Interaction and Unacceptable Behaviour Policy

Document Update: 01/08/2018 

Introduction

Internetty Ltd (Internetty)  is committed to providing a fair, consistent and accessible service for all of our customers. However, Internetty has to balance this by providing a safe working environment for our staff to operate within and to ensure that our work is undertaken in an efficient and effective manner.

On occasions, customers may make unreasonable demands that could affect the service we provide to other customers, or communicate with us in a manner which causes offence to our staff. Where this occurs, Internetty Ltd reserves the right to manage customer contact in an appropriate manner to protect our staff and to maintain the effectiveness of our service to other customers.

This policy sets out our approach to managing those customers whose actions or behaviour are considered unacceptable and are either having a harmful impact on our staff or their ability to provide a consistent level of service to other customers.


Equality and diversity

Internetty recognises that, in some circumstances, customers may have a mental health problem and/or other disability where it may be difficult for them to either express themselves or communicate clearly and/or appropriately. Where unacceptable behaviour is evidenced under these circumstances, Internetty will consider the individual needs and circumstances of the customer and our staff before deciding on how best to manage the situation.

Scope

This policy covers all areas of work undertaken by Internetty Ltd and all of our staff. The policy also covers any external service provided by a partner organisation to our customers, for example translation service.

Defining unacceptable behaviour

What is deemed to be unacceptable behaviour will often differ depending upon the individual(s) involved and their particular circumstances. Examples of unacceptable behaviour are grouped under two broad headings, as follows:

  • Aggressive, abusive or offensive language or behaviour.
  • General unreasonable behaviour.

Aggressive, abusive or offensive language or behaviour

All of our staff have the right not to be subjected to aggressive, abusive or offensive language or behaviour, regardless of the circumstances.

Examples of this behaviour include, but are not limited to:

  • threats of physical violence;
  • swearing;
  • inappropriate cultural, racial or religious references; and
  • rudeness, including derogatory remarks.

Violence is not restricted to acts of aggression that may result in physical harm. It also includes behaviour or language (written or spoken) that may cause staff to feel distressed, threatened
or abused.


General unreasonable behaviour


On occasions, our customers may make unreasonable demands through the amount of information they seek, the nature and scale of service they expect or the number of approaches they make.

Some of our customers may not, or cannot, accept that Internetty is unable to assist beyond the level of service that has already been provided. For example, customers may persist in disagreeing with the action or decision take, or contact Internetty repeatedly about the same issue.

The method or tone in which these communications are received may not in itself be unreasonable - it is the persistent behaviour in continuing to do so that is considered to be unacceptable.

What amounts to generally unreasonable behaviour or demands will always depend on the circumstances surrounding the behaviour and the seriousness of the issues raised by the customer.

Examples of this behaviour include, but are not limited to:

  • demanding responses within an unreasonable time-scale;
  • repeatedly contacting or insisting on speaking to a particular member of staff who is not directly dealing with the matter;
  • excessive telephone calls, emails or letters (this also includes unsolicited marketing calls, letters and emails that are considered to be ‘spam’ or ‘phishing’);
  • sending duplicate correspondence requiring a response to more than one member of staff;
  • persistent refusal to accept a decision;
  • persistent refusal to accept explanations; and
  • continuing to contact Internetty without presenting new and relevant information.

Available restrictions

Where a customer continues to communicate in an unacceptable manner, Internetty Ltd will exercise its right to restrict contact or terminate services provided by Internetty Ltd. The precise nature and action will be appropriate and proportionate to the nature of the unacceptable behaviour and the circumstances of our staff and the customer. This decision is at the sole discretion of the Directors for Internetty Ltd.

When making a decision to restrict contact or terminate services provided by Internetty Ltd, we will take into account of any special requirements of those affected by our decision. For example, where someone cannot read, we are unlikely to limit communications to writing only unless we are satisfied there are reasonable adjustments in place to enable the customer to read our response.

We may decide to, amongst other considerations:

  • block telephone calls and/or emails from being received;
  • arrange for a single, named member of staff to deal with all future calls or correspondence from the customer;
  • limit future contact to a particular form and/or frequency - for example, emails or letters only - and these will be reviewed once per week/month;
  • inform the customer that their correspondence will be read to ensure no new issues have been raised, but then filed, without further acknowledgement;
  • if the customer is a complainant, terminate all contact. This may mean we discontinue an investigation;
  • refer the matter to the police where a criminal offence has been threatened or committed;
  • take legal action, such as applying for an injunction or court order to prohibit contact/poor behaviour. In this instance, advice must be sought in advance from the Internetty Ltd;
  • terminate services provided by Internetty Ltd immediately without recompense for services un-used;

Dealing with abusive aggressive, abusive or offensive language or behaviour
Telephone calls

None of our staff has to tolerate unacceptable behaviour over the telephone. Where this occurs, all of our staff have the right to place callers on hold or to end the call. However, before taking such action, it is reasonable to expect that the caller is warned that their conduct is considered to be offensive and to allow them the opportunity to moderate their behaviour.

Where a call is terminated by a member of staff, they must log the details in the notes where applicable, noting the reason for terminating the call. The matter must also be reported to their immediate manager in order to ensure fairness and consistency of approach.

Where the notes contain evidence of multiple instances of offensive behaviour and this continues, a more permanent restriction may be considered necessary by, for example ‘call barring’ the inbound telephone number. This decision is at the sole discretion of the Directors for Internetty Ltd.

Emails and letters

As with telephone calls, none of our staff has to tolerate unacceptable behaviour communicated via email or letter. Where there is a legitimate request for information contained within the communication, irrespective of the language used, it is reasonable to provide that information. But at the same time it is good practice that the customer will be warned that their conduct is considered to be offensive and will not be tolerated in the future.

Where no legitimate information is being requested, staff do not have to respond to an abusive email or letter. However, it would be good practice to issue a warning that the conduct is considered to be offensive and will not be tolerated in the future.

It is appreciated that some staff may feel uncomfortable responding to abusive emails and letters. If this is the case, they should refer the matter to their line manager who may take matters forward on their behalf.

Threats received to our staff

We take any threat to our staff very seriously. In such circumstances, the matter must be immediately reported to a line manager, who will work with the staff member in question to ensure that all necessary steps to ensure their well being are taken. The incident must also be reported to the Compliance Team and the appropriate Operations Manager.

Any request to supply evidence of the threat (for example, copies of correspondence or voice recordings) to the third party or the police, must be directed to the Compliance Team to administer in conjunction with the Data Protection Act.

Threats received involving third parties

On occasions, threats may be made against third parties - for example, against an individual, supplier, sub-contractor or alternatively their premises. In such circumstances, the matter must be taken seriously and immediately reported to the Compliance Team and the appropriate Operations Manager. The matter must also be reported to third party in order for them to take matters forward as they see fit. This will normally be undertaken by the Compliance Team or the Operations Manager.

Any request to supply evidence of the threat (for example, copies of correspondence or voice recordings) to the third party or the police, must be directed to the Compliance Team to administer in conjunction with the Data Protection Act.

Authorising contact restrictions

Where customers continue to display unacceptable behaviour, the decision to place a temporary or permanent contact restriction can only be authorised by the Directors of Internetty Ltd, Support & Customer Service Manager.

Wherever possible a reasonable degree of access to our service should be maintained, but at the same time give due regard to our staff. An example may be limiting customer contact to a specific internal email address and/or a specific internal telephone number.

In some circumstances, where all contact is being restricted or termination of services provided, this can only be authorised by the Directors of Internetty Ltd.

Letting the customer know about the restriction

Where contact is being restricted, the customer must be told of the decision. Wherever possible this should be by letter or email but may be done by telephone and supported by a suitable note in the relevant file. The communication does not have to be from the authorising person. However, authorisation to implement the restriction must be obtained before telling the customer.

The communication should inform the customer of the following however is not required:

  • the reason why we consider their behaviour to be unacceptable;
  • details of any earlier warning(s) issued about their conduct;
  • the restriction(s) we are imposing; and, if appropriate
  • how long the restriction(s) will last

In the event of a complete restriction or termination of services; the customer must also be given the option to resolve this matter. Communication of the right of appeal can be found in this policy under “Customer Appeals”;

A copy of the letter or email issued to the customer should be sent to the Compliance Team. The Compliance Team is responsible for maintaining a register of restrictions in place, which will be made available to staff to view.

Customer appeals

A customer may only appeal a decision to restrict contact where all forms of contact have been restricted or complete termination of services provided.

Appeals should be submitted either by email and sent to the Compliance Team at [email protected] or by writing to the address at www.internetty.uk

Exceptionally, appeals may be made by telephone on 0333 102 0000. Where details of the appeal are made over the phone, the Compliance Team will write to the customer confirming details of the appeal. The restriction will remain in place while the appeal is being considered.

The appeal will be considered as soon as reasonably possible by the Directors of Internetty Ltd. Normally the appeal will be considered by a different member of staff from the person making the original decision to restrict contact.

The customer will be advised in writing or by email by the Compliance Team whether the restricted contact arrangements still apply or a different course of action has been agreed. The Compliance Team shall record the appeal decision in the case file and register respectively.

Monitoring and reporting

The Management Team will monitor this policy from time to time to ensure that it is being applied in a fair, reasonable and consistent manner. The Management Team will also monitor the outcomes of the policy against the Equality Act 2010 protected characteristics: age, sex, ethnicity, religion or belief, disability and sexual orientation.

 

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