How to Create a Complaints Policy

Why a complaints policy matters

Every theological institution should maintain a published complaints policy that sets out how students, staff and stakeholders raise concerns and how the institution responds. A well-designed policy promotes fairness, transparency and timely resolution; supports continuous improvement; and reduces the risk of escalation to external bodies.

Complaints policies also help institutions meet expectations for governance and quality assurance by demonstrating clear procedures, responsibilities and record-keeping.

Key principles to include

• Accessibility: Make the policy easy to find and available in plain language.
• Independence and impartiality: Ensure reviewers have no conflict of interest.
• Timeliness: Set realistic timeframes for acknowledgement, investigation and final response.
• Proportionality: Use simpler processes for minor concerns and formal procedures for serious matters.
• Confidentiality: Protect personal data and explain limits to confidentiality.
• Right to appeal: Describe internal review or appeal steps, and whether an external reviewer is available.
• Record-keeping and reporting: Maintain logs of complaints, outcomes and actions taken to reduce recurrence.

Structure: a practical template

1. Purpose and scope: Define who may complain (students, applicants, staff, visitors) and the matters covered.
2. Definitions: Explain terms such as complaint, grievance, informal resolution, and appeal.
3. How to make a complaint: Give contact points, required information and timelines for acknowledgement.
4. Informal stage: Encourage early resolution and explain mediation or informal discussion options.
5. Formal investigation: Describe steps, investigators, evidence collection and decision-making authority.
6. Outcome and remedies: Specify possible outcomes (apology, corrective action, procedural change) and how outcomes are communicated.
7. Appeals: Set out grounds for appeal, who reviews appeals and time limits.
8. External review: Explain whether an external reviewer or ombudsman is available and how to contact them.
9. Monitoring: Explain how complaints feed into quality assurance, reporting to governance bodies and annual review.

Operational considerations

Assign clear responsibilities (e.g. complaints officer, senior officer for appeals) and ensure staff receive training. Protect vulnerable people by offering support and adjustments. Ensure data protection compliance and retain records according to institutional retention schedules. Use anonymised complaints data to inform policy change and staff development.

When to refer externally

Some complaints may involve alleged criminal conduct, child protection, regulated professional conduct, or fraud; these must be referred to the appropriate statutory authority and may be paused internally while investigations proceed. Where an impartial external reviewer or ombuds service exists, inform complainants how to access that route after internal options are exhausted. Institutions must not present ITAA accreditation as a substitute for statutory complaint routes or governmental oversight.

Communicating the policy

Publish the policy on your website, include it in student handbooks and induction, and provide clear contact details for the complaints officer. Use simple flowcharts for student-facing summaries and ensure alternative formats are available for accessibility needs.

Maintaining trust and continuous improvement

Report anonymised complaints trends to the board or governors and include corrective actions in annual quality reports. Review the policy regularly (for example, annually) and after any significant case to capture lessons learned and evidence institutional learning.

Sample quick checklist

• Is the policy publicly available and easy to find?
• Are timeframes and contact points clear?
• Does the policy describe informal and formal stages?
• Is appeals handling independent of the original decision-maker?
• Are data protection and confidentiality addressed?
• Is there signposting to external bodies where appropriate?

ITAA's Role and final notes

The International Theological Accreditation Association (ITAA) expects accredited institutions to publish a clear complaints policy and to use complaints data in quality assurance. ITAA provides guidance and may review policy implementation as part of its standards and evaluation processes. ITAA accreditation is non-governmental and does not replace any legal or statutory complaint routes; institutions remain responsible for complying with all applicable laws.

For further institutional guidance and related resources, see ITAA Standards, Process & Requirements, Applications, the Knowledge Centre and Contact & Verification pages.