where the service user has provided consent to the involvement of the representative (or, where consent cannot be obtained, where the representative has a legitimate interest in the wellbeing of the service user).
• All members of Raiys workforce — clinical, administrative, and managerial — who have any involvement in receiving, processing, investigating, or responding to complaints.

Complaints may relate to any aspect of Raiys services, including but not limited to:

This policy does not replace or supersede Raiys's Safeguarding Policy, Incident Reporting and Duty of Candour Policy, or any statutory whistleblowing procedures. Where a complaint raises matters that engage any of these policies, the relevant procedures will be activated in parallel with, and without delay to, the complaints handling process.

4. Legal, Regulatory and Professional Framework

5. Principles of Complaints Handling

6. Definition of a Complaint

For the purposes of this policy, a complaint is defined as any expression of dissatisfaction — whether written, verbal, or communicated through a representative — regarding any aspect of the services provided by, or on behalf of, Raiys. Complaints may be raised in relation to:

• The quality, appropriateness, or safety of clinical care or decisions.
• The conduct, attitude, or communication of any member of Raiys workforce.
• Any administrative, operational, or systems failure that has adversely affected a service user's experience.

A complaint is distinct from, though may run concurrently with, a safeguarding concern, a clinical incident, or a formal legal claim. Where a complaint raises matters that engage these other processes, the relevant procedures will be activated in parallel.

7. How to Make a Complaint

Raiys ensures that the process for raising a complaint is clearly communicated to all service users at the point of referral, throughout their clinical journey, and in all relevant service user documentation. Complaints may be raised through the following channels:

Raiys will provide information about how to complain in plain language, in accessible formats, and with reasonable adjustments as required, including the provision of information in alternative formats (e.g. larger print, audio, easy-read) where requested.

7.1 Who to send a complaint to

Every complainant is entitled to know, by name, exactly who is handling their complaint. The current named contact for all complaints is:

This information is also provided directly to every service user at the point of referral and is displayed on the Raiys website. Where the named contact changes, this policy and all published materials are updated within 5 working days.

8. Neuro-Affirming and Trauma-Informed Approach

Raiys is acutely aware that the process of making a complaint can be particularly challenging for neurodivergent individuals. Raiys is committed to ensuring that its complaints handling processes are designed and delivered in a manner that actively mitigates these challenges:

• All staff involved in complaints handling receive specific training in neuro-affirming and trauma-informed communication, enabling them to engage sensitively and effectively with complainants whose presentation, communication style, or emotional responses may differ from neurotypical norms.
• Complainants who experience difficulty in communicating their concerns clearly — whether due to emotional distress, processing differences, or communication challenges associated with their neurodevelopmental condition — will be offered additional time, flexible formats, and support in articulating their concerns.
• Raiys will use clear, structured, and jargon-free language in all complaints communications, and will avoid the use of defensive, dismissive, or technical language that may be perceived as minimising the complainant's concern.
• Complainants will never be made to feel that their communication style, emotional response, or perceived lack of 'reasonableness' in any way undermines the validity of their complaint or diminishes Raiys obligation to address it fully and fairly.

9. Complaints Handling Procedure

9.1 Acknowledgement

Upon receipt of any complaint, Raiys will:

• Acknowledge receipt of the complaint in writing within two working days of receipt (or sooner, in the case of complaints raising immediate patient safety concerns).
• Provide the complainant with the name and contact details of the person responsible for handling their complaint.
• Provide clear information about the expected timescales for the investigation and response, and about the complainant's options if they remain dissatisfied at the conclusion of the process.
• Confirm whether any immediate action has been taken to address the concerns raised, where this is appropriate.

9.2 Investigation

All complaints are investigated in a fair, thorough, and proportionate manner. The investigation process will:

• Be conducted by a person who has no direct personal involvement in the matters complained about, and who has received appropriate training in complaints investigation methodology.
• Gather all relevant evidence, including clinical records, correspondence, staff accounts, and any other documentation or information pertinent to the complaint.
• Include the opportunity for staff members who are named in the complaint to provide a full and accurate factual account of the events in question.
• Assess whether any safeguarding, duty of candour, or incident reporting obligations are engaged, and activate the relevant procedures if so.
• Be completed within a reasonable timeframe, and within the maximum timescales specified in the associated Standard Operating Procedure, with the complainant kept informed of progress at regular intervals.

9.3 Response

Upon completion of the investigation, Raiys will provide the complainant with a clear, full, and written response that includes:

• A clear and honest account of the findings of the investigation.
• An explanation of the actions taken or planned in response to the findings.
• An acknowledgement of any failure in the quality of care or service provided, and a sincere apology where one is warranted, in accordance with Raiys Duty of Candour Policy.
• Information about the complainant's options if they remain dissatisfied with Raiys response, including the right to escalate to Healthcare Improvement Scotland, the Scottish Public Services Ombudsman, the Care Quality Commission, or the Health Service Ombudsman, as applicable.

10. Complaints and Duty of Candour

Where the investigation of a complaint reveals that a service user has experienced harm, or that there has been a failure in care that may have had, or has had, an adverse impact on a service user's health, safety, or wellbeing, Raiys Duty of Candour obligations are engaged. In such circumstances:

• The Registered Manager will ensure that the Incident Reporting and Duty of Candour Policy is activated promptly and in parallel with the complaints response process.
• The service user (or their representative) will receive a direct, in-person or telephone acknowledgement of the issue, a full and honest explanation of what occurred, a sincere and unreserved apology, and clear information about the actions Raiys is taking to prevent recurrence.
• All duty of candour communications and actions will be documented in full in Raiys incident log.

11. Escalation and External Review

Service users who remain dissatisfied with the outcome of Raiys internal complaints process are entitled to seek independent external review. Raiys will ensure that all complainants are informed of the following escalation options at the conclusion of the internal complaints process:

12. Learning from Complaints

Raiys is firmly committed to ensuring that learning from complaints is systematically captured, shared, and translated into tangible improvements to the quality and safety of its services. Raiys learning processes include:

• The maintenance of a comprehensive complaints log that records all complaints received, the outcomes of investigations, and the improvement actions taken in response.
• Regular review of the complaints log by Raiys Clinical Governance Board, with trend analysis to identify recurring themes, systemic issues, and patterns of concern.
• The inclusion of complaints learning in staff briefings, team meetings, clinical supervision, and continuing professional development activities.
• The integration of complaints-driven improvement actions into Raiys Quality Improvement Plan, with clear ownership, timescales, and monitoring arrangements.
• An annual complaints report, which summarises the volume and themes of complaints received, the outcomes of investigations, and the improvements made in response, and which is presented to Raiys Clinical Governance Board and made available to regulatory bodies on request.

13. Roles and Responsibilities