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Response to HMCPSI Complaints Review – June 2021

Director of the SFO Lisa Osofsky said: 

“The SFO exists to uphold the rule of law and deliver justice for victims. Our ultimate aim is to provide the best possible outcomes for the public and our open and accessible complaints procedure is a vital part of this.”

“We are committed to ensuring we consistently provide the best service for victims, which means reflecting and adapting our approach as and where necessary.

“We thank the inspectors again for their time and welcome their helpful recommendations on how to further improve our service to the public. We have carefully considered the report’s findings and will act upon the inspectors’ recommendations.”

On 25 February 2021, HMCPSI published a report into the SFO’s complaints policy and complaints handling. The Director of the SFO Lisa Osofsky thanked the inspectors for their helpful recommendations and confirmed we would respond formally in due course so that everyone can see the action the SFO will take. This is our formal response.

The proper handling of complaints is vital to ensuring we consistently deliver a high quality service in our mission to fight complex financial crime, deliver justice for victims and protect the UK’s reputation as a safe place to do business. It is also an important part of our accountability to victims, other stakeholders and the wider public.

We recognise that complaints are a valuable source of feedback and provide an opportunity to improve our service and reputation. Our aim is to have a process that is clear, accessible and well managed so that decisions are taken quickly, things put right where necessary and lessons learnt for the future.

We are pleased that the report acknowledges many positive features of our complaints handling including that:

  • the SFO has the correct culture in place so that staff seek to deal with complaints informally before they progress to a formal complaint;
  • the formal stages of the SFO’s complaints policy are clear and accessible to the public; and
  • the SFO’s responses to complaints are of a high standard overall.

The inspectors also agreed with the decision to uphold or not uphold a complaint in all of the cases examined.

The report makes six recommendations to further improve our complaints handling and identifies several other issues to address. The SFO accepts all the findings and will act upon them within the next two months.

In summary, we will restructure and simplify our approach by removing informal complaints as the first stage of the complaints procedure and implement a two-stage process for all formal complaints. The existing culture of trying to resolve issues informally before having recourse a formal complaint will continue to be encouraged. We will also implement improvements in relation to timescales, signposting, quality assurance and learning from complaints. Further details in relation to each recommendation and issue to address are set out below.

Recommendations

  • The Serious Fraud Office should remove stage 1 from the complaints policy and ensure that, when any correspondence is sent out regarding informal complaints, it contains signposting to the complaints policy

SFO response: We accept this recommendation and will restructure our complaints policy accordingly. We also note the Inspectorate’s positive endorsement of our existing culture of trying to resolve issues informally and will continue to encourage this type of resolution before the formal complaints policy is invoked. Where a complainant remains dissatisfied after an attempt at informal resolution, or the position is unclear, we will add a requirement to signpost the formal complaints policy.

  • The Serious Fraud Office should align the wording on timescales in the internal and external-facing complaints policies, and should make clear to complainants in advance when they can expect a substantive response

SFO response: We accept this recommendation and will revise our internal and external-facing complaints policies to specify timescales for acknowledgment and substantive responses. We will also add a requirement for acknowledgements to include the target date for our substantive response.

  • The Serious Fraud Office should set a target of 28 days for responding to stage 2 and stage 3 complaints

SFO response: We accept this recommendation and will modify our complaints policy to set a target of 28 days for responding to formal complaints and any subsequent request for a further review (stages 1 and 2 under the new structure).

  • The Serious Fraud Office should ensure that a consistent quality assurance process is applied to all complaint responses

SFO response: We accept this recommendation. Quality assurance already takes place on an informal basis and we will codify this practice in our revised complaints procedure to ensure that it is applied consistently to all substantive responses.

(5)(a) The Serious Fraud Office should record the outcomes of complaints and anything done well, or which could be improved

  • SFO response: We accept this recommendation and will incorporate improved record keeping into our revised complaints procedure. This will include recording the outcomes of complaints and any learning points arising – whether from the subject matter of the complaint, the handling of the complaint or both.

(5)(b) The SFO should implement a process to ensure any learning is embedded by changes to policy or guidance documents

  • SFO response: The SFO accepts this recommendation which is essential to harnessing complaints to improve the service we provide. We will implement a process to ensure that we capture and act upon any learning from complaints – whether in relation to the subject matter, handling or both.

(5)(c)  The SFO should consider how best to use learning from previous complaints to forestall future complaints, such as providing better explanations at the outset for why cases are not adopted for investigation

  • SFO response: We accept this recommendation. Most formal complaints received by the office concern decisions not to accept cases for investigation and we will review whether there is scope from improvement around our handling and communication of such decisions.

Issues to address

  • The Serious Fraud Office should provide more detail in the descriptions of the categories of complaint that can be made. It should be apparent to complainants from the outset that all complaints related to the Serious Fraud Office’s decision not to investigate are classified as investigative complaints rather than complaints about the inaction of the Serious Fraud Office

SFO response: In light of the Inspectorate’s findings, we have decided to dispense with the current practice of treating complaints differently depending on their categorisation. We will implement a two-stage process for all formal complaints meaning that a formal complaint concerning a decision not to investigate may proceed to a further review irrespective of how it is classified.

  • The Serious Fraud Office should consider how best to ensure a fair complaints process whilst maintaining proportionality in its response. It should review the process to consider whether all complaints should be allowed to proceed to stage 3, making the formal complaints policy a two-stage process. This should be made clear to complainants in the policy on the Serious Fraud Office website and in complaint responses

SFO response: As outlined at (6), we have considered this issue and decided to implement a two-stage process for all formal complaints including those concerning legal, investigative or operational decisions. Our complaints policy will be revised to reflect this simplified approach and we will signpost the possibility of a further review in substantive responses to formal complaints.

  • The Serious Fraud Office should expressly state in the final response letter that the complaint has been dealt with independently

SFO response: We will add this requirement to our revised complaints procedure.

  • The Serious Fraud Office should acknowledge all complaints at stage 2 and 3 within five working days and ensure that every acknowledgement contains a date by which the complainant can expect a substantive response

SFO response: We will modify our internal and external-facing complaints policies to set a target of five working days for acknowledging formal complaints and any subsequent request for a further review (stages 1 and 2 under the new structure). We will also add a requirement for acknowledgements to include the target date for our substantive response.

  • Complaint responses should indicate whether there is a further stage open to the complainant in the Serious Fraud Office complaints process, and if so, what that is, and whether other agencies may be able to assist

SFO response: We will add these requirements around signposting to our revised complaints procedure.

Good practice 

In line with good practice identified in the report, the SFO will provide a recommended structure to follow when responding to a formal complaint or request for a further review.