ANA Feedback Procedure

Purpose
This procedure explains how members, members of the public and other stakeholders can provide feedback or raise a complaint about matters within ANA's responsibility. It sets out how complaints will be received, considered and responded to fairly, proportionately, consistently and transparently.

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ANA uses feedback and complaints to identify opportunities to improve its governance, policies, systems, services and activities, and to identify concerns relating to compliance with the ANA Ethical Practice Guidelines (AEPG). 

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What is a Complaint?

A complaint is an expression of concern or dissatisfaction about a matter within the scope of this Policy for which the complainant is seeking a response, review or resolution from ANA.

General feedback, suggestions or comments that do not require a formal response or resolution will be treated as feedback rather than as a complaint.

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Scope
This policy applies to complaints related to non-compliance of:

1. ANA Systems and Services: -

   • Specifically concerning membership processes and service delivery. 

2. ANA Ethical Practice Guidelines (AEPG): -

   • Alleged breaches of the AEPG including serious or gross misconduct

How to Make a Complaint

To submit a complaint:

• Email info@appliedneuroscienceassociation.com with the subject line: “Complaint.”

• Provide details of the matter being raised, including relevant dates, individuals or ANA services involved where applicable, and the outcome or resolution being sought.

• Include any relevant information, materials or evidence available to support the complaint.

Complaints Process

1. Acknowledgement:

   • ANA will acknowledge receipt of the complaint via email within 10 working days.

   • The acknowledgement will include the name of the person handling the complaint and a request for additional details, if necessary.

2. Record Keeping:

   • The complaint will be logged in the ANA Feedback Register on the day it is received and its progress and outcome recorded.

3. Initial Review:

   • ANA will review the available information and circumstances, with the aim of resolving matters fairly, proportionately and informally where appropriate.

   • ANA may request further information from the complainant or other relevant individuals where necessary to understand and assess the complaint.

   • Where a complaint concerns an individual, they will normally be given sufficient information about the matters raised and a reasonable opportunity to respond, where appropriate.

   • A person with a material conflict of interest in relation to the complaint will not determine its outcome. Where necessary, ANA will reassign responsibility for handling the complaint or seek appropriate independent input.

   • ANA will aim to complete its initial review within 30 days. Where this is not reasonably possible, the complainant will be informed of the delay and provided with an update on progress.

4. Meeting (if required):

   • Where it may assist in understanding or resolving the complaint, ANA may invite the complainant to a digital meeting during the initial review.

   • A meeting is not required for ANA to reach an outcome.

5. Response:

   • ANA will provide the complainant with a written response following completion of the initial review, whether or not a meeting has taken place.

   • The response will set out the outcome of the complaint and, where appropriate, the reasons for the decision and any action or resolution proposed.

   • The initial review may refer the complaint to informal resolution as an outcome.

   • ANA will aim to provide the written response within 10 days of completing the initial review.

6. Escalation:

   • If dissatisfied with the outcome, the complainant may request a review within 10 days of receiving ANA's written response.

   • The request should explain the reasons for seeking a review, including any concerns about the way the complaint was handled or its outcome, and identify any relevant new information.

7. Secondary Review:

   • Where a secondary review is accepted, it will, where practicable, be undertaken by a person who was not responsible for the initial outcome.

   • The review will consider whether the complaint was handled fairly and proportionately, whether relevant information was appropriately considered, and whether the outcome was reasonable in light of the information available.

   • Further enquiries may be undertaken where further information is needed.

   • ANA will aim to complete the secondary review within 30 days and will provide an update where this timeframe cannot reasonably be met.

   • ANA will provide a written response setting out the outcome of the review. This will constitute ANA's final response under this Policy. 

   • Where a breach of the AEPG is established and disciplinary action is considered appropriate, the matter may be referred to the ANA Disciplinary Procedure.

Remedies

ANA will take appropriate and proportionate action based on the findings of a review process. This may include: 

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Informal Resolution

• a conversation with the individual;

• clarification of expected standards;

• support, guidance or training;

• agreed corrective action;

• an informal written reminder or note of expectations;

• monitoring for an agreed period; or

• mediation or facilitated discussion, where suitable.

Precautionary action

Where necessary, ANA may take precautionary action while a matter is being considered or investigated. This may include temporary suspension from ANA membership, role duties, and restriction of access to ANA platforms.

Precautionary action is not a disciplinary sanction and does not imply that the allegation has been upheld. It may be used where ANA considers it necessary to protect individuals involved, preserve evidence or confidential information, and protect the integrity of the process.

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Disciplinary action

Where a breach of the AEPG is established and disciplinary action is considered appropriate, the matter may be referred to the ANA Disciplinary Procedure.

Any disciplinary action and outcomes will be determined in accordance with that Procedure.

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Confidentiality

ANA will handle information relating to complaints appropriately and with due regard to confidentiality. Information will be shared only where reasonably necessary to consider, investigate or respond to the complaint, or where disclosure is otherwise required or permitted by law.

Personal data will be handled in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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Unacceptable Complaints and Behaviours

ANA expects individuals engaging with the complaints process to communicate respectfully and reasonably.

Where behaviour associated with a complaint is abusive, threatening, persistently unreasonable or otherwise places disproportionate demands on ANA's limited resources, ANA may take proportionate steps to manage the communication or engagement.

This may include limiting the frequency, method or scope of communications, or discontinuing engagement with a complaint where appropriate. Any such action will not prevent ANA from considering legitimate concerns raised through the complaint.

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Repetitive or Vexatious Complaints and Behaviour

A complaint, or behaviour associated with a complaint, may be considered repetitive or vexatious where one or more of the following applies:

1. Harassment, Abuse or Threatening Behaviour

   • Repeated abusive, threatening, intimidating or coercive communications or behaviour towards ANA members, volunteers, staff or others involved in the complaints process.

2. Knowingly False or Bad-Faith Complaints

   • Knowingly providing false or misleading information, or pursuing a complaint primarily to harass, intimidate or cause harm rather than to raise or resolve a legitimate concern.

3. Repeatedly Reopening Concluded Matters

   • Repeatedly raising the same or substantially similar complaint after ANA's complaints process has concluded, without materially new information or evidence that would justify further consideration.

4. Unreasonable or Disproportionate Demands

   • Persistently making demands about the handling of a complaint that are unreasonable or disproportionate, including excessive contact, unreasonable timescales, or repeated demands for action that falls outside ANA's responsibilities or this Policy.

5. Failure to Engage Reasonably with the Complaints Process

   • Persistently refusing to provide information reasonably required to consider the complaint while continuing to demand an outcome or otherwise using the complaints process in a way that prevents reasonable consideration or resolution of the matter. 

Response to Vexatious Complaints:

ANA reserves the right to limit, pause or discontinue engagement where a complaint, or behaviour associated with it, is reasonably considered repetitive, abusive, malicious or vexatious following appropriate review.

Any restrictions imposed will be proportionate to the circumstances and may include limiting the frequency, method or scope of communications.

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Review Process

Before a complaint or associated behaviour is classified as repetitive or vexatious, the circumstances will be reviewed fairly and, where practicable, by someone other than the person directly involved in the communications concerned.

The reasons for any resulting restriction on communication or engagement will normally be communicated to the complainant.

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Protection Against Retaliation

ANA will not tolerate retaliation against any individual who raises a concern or complaint in good faith, or who participates honestly in the consideration, review or investigation of a complaint under this Policy.

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Legal Rights

This Policy does not affect any legal rights or any right to raise a matter with an appropriate external body or authority where applicable.

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Complaints Outside ANA’s Scope

ANA is not a clinical regulator, emergency service, healthcare provider or statutory authority. It cannot determine criminal or civil liability, provide crisis intervention or legal adjudication, or make clinical determinations concerning diagnosis or treatment. ANA cannot investigate or determine:

• criminal or legal matters that require determination by the police, courts, statutory regulators or other competent authorities;

• clinical diagnosis, treatment decisions or other matters requiring determination by an appropriately regulated healthcare professional or body;

• the professional competence or practice of individuals who are not subject to ANA's professional or ethical standards;

• matters relating solely to organisations, services or individuals over which ANA has no responsibility or applicable professional remit;

• complaints that have completed ANA's complaints and review process, unless materially new information or evidence is provided.

Where a complaint includes matters outside ANA's remit alongside matters that fall within it, ANA may consider those aspects for which it has responsibility and, where appropriate, direct the complainant to a relevant body for matters outside its remit.

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Nothing in this section prevents ANA from considering an allegation that the conduct of an ANA member may have breached the AEPG, where the AEPG applies. Use of, or reliance upon, information provided through ANA's services, systems and resources remains subject to the ANA Terms of Use.