Customer complaint management policy

WorkCover Queensland’s Customer Complaints Policy explains complaint handling, resolution processes, and available escalation pathways.

Purpose

This Policy outlines how WorkCover Queensland (“WorkCover”) manages customer complaints (“complaints”) or expressions of dissatisfaction that our customers may have in relation to our products, services, team members or the handling of their complaint. It sets out expectations for handling customer complaints including the complaint resolution process, and the internal and external escalation pathways available.

Scope

In Scope

This Policy applies to interactions by or on behalf of the customer that meets the definition of a customer complaint including:

General complaints
Human Rights – Customer Complaints
Victims’ Rights – Customer Complaint
This Policy applies to all employees and contractors of WorkCover.

Out of Scope

Customer complaints do not include the following and are considered out of scope for this Policy:

Corrupt conduct or fraud matters (refer to the Fraud Policy)
Matters regarding public interest disclosures (Public Interest Disclosure Act 2010)
Complaints that seek a different outcome for reviewable decisions (as defined in section 540 of the Workers’ Compensation and Rehabilitation Act 2003) are excluded from this scope (This exclusion applies to the outcome of reviewable decisions only and does not preclude complaints relating to the process undertaken by WorkCover in reaching such decisions.)
Right to Information (RTI) requests pursuant to the Right to Information Act 2009
Employment-related complaints raised by WorkCover employees (refer to the Individual Employee Grievance Policy)
A request for a general service or action that is not in relation to dissatisfaction with WorkCover’s services or products
A statement of overall opinion unless a response or resolution is requested or required.

Statement

This policy adheres to section 264 of the Public Sector Act 2022, is compatible with the Human Rights Act 2019, The Queensland Ombudsman’s guidelines and meets the principles of the Australian Standard 10002:2022 Guidelines for complaint management in organisations.

WorkCover is committed to providing a fair, transparent and consistent process for recording, investigating and resolving complaints, and aims to ensure that concerns are resolved promptly and effectively building trust and accountability with its customers. WorkCover will also use learnings identified through the complaints process to inform ongoing improvements to our products and services.

Guiding Principles

WorkCover’s Policy is guided by its Code of Conduct as well as the following principles:

Customer-Focused - WorkCover will listen to our customers and take the time to understand their concerns throughout the complaints process
Accessibility – WorkCover’s complaints process is free and accessible to all of our customers. Additional support is available should a customer require this through the course of a complaint
Responsiveness – WorkCover will make a genuine attempt to resolve complaints as quickly as possible. Customers (or their representatives) will be kept informed through the course of their complaint and responses will be made within the requisite timeframes in line with this Policy
Fairness and Respect – Customers making a complaint will be treated fairly and with respect throughout the complaints process
Clarity and Transparency – Information on how to make a complaint to WorkCover will be visible and transparent to our customers, and WorkCover is committed to communicating openly with our customers through the course of a complaint
Continuous Improvement – WorkCover will learn from the complaints we receive and use this information to improve our services, products and ways of working.

Types of Customer Complaints

Customer Complaints - General

Customer complaints are interactions by or on behalf of the customer that meets the following definition:

An expression of dissatisfaction made to or about WorkCover related to its products, services, employees or the handling of a complaint, where a response or resolution is explicitly or implicitly expected, or legally required.

Examples of complaints in the WorkCover context include (but are not limited to) the following:

Staff Conduct or Service Delivery
- A customer expresses dissatisfaction with how they were treated by a WorkCover staff member
- A customer feels the service provided was unprofessional, unhelpful, or lacked empathy.
Inaction or Delays
- A customer reports that WorkCover has not responded to their enquiry within a reasonable timeframe
- A customer is frustrated by delays in progressing their claim or receiving updates.
Disagreement with Policy or Process
A customer challenges the fairness or clarity of a WorkCover policy or application of the Workers’ Compensation and Rehabilitation Act 2003 (e.g. eligibility criteria, claim lodgement process, how their premium is calculated or premium charged)
A customer disagrees with how a particular process was applied to their case.

Human Rights – Customer Complaints

The Human Rights Act 2019 requires WorkCover to:

Deliver services in a manner compatible with human rights
Consider human rights in all circumstances
Make decisions that are compatible with human rights
Include the total number of Human Rights complaints received, along with the outcomes of these complaints, in the publicly accessible annual report.

If a complainant alleges a human rights breach by WorkCover or its staff, it will be investigated through the complaint’s process. If no breach is mentioned but potential issues are identified, WorkCover will still investigate.

Victims’ Rights – Customer Complaints

The Victims’ Commissioner and Sexual Violence Review Board Act 2024 (VCSVRBA) sets out the Charter of Victims’ Rights. It defines the rights of a victim which must be upheld by Queensland Public Sector entities and provides direction on the reporting and referral of related complaints.

A complaint about a breach of the Charter of Victims’ Rights is in scope of this policy, however complaints about actions or decisions of the Victims’ Commissioner or Office of the Victims’ Commissioner are out of scope.

Excluded complaints

Occasionally, complaints that meet the definition of a customer complaint under this policy may be excluded from investigation, as listed below.

A complaint where WorkCover has already issued an outcome for the issues raised.
Any complaints that are currently being reviewed by, or for which an outcome has already been issued by an external body, for example the Qld Ombudsman, Office of Industrial Relations, the Human Rights Commission, or by a Court.

If a complaint is found to be misleading, untrue, or the complainant refuses to cooperate with WorkCover’s investigation efforts, the matter will be closed with no further action. Should the complainant agree to cooperate then the complaint may be reponed.

This decision will be made by the Manager, Customer Complaints, and the complainant will be advised in writing that WorkCover will not proceed, or that the matter will be reopened.

Customer Complaints Management Model

WorkCover has adopted the three-level model of complaint management as defined within the Australian Standard 10002:2022. The WorkCover model is as below:

Level 1 - Frontline Complaint Handling - Early Resolution
Level 2 - Formal Complaint Investigation & Internal Review
Level 3 - External Review

Level 1 - Frontline Complaint Handling - Early Resolution

Who: All WorkCover staff
What: Staff are trained and empowered to resolve simple complaints early at first contact
When: Acknowledged at point of interaction; respond within 5 business days
How: Formal written responses are not always required; staff confirm customer satisfaction with response and advise complainants of their escalation pathways
Record: All complaints resolved at level 1 are logged in the Complaint Management System.

Level 2a - Formal Complaint Investigation

Who: Investigator and Reviewer
What: Complaints that are triaged as complex and requiring formal investigation
When: Acknowledged within 3 business days; respond within 30 business days.
How: Formal written response to complaint prepared by the Investigator and approved by the Reviewer
Record: All Level 2 complaints are logged in the Complaint Management System.

Level 2b - Internal Review

Who: Impartial, independent and appropriately delegated staff member
What: An independent, merit-based review of a completed formal complaint decision (request for review to occur within 20 business days of receiving initial outcome)
When: Acknowledge within 3 business days; respond within 20 business days
How: Formal written response prepared by Internal Reviewer and approved by an appropriately delegated officer
Record: All Internal Reviews are logged in the Complaint Management System.

Level 3 - External Review

Who: Any external review body e.g. Queensland Ombudsman, Human Rights Commission
What: If still dissatisfied with our response, customers can contact external review bodies like the Queensland Ombudsman for an independent external review
How: Visit the Ombudsman’s website or call 1800 068 908
Assist: The Complaints team assists the Ombudsman or other review agencies by responding to requests for information.

Detailed steps are included within WorkCover’s Customer Complaint Management Procedures.

Accessibility

WorkCover is committed to supporting our customers who may experience barriers to making a complaint. Support will be made available to customers who may need additional assistance to lodge a complaint. This may include support by a family member, friend, carer, an advocate, a community Elder or independent entity through the course of the complaint.

Support is also available for the following:

Technology – alternative methods of lodging a complaint are available should a customer not have access to technology.
Linguistically diverse - when dealing with customers who have English as a second language, WorkCover operates under the Queensland Government Language Service Policy. This policy deals with access to interpreters and translated information for people from linguistically diverse backgrounds. An interpreter or translator service will be provided in situations where a person has difficulty communicating in English. This includes those who require an interpreter due to hearing impairment (via sign language or Teletypewriter). When a person requests an interpreter (or translation of a document) they will be provided with this service.
Speech or hearing Impairment – the National Relay Service may accessed for customers with a speech or hearing impairment.

Vulnerable Customers

Complaints received from vulnerable customers are immediately elevated and receive the highest level of attention and care. This includes managing the complaint as a level 2 Formal Investigation.

Vulnerable customers are identified as those at risk of:

Self-Harm
Domestic and family violence
Financial distress
A serious and or terminal illness
Victims of crime
Where a delay in addressing the complaint could adversely affect the customer’s basic living conditions.

Where vulnerable customers are identified through the complaints process, the applicable vulnerable customers or self-harm policy and procedures are utilised in parallel with this policy.

All complaints involving vulnerable customers will be prioritised for investigation, acknowledged within 3 business days, and completion within 30 days.

Conduct and Respect

Each complaint will be managed in an equitable manner including customers who display unreasonable or challenging behaviour. This behaviour may include threats of violence towards WorkCover employees and the use of abusive language. In this instance, team members will follow the Zero Tolerance to Customer Aggression Policy.

Unreasonable Complainant Conduct

Unreasonable complainant conduct (UCC) arises when a complainant’s behaviour, because of its nature, frequency, or intensity, unreasonably impacts employees, other complainants, or WorkCover’s operations. Forms of UCC include:

Unreasonable Persistence – prolonged unreasonable contact, which significantly impacts employee wellbeing as well as time and other resources
Unreasonable Demands – issuing unreasonable instructions, escalations or expectations of outcomes
Lack of Cooperation – providing insufficient or irrelevant details, or actively hindering the complaints process
Unreasonable Arguments – irrational, false, inflammatory and defamatory complaints, not supported by evidence
Aggressive or Abusive Behaviour – conduct which compromises the health, safety and security of employees or others.

In these circumstances, WorkCover may put communication strategies in place in line with their UCC procedures.

Privacy

WorkCover is committed to managing and protecting information privacy by responsibly collecting, using, storing and disclosing the personal and sensitive information it holds, in a way that is consistent with its legal obligations. As a Queensland Government owned statutory body established under the Act, WorkCover is bound by the Information Privacy Act 2009 (IP Act). The IP Act and more specifically the Queensland Privacy Principles (QPP’s), sets out the ways in which Queensland Government agencies must handle personal information and provides rights to individuals to access their own personal information. Personal information is defined in the legislation as:

Personal information means information or an opinion about an identified individual or an individual who is reasonably identifiable from the information or opinion –
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.

Personal information includes the nature of a worker's injury, work-related causes of the injury, rehabilitation and return to work issues and status of a claim

All personal information collected through the course of a complaint will be handled in accordance with the IP Act, QPP’s and WorkCover’s Privacy Policy.

Continuous Improvement

The ongoing monitoring of complaints including themes and insights will assist in the identification of opportunities for continuous improvement, possible systemic issues and potential incidents. The Complaints Team will monitor key themes and insights and escalate in line with existing policies and procedures. Quality assurance reviews will also be undertaken regularly to determine opportunities for improvement.

Reporting

Complaints reporting (including volumes, themes and key drivers) will be provided on a quarterly basis to internal forums including the Executive Leadership Team and the Board.

In accordance with the Public Sector Act 2022, WorkCover has an obligation to publish complaint information on its website annually by 30 September. This includes the number of complaints received in the financial year, complaints with further action required and complaints with no further action required. Both further action and no further action are defined within section 10 – Definitions.

In addition to customer complaints Workcover is required to report in the annual report or via the Qld Government open data portal:

The total number (including the outcome) of Human Rights Complaints received in a financial year as prescribed by section 97 of the Human Rights Act 2019
Breaches to the Charter of Victims’ Rights received in a financial year including, the total number of complaints (including the specific charter breached), any complaints referred to another entity, how the complaint was dealt with as prescribed section 59 of the Victims’ Commissioner and Sexual Violence Review Board Act 2024.

Roles and responsibilities

The key roles with the customer complaints management process are as follows:

Role	Responsibilities
All Staff	Must comply with this Policy.
Board (including sub-committees)	Recipient of quarterly reporting on complaints volumes, themes and trends.
Chief Operating & Technology Officer	Provides executive oversight of the Customer Complaints Policy and associated procedures, ensuring organisational alignment and effective complaints‑handling practices.
Complaints Team	A specialist team that provides organisation wide visibility of complaint activity, sets best practice standards, and guides the business in effective complaints handling. The team manages higher priority and regulator referred complaints and, where required, acts as the investigator across the three level complaints model. The team also leads reporting, trend analysis, and continuous improvement initiatives.
Document Delegate	Manages the day‑to‑day operation, maintenance, and support of the Customer Complaints Policy as delegated by the Document Owner. Promotes adherence to the policy and supports employees to understand and comply with complaint‑handling requirements.
Document Owner & Executive General Manager, New Claims	Document owner for the Customer Complaints Policy, responsible for ensuring the policy remains current, accurate, and reflective of legislative and organisational requirements.
Executive Leadership Team (ELT)	Oversees organisational performance in managing customer complaints and ensures effective escalation and response to systemic issues. They support a culture of accountability, fairness, and continuous improvement.
Internal Audit	Provide independent and objective assurance over the adequacy and effectiveness of governance, risk management and internal control Frameworks in accordance with the Annual Audit Plan approved by the Risk and Audit Committee (RAC).
Internal Reviewer	An impartial senior WorkCover staff member, at an equal or higher level than the original Reviewer, who undertakes an internal review of the complaint handling process and outcome when requested by the complainant (level 2b).
Investigator	A WorkCover staff member who has the authority to investigate a level 2a Formal Investigation complaint and provide outcomes /responses.
Manager, Customer Complaints	Provides oversight and governance of the Customer Complaint Policy and its effective operationalisation. Ensure robust quality assurance and deliver accurate, meaningful reporting aligned with legislative and organisational requirements. Authorised to exclude certain types of customer complaints.
Reviewer	A WorkCover staff member who has the appropriate authority to authorise / approve a response prepared by the Investigator as part of a level 2a Formal Investigation.
Risk Group	Responsible for the facilitation of the end-to-end Level 2b Internal Review Process including investigation and issuance of outcome.
WorkCover Legal Services	Review policy governance documents against legislative changes and those with legal risk to ensure legal compliance.

Monitoring and reporting

The Document Owner is responsible for monitoring the effectiveness of WorkCover’s complaints management system and adherence to this policy by users. This includes monitoring:

Complaint volumes and trends (quantitative)
Complaint resolution timeframes (quantitative)
Complaint feedback: customer satisfaction rate (qualitative)
Root cause analysis and action plan to address complaint root causes (quantitative, qualitative)
Quality assurance checks to ensure complaints management system meets agreed service level timeframes and pre-determined criteria (quantitative, qualitative).

Non-compliance

Where an instance of non-compliance with this Policy is identified, any actual or potential compliance breach must be assessed, managed and reported in accordance with the WorkCover Compliance Policy and Compliance Breach Procedure and reported as required.

Policy review

This Policy must be reviewed every two (2) years (unless determined earlier) by the Complaints Team and approved by the Executive Leadership Team.

The Document Delegate will facilitate the review, with approval sought from the Document Owner should any changes be identified.

The Policy sits under the Risk Management Framework and is supported by a Customer Complaints Management Procedure which together forms the broader complaints management solution. Refer to Section 11 - Related Documents for a list of supporting documents.

Controls

The key controls in relation to this Policy are as follows:

Complaints are recorded on a central complaints management system
Complaint records are managed in line with WorkCover’s Records Governance Policy
Complaints data including trends, insights and systemic issues is reported to the Board, Risk and Audit Committee and Executive Leadership Team
Complaint handling education and support is provided to all frontline team members and leaders and Complaints Team members
Quality assurance is undertaken on complaints.

Definitions

The below table outlines the key terms and definitions used within this Policy.

Term	Definition
Accountable Executive	The member of the Executive Leadership Team who is accountable for the Policy, its contents and oversight.
Complaint	An expression of dissatisfaction made to or about WorkCover related to its products, services, employees or the handling of a complaint, where a response or resolution is explicitly or implicitly expected, or legally required.
Complainant	Defined as a person or their representative, or an organisational representative who makes a complaint to WorkCover. A representative must be authorised to make the complaint on behalf of the person or organisation, e.g. parent/or relative/person with enduring power of attorney, or officer of an organisation.
Complaints Management Solution	The policy, procedures, personnel and technology used by WorkCover to receive, record, respond to and report on customer complaints.
Complaints Management System	Technology application used to record and document complaints.
Complex Complaint	Complex complaints are those that require structured investigation and oversight due to their complexity, impact or sensitivity. Potential risk to the complainant and potential risk to WorkCover.
Customer	A customer may include an injured worker, employer, provider, key stakeholder or other party.
Further Action	Further action means where, upon finalising a customer complaint, WorkCover needed to take further action to deal with the concerns raised or resolve the complaint resulting in a systemic or direct benefit.
No Further Action	No further action means where, upon finalising a customer complaint, WorkCover did not need to take further action to resolve the issues raised in the complaint. This includes an internal review process that upheld and affirmed the original decision. No further action includes where a customer complaint is able to be resolved through issuing an apology or an explanation to the complainant.
Resolution	A complaint is resolved when the issue raised is dealt with in line with the WorkCover’s complaint policy and procedures. The resolution may or may not be to the complainant's satisfaction.
Simple Complaint	Simple complaints are those appropriate for early resolution (level 1) and are defined as: Low risk to the complainant and low risk to WorkCover. Usually involves one issue and requires no formal investigation.
Written Responses	Written responses may include emails or letters (in hard copy).