We value the importance of effective and empathetic communication to help people use our service and enable us to carry out our work efficiently.
We expect PHSO employees and people who engage with us to behave in an acceptable way.
We expect PHSO employees to:
- provide a fair, open, proportionate and accessible service
- listen and understand
- treat everyone who contacts us with respect, empathy and dignity
- conduct themselves in accordance with the standards and values set out in our Code of Conduct.
We expect everyone who contacts us to:
- treat employees with respect and courtesy
- engage with us in a way that does not impact on our ability to carry out our work effectively and efficiently for the benefit of everyone who interacts with us.
We hope that most people will be satisfied with the contact they have with us but we recognise that some people may not be. You can provide feedback about our service at any time during your contact with us.
Behaviour that is unacceptable
We recognise that some people who contact us may have reason to feel aggrieved, upset or distressed. However, it is not acceptable when that anger is directed towards our employees.
In a small number of cases, a person’s behaviour while engaging with us may become unacceptable because it involves abuse of our employees or our service.
When this happens, we will take action to protect our employees and maintain our ability to do our work and provide a service to others. We will manage these actions or behaviours in line with our Unacceptable Behaviour Policy.
Examples of what we consider to be unacceptable behaviour include:
Aggressive, abusive or offensive behaviour
Physical behaviour, language, images (whether face-to-face, via telephone or written in emails, letters or online) that may cause employees to feel intimidated, uncomfortable, degraded, threatened or abused is not acceptable.
This includes abuse about any protected characteristic, as defined by the Equality Act 2010 (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation).
We may consider demands about the nature or scale of our service to be unacceptable. For example:
- requesting responses in unreasonable timescales
- insisting on speaking with senior colleagues or escalating to senior colleagues when not getting the desired answer from a PHSO employee
- making repeated approaches about the same issue without raising new information
- vexatious requests for information
- repeatedly changing the substance of a complaint
- raising unrelated concerns or refusing to accept a decision where explanations for the decision have been given.
Unacceptable levels of contact
We may consider communication unacceptable in nature or because of the scale of service expected. For example:
- continually contacting us in the process of looking at the issue or complaint
- numerous calls or emails in one day or excessive contact over a short period of time
- repeatedly sharing information that has already been shared
- continually reframing the issue or complaint in such a way that it makes it difficult for us to do our job effectively.
Refusal to co-operate
It is unacceptable if a person refuses to engage with the complaints process by:
- refusing to provide information and/or evidence
- not providing a summary of their concerns
- not providing comments or responses to reasonable deadlines
- not agreeing to a defined complaint scope within a reasonable timescale.
How we make decisions about unacceptable behaviour
Any PHSO employee who directly experiences unacceptable behaviour while in contact with someone using our service is authorised to deal with it immediately. They will do this in a manner they consider appropriate to the situation and in line with our policy.
Decisions to restrict contact for longer than six months will only be taken after careful consideration of the situation in consultation with a manager.
Individuals will be informed in writing or other agreed format (where a reasonable adjustment is in place) of any behaviour that is considered unacceptable in line with our policy.
Action we might take
Wherever possible we try to work with individuals to rectify the situation and continue communication in a respectful and dignified way for all involved.
Where we are not able to do this, we may take the following actions:
- provide a verbal warning at the time of incident so the individual has an opportunity to understand the impact of their behaviour and rectify the situation
- provide a written warning following the incident so the individual is aware of the impact of their behaviour and can modify it for future interactions
- restrict contact to certain communication methods, while taking account of any reasonable adjustments in place
- restrict contact to named individuals
- restrict contact to certain times on set days
- block emails or telephone numbers.
In exceptional cases we reserve the right to refuse to accept a complaint or future complaints from an individual.
Where appropriate, we will refer the incident to the police for criminal investigation.
Making sure our service is accessible to those who need it
We will make sure that we meet the requirements of the Equality Act 2010 and the Public sector equality duty. This includes considering adjustments for disabled people and people living with a long-term health condition or impairment.
Our employees are trained to handle difficult situations appropriately and are expected to understand the causes of challenging behaviour.
On occasion however, someone’s behaviour may go beyond what is reasonably acceptable. If this happens we will follow our unacceptable behaviour policy.
Some people who have a disability, long-term health condition or impairment may be subject to a restriction under the policy. In these cases, we will consider whether applying the restriction would affect that person more than someone who does not have that disability, health condition or impairment. Where necessary, we will make sure you are still able to access the organisation.
Appealing a decision to restrict contact
When we send a letter informing someone of a restriction, we will provide information on how to appeal against the decision.
If they wish to appeal the restriction, they must do so within 10 working days of the decision to restrict contact (or another timescale to be agreed if a reasonable adjustment is in place). The restriction will remain in place while the appeal is considered.
Any appeal will only consider arguments against the restriction. It will not consider arguments related to any complaint or issue brought to us.
An appeal could include that the restrictions:
- are disproportionate
- will disproportionately impact the individual because of personal circumstances, such as a previously undisclosed disability, condition or impairment.
The Review and Feedback team will usually consider the appeal. In cases where the restriction was put in place by that team, an Assistant Director will consider the appeal. They will make the decision to remove, change or uphold the restriction based on the evidence available to them. There is no further right of appeal.
Duration of restricted contact
Restricted contact will be put in place for a minimum of 6 months and be reviewed every 3 months. At the end of 6 months the restriction may be extended and reviews at 3 monthly intervals will continue.
Employees have approval to review a restriction prior to the review date if they consider the person involved has positively changed their behaviour. If a restriction is removed that person will be informed in writing or via an agreed alternative format if a reasonable adjustment is in place.
Non-compliance with restrictions
If someone does not comply with a restriction, employees have approval to stop contact at the time this happens. For example, if the restriction prohibits any telephone contact employees can remind that person of the restriction and end the call immediately.
If they continue to ignore the restriction, employees will consult with a manager to consider whether further restrictions are required, in line with our unacceptable behaviour policy.