Feedback and Complaints Policy

1. Introduction

As a client of London Medical Laboratory Limited ("LML"), your feedback is essential in helping us to continue to improve the services that we provide. We will strive to provide a response to all feedback provided by clients within 48 hours of receipt and will work to fully resolve any complaints raised promptly.

We take negative feedback and any complaints very seriously.

Firstly, we strive to provide laboratory services in a way that does not generate complaints. However, when there are occasions that our systems are overwhelmed or fail in some way to meet the expectations of our customers and clients, we will do our best to find a satisfactory conclusion to any inconvenience or any other problem we may have caused you by not providing what you expected from us.

Please don't ever hesitate to get in touch if there is anything that has disappointed you in the way we carry out our service to you. The best way to get in touch with us is by phone at 020 71833718 and/or email at [email protected].

In the interests of candour, we have included our entire complaints policy. This policy outlines procedures and responsibilities within London Medical Laboratory Limited ("the Company") for handling any concerns, issues or complaints that may arise. This includes our branches and testing locations or if you visit or make a purchase from one of our online sites or websites:

This policy along with our Terms and Conditions and Privacy Policy (together, the "Terms") apply to any order you make for our Services.

2. Purpose and objectives

The purpose of this Policy is to ensure that any complaints or concerns by patients are correctly managed. This policy serves to indicate how issues concerning patient concerns or complaints should be managed within the Company.

Complaints received within LML are a form of feedback on our services from our internal and external users. Complaints are dealt with by competent members of staff, in the manner required by the company, in adherence to LML’s Complaints Policy and Procedure (LML-POL-7). Complaints are dealt with to the complainant’s satisfaction so that:

Lessons learned are incorporated appropriately.
That laboratory management are aware of complaints about the service provided within its remit.
Complaint and any concerns raised are dealt with and responded to in a timely manner

The handling of complaints and anomalies is of importance to LML for several reasons, these include the following:

Inaccuracies and mistakes may have a bearing on client health.
Mistakes may lead to legal action.
They have a detrimental effect on the reputation of LML.
They may highlight areas of the services provided where methods and procedures are unclear, or where members of staff may need further training.

All complaints received must be recorded. All complaints received are processed via ZenDesk.

3. Duties and responsibilities

The CQC Registered Manager holds overall responsibility for ensuring the development, implementation and operation of this policy regarding complaints. The Customer Service Manager supported by the Customer Service Supervisor will lead and oversee the process of the implementation of this policy, as well as monitoring its compliance and effectiveness. The CQC Registered Manager must notify the Customer Service Manager of any amendments required to this protocol. All changes must be made under change control by the CQC Registered Manager or a designated representative.

It is the responsibility of the member of staff following this procedure to ensure they fully understand the policy.
Customer Service staff, either in-branch or in the head office or online, will deal with a complaint.
However, the Customer Service Supervisor must be informed when a complaint is made.
It is the responsibility of any staff member receiving a complaint to record it appropriately and alert relevant senior staff.

The Customer Service Manager as the overall manager of the entire Customer Service Team, will act as the designated complaints manager for the Company under supervision and guidance of the CQC Registered Manager. Supported by the Customer Service Supervisor, the Customer Service Manager is:

Responsible for managing the procedures for handling and considering complaints dealt with by the Customer Service Team.
Responsible for ensuring that action is taken, if necessary, in light of the outcome of a complaint or investigation.
Responsible for the effective management of the complaint’s procedure by the Customer Service Team and reporting to the CQC Registered Manager and/or CEO if required.

4. Principles

A complaint usually comes about where someone expresses concern or dissatisfaction in relation to the services we provide. They might express concern about:

Something which is against the choice or wishes of a user
The way treatment, service or care has been provided to a user of the service (patient)
Discrimination against a user of the service
How a service has been managed, which has a direct impact on a member of the public

LML, though a private laboratory follows the Parliamentary and Health Service Ombudsman’s Six Principles of Good Complaints Handling which are:

Getting it right
Being customer focused
Being open and accountable
Acting fairly and proportionately
Putting things right
Seeking continuous improvement

London Medical Laboratory Limited will always aim to:

Publicise for patients how any complaints can be made, and also how any concerns or issues can be raised. This will primarily be done through emails, phone calls and through the company and third-party websites such as Trustpilot or Google. Emails and phone calls serve as the primary portal for service users. Complaint procedures will also be communicated through other means, such as verbally in-store to branch managers.
Aim to resolve any concerns or issues without recourse to the need to make use of the formal complaints policy whenever possible.
Acknowledge receipt of a complaint and offer to discuss the matter with the complainant within three working days.
Deal efficiently with complaints and investigate them appropriately.
write to or speak with the complainant on completion of any investigation explaining how it has been resolved, what appropriate action has been taken and what options are available should the complainant be dissatisfied by the handling of the complaint.
indicate that recourse to independent arbitration or mediation can be made by a complainant if they are still unhappy.
assist the complainant in following the complaints procedure or provide advice on where they may obtain such assistance.

If a complaint is made orally (usually via telephone or in-store) and is resolved to the complainant’s satisfaction within 24 hours, it need not be responded to formally via writing. Complainants must always be made aware that they have the right, should they so wish, to make a complaint formal which will be graded higher than a standard complaint (i.e. Level 2 and upwards, see section 5.6).

5. Procedures

5.1 Complaint definition

As per the CQC definition, a complaint is regarded as ‘any expression of concern or dissatisfaction in relation to the service we provide’. This may take the form of a verbal or written complaint that may be received as a telephone call, letter, email, in person in a LML branch or other communication (e.g. Google or Trustpilot). Most patient complaints are received via emails.

The primary aim of complaint handling is to increase customer satisfaction, or at least to decrease dissatisfaction. This requires a “customer-centred” approach that involves active listening, acknowledgement of the customer’s point of view, a promise to investigate, and an apology for any inconvenience experienced. Arrangements are such as to ensure:

Complaints are dealt with effectively.
Complaints are properly investigated.
Complainants are treated with respect and courtesy.
Complainants receive, so far as is reasonably practicable:

Assistance to enable them to understand the procedure in relation to complaints; or
Advice in where they may obtain such assistance.

Complainants receive a timely and appropriate response.
Complainants are told the outcome of the investigation of their complaint; and
Action is taken, if necessary, in the light of the outcome of the complaint.

5.2 Guidance on LML timeframes

A complaint can be managed via informal or formal routes and this is normally indicated by complainant. LML encourage staff to resolve minor problems immediately via an informal method which is usually addressed within 24 hours. These informal concerns should be recorded locally for learning purposes and shared with the customer team on a regular basis.

Formal complaints are graded higher (see section 5.6) and normally those issues that require an investigation within the agreed timescale. LML timescales for formal complaints are a response within 2 working days from the date of receiving the complaint. Complaints vary in complexity and the time required to investigate; therefore, it is important that the complainant is involved in discussion regarding the target timescale. LML aim to ensure all complainants are dealt within the timescales however where this is not possible this is communicated to the complainants by email.

5.3 Period within which complaints can be made

The period for making a complaint is normally:

12 months from the date on which the event which is the subject of the complaint occurred; or
12 months from the date on which the event which is the subject of the complaint comes to the complainant's notice.

The Company has discretion to vary this time limit if appropriate. i.e. where there is good reason for not making the complaint sooner, or where it is still possible to properly investigate the complaint despite extended delay.

When considering an extension to the time limit it is important that the Customer Service and CQC Registered Managers take into consideration that the passage of time may prevent an accurate recollection of events by the staff members concerned or by the person bringing the complaint. The collection of evidence, clinical guidelines or other resources relating to the time when the complaint event arose may also be difficult to establish or obtain. These factors may be considered as suitable reason for declining a time limit extension.

5.4 Source of complaint

Official complaints from users of the service are usually received by the customers service team. Complaints from clients (such as GPs, companies and pharmacies) must be dealt with according to this LML official Complaints Policy. The Customer service team gives clear deadlines for dealing with complaints and providing investigation reports.

A complaint can be raised by for example:

A client such as a GP, company or pharmacy
A customer using our services or a customer that is using our services through another company
A member of the public
Staff (including LML GPs or our consultants)

5.5 Receiving a complaint

All formal and highly graded complaints (level 2 and upwards) should be brought to the immediate attention of the Customer Service Manager except where a named delegate has been appointed. In this case the named delegate should be made immediately aware of all complaints.

The Customer Service Manager (or his/her named delegate such as the Customer Service Supervisor), or CQC Manager, if necessary, must:

Acknowledge the complaint within 2 working days verbally or in writing and at the same time, offer to discuss the complaint, at a time to be agreed with the complainant decide, in accordance with the complainant the way the complaint is to be handled (i.e., formally or informally),complete, in the case of formal complaints, a preliminary investigation and provide a response to the complainant within 14 days, in line with CQC requirements. Any delays will require a satisfactory explanation (please refer to CQC website for more information).
Discuss the complaint and if the grade of complaint is Level 2 or above and is of a serious nature, a complaint action should be developed.
Speak with the customer and offer a remedial solution which is in most cases a refund and/or a free replacement test as compensation.

Members of staff receiving verbal comments, concerns and suggestions which they cannot resolve themselves by immediate action, should usually refer them to the most senior person on duty in that area; that person is responsible for responding.

In general, staff should:

Listen to the complainant, acknowledge their complaint
Express regret sincerely for any inconvenience or distress caused
Clarify the details of the complaint.
Offer an explanation and/or offer to investigate

In all instances, staff must clarify the substance of the complaint with the complainant and, if possible, resolve the complaint to the person’s satisfaction at the time the complaint is made. Make a contemporaneous record of the discussion and record on Zendesk. Complaints may be received either verbally or in writing.

Verbal complaints:

Wherever possible, complainants should be directed to the call centre to file a complaint. All verbal complaints, i.e., those made either in person or via telecommunications, must be logged by the Customer Service Agents using Zendesk and the complaint tagged as a complaint for review by the Customer Service Team Supervisor.
Any complaints in-store will be reported to the call centre, or an email will be written by the branch manager. All customers are recommended to call the call centre or email the company if they wish to formally complain.
The Customer Service Supervisor will review all complaints and escalate them to the Customer Service Manager or CQC Manager if necessary.

Written complaints:

All written complaints submitted electronically should go to [email protected] or [email protected] where they can be reviewed by the Customer Service Supervisor and escalated to the Customer Service Manager or CQC Manager if necessary. The Customer Service Agents are required to check this inbox several times every working day.
Complaints submitted via post, must also be brought directly to attention of the Customer Service Manager, or CQC Manager if necessary. Where a delegate or representative has been appointed and named, they may be notified in place of The Customer Service Manager.
Complaints on third-party websites such as Trustpilot or Google will be dealt with by the Customer Service Supervisor. He or she will escalate the problem to the Customer Service Manager or CQC Manager if requested.

5.6 Grading of a complaint

Investigation should be performed for every complaint, this is a detailed systematic search to uncover facts and determine the truth of the factors (who, what, when, where why and how) of accidents.

Patient safety or root cause analysis (RCA) investigations should be conducted at a level appropriate and proportionate to the incident, claim, complaint or concern under review.
Root cause analysis (RCA) will identify the contributory factors e.g., systemic failures that allowed the causal factors to occur.
A proper investigation will provide appropriate line of action to address the complaint.

Complaints will be investigated in the first instance by the Customer Service Supervisor who will contact the patient with 48 hours of being notified about a complaint. The Customer Service Manager will be notified immediately and all communication will include the Customer Service Manager. If the Customer Service Manager is unable to resolve the issue it shall be referred up the chain of management (i.e., CQC Manager, CEO and/or Medical Director) as necessary to reach a satisfactory outcome for the complainant with the complainant been informed of a new timeline for resolution.

When the complaint is first received it will be graded as follows:

Level 1 – minor complaint being handled by the Customer Service Supervisor under supervision of the Customer Service Manager
Level 2 – complaint escalated to CQC Manager
Level 3 – complaint escalated to joint CEO and/or Medical Director
Level 4 – complaint escalated to CQC or equivalent ombudsman

5.7 Complaints against the Customer Service Manager or CQC Manager

Any complaints filed against the Customer Service Manager or CQC manager (or his/her named delegate) should go directly to the company’s joint Chief Executive Officer (CEO). The CEO will take the lead in dealing with the complaint by following this document and conducting any investigations pertaining to the complaint in place of the CQC manager. The CEO reserves the right to delegate the task of investigation to an appropriate member of senior management. Under no circumstances can the task be delegated to the CQC manager unless the complaint is about The Customer Service Manager.

5.8 Complaints action plan

If the complainant does not accept the offer of a verbal discussion in an effort to resolve matters, the CQC Registered Manager or someone delegated to act on his/her behalf will notify the complainant in writing of the time period (28 days) within which a response can be expected.

If a clear plan and a realistic outcome can be agreed with the complainant from the start, the issue is more likely to be resolved satisfactorily. In most cases the remedial solution will be a refund and/or a free replacement test as fair compensation. Having a plan will help the Company to respond appropriately. It also gives the person who is complaining more confidence that the Company is taking their concerns seriously.

If someone makes a complaint, the person making the complaint will want to know what is being done and when. However, accurately gauging how long an issue may take to resolve can be difficult, especially if it is a complex matter involving more than one person or organisation. To help judge how long a complaint might take to resolve, it is important to:

address the concerns raised as quickly as possible
stay in regular contact with whoever has complained to update them on progress
follow closely any agreements made – and, if for any reason this is not possible, then explain why.

In any case, the upper limit for a complaint to be dealt with is 28 days.

5.9 Investigation and responses to complaints

All formal or highly graded complainants shall receive a formal, written response to their complaint, within 28 working days of receipt, unless the complaint was resolved informally (e.g., verbal explanation and/or apology during an initial telephone conversation) and this resolution was recorded. During the investigation, the complainant will be kept informed of progress either verbally or in writing as agreed with the complainant.

Copies of investigation reports may be sent to complainants, but these should always be accompanied by a covering letter. This letter shall contain the name, address and telephone number of the manager responding to the complaint, shall be dated, and the date of email sent shall be recorded, either on a copy of the letter kept on file, or in the corresponding Zendesk complaint record. If an investigation requires longer than 28 days, the complaint investigator must reply within the 28-day period stating the reason for the delay.

The target date for investigating and responding to a written complaint is 3 days.

The response must be signed off by the CQC Registered Manager and include:

an explanation of how the complaint has been considered.
the conclusions reached in relation to the complaint, including any remedial action to be taken details of how to seek arbitration or mediation if the complainant remains dissatisfied.

6. Escalation of a complaint

The following routes will be open to patients in the event that a complaint cannot be satisfactorily resolved directly with the Company or by the CEO or Medical Director.

1. Raising the matter with the Care Quality Commission (CQC). The CQC are the independent regulator of health and adult social care in England. The CQC makes sure health and social care services provide people with safe, effective, compassionate, high-quality care and we encourage care services to improve. LML is regulated and inspected by the CQC.

Telephone: 03000 616161
Email: [email protected]
Website: www.cqc.org.uk and for LML www.cqc.org.uk/provider/1-4035892777

2. LML is accredited by The United Kingdom Accreditation Service (UKAS). UKAS is the National Accreditation Body. They are appointed by government, to assess and accredit organisations that provide services including certification, testing, inspection and calibration. Information on raising a complaint about an accredited body can be found on the website.

Website: www.ukas.com/wp-content/uploads/2022/03/UKAS-B22-03-2022-UKAS-Complaint-Leaflet.pdf
E-mail: [email protected]
Phone: 01784 429 000

3. Seeking assistance from the Patients Association. This is a national health care charity that highlights patients’ concerns and needs. It provides advice aimed at helping people to get the best out of their healthcare and tells patients where they can get more information and advice. Phone: 0845 608 4455

Website: www.patients-association.org.uk.

4. The Citizens Advice Service provides free, confidential and independent advice from over 3,000 locations, including in their bureaux, GP surgeries, hospitals, colleges, prisons and courts. Advice is available face-to-face and by phone.

7. Duty of candour

If the complaint is a notifiable incident, as per the Duty of Candour Policy and Procedure, we shall follow that procedure as indicated.

8. Confidentiality

All complaints will be treated in the strictest confidence.

Where the investigation of the complaint requires consideration of the patient's medical records, the CQC Registered Manager or someone designated to act on his/her behalf will inform the patient or person acting on his/her behalf if the investigation may involve disclosure of information contained in those records to a person other than the company, or an employee/contractor working for the organisation.

9. Unreasonable / vexatious complaints

Where a complainant becomes aggressive or, despite effective complaint handling, unreasonable in their promotion of the complaint, some or all of the following formal provisions will apply and will be communicated to the patient:

The complaint will be managed by one named individual at senior level who will be the only contact for the patient (typically the CQC manager)
Contact will be limited to one method only (i.e. in writing)
Place a time limit on each contact
The number of contacts in a time period will be restricted
A witness may be privy to all contacts
Repeated complaints about the same issue will be refused
Correspondence regarding a closed matter, will only be acknowledged and not otherwise responded to
Set behaviour standards (e.g. use of vulgarity will not be tolerated).
Return any irrelevant documentation
Keep detailed records of all communications.

Updated 12 May 2022

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