Complaints and Appeals
OCD Tech-ISO remains open and willing to process negative feedback with as much enthusiasm as positive feedback. Through the formal review and processing of complaints and appeals, OCD Tech-ISO can only improve.
For the purposes of its accredited certification services, the following distinctions are understood:
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- “Complaints” refer to reports by clients or any third party of some perceived problem with OCD Tech-ISO, its processes, staff, or services. These are not limited to clients, but may be filed by any third party, including the public. For client feedback, the complaint procedure is only used if the issue does not fit either the category of a nonconformity contest or appeal.
- “Appeals” refers to specific requests by clients to review a formal decision issued by OCD Tech-ISO, typically related to certification or a nonconformity contest. Appeals would not be submitted by any other third-party.
In all cases, confidentiality of client information and OCD Tech-ISO intellectual property and trade secrets must be protected when responding to complaints or appeals.
Complaints
Intake and Acknowledgment
Incoming complaints are routed to the Director. The complaint is filed within the client file if received by an existing client; otherwise, the original complaint is filed in a generic set of records for complaints.
If the complainant has provided contact information, the Director or designate will notify the complainant that the complaint was received and is being processed. This acknowledgment must be submitted to the complainant within 10 business days of receipt.
If the complainant has not provided any contact information, then acknowledgment is impossible and need not be performed. The complaint must be processed per the rules below, regardless.
Initial Review
The Director or designate will perform an initial review, to determine:
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- If the complaint is in reference to duties performed by the Director and/or if the complaint names the Director as a subject of the complaint. If so, the Director must pass the complaint onto the Certification review Committee (CRC) for processing and recuse themselves from further action on the complaint.
- If the complaint has sufficient details to allow OCD Tech-ISO to understand the issue. If not, the Director or designate will contact the complainant to obtain additional information to better understand the issue.
- If any conflicts of interest arise which would prohibit OCD Tech-ISO from processing the complaint. If so, then the problem must be communicated to the complainant and an alternate method of handling the complaint can be negotiated. This may be suggesting to the complainant where they can file the complaint, with an independent third party, or suggesting alternative complaint resolution methods. A conflict of interest preventing OCD Tech-ISO from processing a complaint is extremely unlikely, however, and OCD Tech-ISO must make every effort to process complaints under any circumstance.
- If the issue is related to a nonconformity contest; if so, then the Director or designate will notify the client that the issue must be processed as a nonconformity contest per the procedure Conformity Assessment Procedure and cannot be processed as a complaint.
- If the issue does not relate to OCD Tech-ISO certification services, but instead about one of OCD Tech-ISO’s certified clients. If so, then OCD Tech-ISO will instruct the complainant to raise the issue direction with the certified client; OCD Tech-ISO may also refer the complaint directly to the certified client. If the complainant provides evidence that they already raised the issue with the certified client and wishes to “escalate” the matter to OCD Tech-ISO, then it may be processed by OCD Tech-ISO.
If the review steps above allow the complaint to be processed normally, then the Director or designate will open a corrective action request (CAR) in the OCD Tech-ISO CAR system, per the procedure Corrective & Preventive Action. The rules for processing the CAR will then be followed.
Optionally, the Director or designate may notify the complainant that a CAR has been filed and give them the CAR number for future reference.
Complaints filed as CARs do not have specific response date or time requirements, as each issue may require a different level of effort – and thus additional time – to resolve.
Investigations
The investigation into the complaint is done per the procedure Corrective & Preventive Action. This requires root cause analysis and corrective action to resolves all identified root causes.
The decision to be communicated to the complainant shall be made by, or reviewed and approved by, individual(s) not previously involved in the subject of the complaint.
Any investigations and decisions related to the complaint, including verification of effectiveness, must be made by individuals not previously involved in the subject of the complaint.
Updating the Complainant
As reasonable, the Director or designate should update the client periodically on the status of the complaint, especially in cases where the issue may take more than 3 months to resolve. It is recommended that an update be sent monthly.
Updates must comply with confidentiality rules per the procedure Management of Confidentiality.
Resolution and Closure
Once a complaint-related CAR is closed, the complainant shall be notified. The level of detail of the notification shall be subject to the confidentiality rules per the procedure Management of Confidentiality. OCD Tech-ISO should endeavor to provide sufficient detail and evidence to satisfy the complainant, however, provided confidentiality rules are not violated. “Confidentiality” should not be used as an excuse to deny the complainant details that they may need to feel satisfied that the issue was properly investigated and resolved by OCD Tech-ISO.
OCD Tech-ISO may opt to make some complaints and resolutions public, to the extent that the complainant allows this and giving consideration to confidentiality rules per the procedure Management of Confidentiality.
Escalation
If the complainant is not satisfied with the result of a complaint investigation and any final decisions made, the Director or designate will inform the complainant that two “escalation” paths are open to them:
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- Escalation to Full CRC
The complainant may request an escalation of the issue to the full Certification Review Committee. In this case, the CRC will convene a special session comprised of at least three members and review the associated CAR. Any CRC members involved in any way with the original CAR must recuse themselves, but the CRC must be re-populated with three members. The CRC will review the actions taken and issue a report on any suggested changes or deficiencies in the CAR and final decision. If there are issues or deficiencies, the CAR will be re-opened to process the concerns accordingly. If the decision by the CRC is to uphold the decision as originally determined, the Director or designate will notify the complainant accordingly. - Escalation to Accreditation Body
The complainant may raise the issue with OCD Tech-ISO’s accreditation body. The Director or designate will provide the complainant with the proper contact method to do so.
- Escalation to Full CRC
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Appeals
Intake & Acknowledgment
Clients may appeal a certification decision, such as a decision to deny, suspend, withdraw, or reduce the scope of certification. In addition, a client may use the appeal process to appeal a decision related to a nonconformity contest.
In such cases, the appeal is submitted to the Director. The Director or designate will notify the appellant that the appeal was received and is being processed. This acknowledgment must be submitted to the appellant within 10 business days of receipt.
Submission, investigation, and decision on appeals may not result in any discriminatory actions against the appellant.
Initial Review
The Director or designate will perform an initial review, to determine if the appeal has sufficient details to allow OCD Tech-ISO to understand the issue and validate the appeal. If not, the Director or designate will contact the appellant to obtain additional information to better understand the issue.
Investigations
The Director or designate will then convene an ad hoc Appeals Committee to investigate the matter. The Appeals Committee may not be comprised of any CRC members or OCD Tech-ISO personnel who were involved in the original decision under appeal, including any persons involved in any audit related to the appeal. The Appeals Committee must be comprised of three individuals with sufficient knowledge and background to properly investigate the appeal. OCD Tech-ISO may use independent third parties for this role.
The CAR system may be used for processing appeals, but a unique CAR must be filed for such appeals; existing CARs related to any issues mentioned in the appeal must remain apart from an appeal-related CAR. In some cases, the CAR system may not prove useful or effective for processing appeals, so this is not mandatory.
The Appeals Committee will review the information and take additional steps, as needed, to investigate the matter.
Updating the Appellant
As reasonable, the Director or designate should update the appellant periodically on the status of the appeal, especially in cases where the issue may take more than 3 months to resolve. It is recommended that an update be sent monthly.
Updates must comply with confidentiality rules per the procedure Management of Confidentiality.
Resolution & Closure
The Appeals Committee will make a final decision based on this information, and document this in a formal appeals notice. This decision must be signed by all three of the Appeals Committee members and must be unanimous. Failure to obtain a unanimous decision will result in the original issue being withdrawn.
The appeals decision will then be provided to the Director or designate, who will provide this to the appellant.
Escalation
If the appellant is not satisfied with the result of an appeal, their only escalation avenue is to file a complaint against OCD Tech-ISO with its accreditation body. The Director or designate will provide the complainant with the proper contact method to do so.