Complaints Procedure for Students

Introduction

Purpose

1. The purpose of this Procedure is to enable a dedicated framework to be in place for student complaints to be received, considered and responded to at Northeastern University London (the University).
2. The views of students are important. The University encourages any student to contact the University to discuss their views and experiences as they arise. This Procedure provides clarity on how a student can communicate with the University regarding eligible matters of concern during the course of their student journey. 
3. Submitting a complaint is one option for communicating a concern(s) to the University. The University encourages students to consider all options as alternative mechanisms could be more suitable, depending on the nature of their concern/s. These can include:
   1. Informal feedback
   2. Student Voice mechanisms
   3. Student Union
4. See the below section on ‘alternative methods to express views’ for further details.

Scope

5. This Procedure applies to all students registered at the University.

Eligibility

Eligible Complaints

6. The following can be considered under this Procedure:
   1. Matters concerning the delivery of teaching, learning, and supervision.
   2. Service delivery and/or standards of a non-academic services of the University.
   3. Information contained in literature aimed at students, such as a handbook or promotional material.
   4. Facilities, such as buildings on campus.

Non-Eligible Complaints

7. The University has in place dedicated policies and procedures to respond to specific matters. Therefore, a student must direct their concern regarding the following topics to the appropriate dedicated frameworks instead of this Procedure. These are:
   1. Academic Appeals Policy and Procedure: queries arising from a decision made from academic judgement and/or an academic body.
   2. Academic Misconduct Policy: concerns arising from the academic work/input of a student with a University assessment or examination.
   3. Admissions Feedback, Complaints, and Appeals Procedure: to challenge a decision relating to admission or student fee status.
   4. Disciplinary Procedure for Students: a concern regarding the behaviour of students. 
   5. Disciplinary Procedure for Staff: queries or concerns relating to the conduct of a member of staff. 
   6. Visitor Policy: concerns arising where an individual is a member of the public/visitor to the University.
8. Any matter received that is considered to be frivolous (unfounded or trivial) or malicious (with vindictive motivation) will be dismissed. 
9. The University will not pursue matters that are not relating to the University or its activities. Where reasonable and practical to do so, the University may direct a student to the correct contact details for non-university matters. For example, where a concern relates to the Northeastern University London Student Union. 
10. Apprenticeship learners, with concerns that are arising in the workplace must refer to their employer’s internal policies and procedures. Such learners are advised to contact the University’s Business Development Team should such a concern influence their study programme. Apprentices may also raise their apprenticeship concerns, complaints, and enquiries with the Education & Skills Funding Agency (ESFA), by contacting the apprenticeship helpline. The ESFA Guide to making a complaint can be found here. The Helpdesk can be contacted by phone on 0800 150600 or via email here.
11. The University reserves the right to determine the most appropriate policy/policies and procedure(s) to use when responding to a concern.

Eligible Students

12. All individuals with an active student status on the University’s student record system may pursue a complaint in accordance with this Procedure. This includes study that is full-time or part-time, undergraduate or postgraduate, and apprenticeship learners. This Procedure also applies to students on the following programmes: 
    1. Mobility courses 
    2. Undergraduate double degrees programmes 
    3. Postgraduate taught programmes (from 2023-24) 
    4. Degree apprenticeship programmes (from 2023-24) 
    5. Postgraduate research programmes (from 2023-24)
13. Students taking a period of temporary withdrawal from their studies, but anticipated to resume their studies, are eligible to be considered under this Procedure. This is subject to any published timeframes stipulated in this Procedure.
14. Former students are eligible where their concern relates to their period of time at the University, subject to any published timeframes stipulated in this Procedure.

Categorisation of Complaints

15. The University’s student complaints process comprises of three stages:
    1. Stage 1 – Initial Response
    2. Stage 2 – Formal Investigation
    3. Stage 3 – Review
16. The stage of a complaint does not reflect the severity of a complaint. The University aims to resolve all complaints as soon as possible and at the earliest level possible, typically the Initial Response stage.
17. The University’s categorisation of a complaint (i.e. Stage 1, 2, or 3) is final.

Time Limitations

18. The University aims to resolve all complaint cases swiftly, taking into account the sensitivities and details of the matter being considered. 
19. A student is encouraged to contact the University at the earliest opportunity. This is to ensure that any remedy, where appropriate, can be put in place as soon as possible. It additionally assists with investigatory processes as potential information, data, evidence and remedy options are more likely to be available and accessible. 
20. Time frames are stipulated throughout the Procedure. Each case is considered on an individual basis and complex cases may understandably require additional time. Where additional time is required, the University will ensure the student is informed. 
21. Where a student submits a complaint outside the published time frame, it will typically not be considered as determined to be out-of-time. Any late complaints may exceptionally be considered where suitable evidence is provided, to demonstrate that a student could not reasonably submit on time. The decision to exceptionally accept a late complaint is at the sole discretion of the University. If a student submits a complaint outside of our time limits, and we do not consider it exceptional, the University will issue a student with a letter explaining that they are out of time. This is called a Completion of Procedures letter. A student can use this letter to contact the Office of the Independent Adjudicator, if appropriate.
22. Reasonable steps and options will be considered when reviewing a complaint, but students should note that the passage of time may influence options available.  
23. Where a complaint relates to a series of related events, it is typically expected that a complaint should be submitted after the final event.

General Principles

24. A student will not be disadvantaged or subject to prejudice by making or pursuing a complaint. All complaints will be responded to professionally, sensitively, and in a supportive manner.
25. All complaints made by a student are kept confidential. Only staff or students who are involved will be contacted, and they will be instructed that all details regarding the complaint are to be kept confidential.
26. All individuals interacting with this Procedure are expected to conduct themselves courteously and respectfully, reflecting dignity and respect. The University may take disciplinary action against students or staff where behaviour does not meet expectations.
27. To submit a complaint under this Procedure, a student must be a direct party or experienced a material detriment for the matter being considered.
28. At all stages of this Procedure, a sufficient level of detail is required to enable responses and processing to be focused and meaningful. When this is not present, the University will place a complaint on hold until the required level of articulation is provided. Additionally, the University reserves the right to subsequently close a complaint if sufficient detail and/or engagement is not provided within a reasonable timeframe. 
29. Any decisions made under this Procedure will be assessed on the ‘balance of probabilities’ only. 
30. Potential outcomes of an eligible complaint comprise the following: 
    1. Upheld
    2. Partially upheld 
    3. Not upheld 
    4. Dismissed
31. All student communications will be sent electronically to their University email account. Alternative communication methods and contact addresses (held on the University’s student record system) may be used where appropriate, for example, to facilitate reasonable adjustments or during engagement with former students. Students are required to keep their contact information up to date. 
32. Students are expected to attend meetings where reasonable notice has been provided. Decisions may be made on the available evidence where it is considered reasonable to do so and the University is satisfied that adequate notice has been provided to students. Students are expected to monitor their University email account throughout the course of their studies.
33. The University may vary any aspect of this Procedure where it is considered necessary, for example to accommodate reasonable adjustments or address a conflict of interest. This includes the right to request evidence to support decision-making.
34. The University may appoint an external individual to undertake any task or duty outlined in this Procedure. This is at the sole discretion of the University.
35. The University accepts no responsibility or liability, nor will the University reimburse any expenses incurred from submitting a complaint.
36. Any individual or role named in this Procedure may nominate a delegate to undertake a role or function on their behalf. 
37. At any stage of the process where a conflict is identified or perceived, the Student Regulation Resolution Office (SRRO) will assign duties to an appropriate member of staff.

Types of Complaints

Anonymous Complaints

38. Anonymous complaints cannot typically be accepted. This is in the interest of ensuring that appropriate information can be collated to inform a complaint investigation and fairness of process. The University reserves the right to determine how it responds to anonymous complaints.
39. Exceptionally, the University may decide to consider an anonymous complaint if the evidence submitted provides a compelling case. The Registrar will review the anonymous complaint and make the decision as to whether or not it should be investigated. Anonymous complaints can only be investigated if substantial evidence is submitted at the time of the complaint being submitted, enabling a thorough review and investigation. Raising a complaint anonymously might impact the time it takes to investigate, the scope of the investigation, and communication of the outcome. 

Multi-issue Complaints

40. A multi-issue complaint can arise where concerns include more than one item, where different items could fall within the remit of more than one policy or procedure. If this does occur, SRRO will inform a student of what issues cannot be considered under this Procedure and will direct any non-eligible items to alternative processes. The University reserves the right to determine, in any given case, which internal procedure is the most appropriate. The University’s decision on such matters is final.

Group Complaints

41. A group complaint is where an issue is raised that affects more than one student. It may be more practical for the concern to be considered as a group. A complaint can be considered as a group complaint in the following circumstances:
    1. Each member of the group unanimously nominates a ‘group representative’ to act on their behalf. The group representative is to liaise and act on behalf of the group.
    2. Each member of the group provides written consent to the University that the group representative is to act on their behalf.
    3. Each member of the group confirms that the proposed group complaint is a full and complete articulation of their complaint. This includes the details, impact and proposed outcome.
    4. Each member of the group confirms agreement to all evidence submitted by the group representative.
    5. The group representative consents to the University that they will act in this capacity and agrees to liaise with group members throughout the process.
42. A student will not be able to be a member of a group complaint if they do not meet all the criteria outlined in the above paragraph. In such circumstances, a student will be advised to submit an individual complaint.
43. The University reserves the right to refuse to accept or progress a group complaint. A typical example of a refusal of a group complaint occurs when there is insufficient common ground between the proposed group complaint members. In such circumstances, students are advised to submit individual complaints.

Support

44. All students can seek advice and support through Student Support and Development and/or the University’s Student Union. This may include signposting to alternative University services where appropriate.
45. Guidance relating to this Procedure can be obtained from the SRRO.

Third Party Involvement

46. A student engaging with this Procedure may be accompanied by one other individual at all stages where meetings are taking place. This accompanying individual must be a fellow student, member of staff or Student Union Officer of the University. 
47. The role of the accompanying party is to support a student during any meeting. They must not make representations or speak on behalf of the student unless there are good reasons why such adjustments are needed. All questions will be directed to the student submitting a complaint.
48. This is an internal Procedure, and it is therefore appropriate for students to represent themselves. A third party can only represent a student if there is a compelling reason for this to take place, for example a reasonable adjustment or suffering from such physical or mental incapacity as to prevent the student acting for themselves. In such circumstances, agreement must be obtained in advance by the University.
49. Legal representation and/or accompaniment at any stage of the process may only be permitted in exceptional circumstances and if considered necessary by the University. The University’s decision is final and will be communicated by the SRRO. The University reserves the right to place a complaint on hold if legal proceedings are to take place. Legal accompaniment and/or representation is not usually permitted except where it is agreed by the University in advance. 
50. At all stages of the process, a student must confirm in advance the identity and role of any third-party. Where an individual requested to join poses a conflict or detriment to the integrity of the process, the University reserves the right to request an alternative individual is selected.

Definitions

51. This Procedure utilises the following terminology: 
    1. Complaint: an expression of dissatisfaction by one or more students about a university’s action or lack of action, or about the standard of service provided by or on behalf of the University. 
    2. Complainant(s): an eligible party/parties permitted to pursue a complaint in accordance with this policy and Procedure.
    3. Case: a received complaint considered in accordance with this Procedure.  
    4. Responder/Investigator/Reviewer: a member of the University who is required to undertake decision-making in accordance with this Procedure. 
    5. University: Northeastern University London.

Responsibilities

52. The Student Regulatory Resolution Office (SRRO) is the designated department of the University responsible for managing and overseeing all complaints. 
53. All students and staff should direct all complaints to the SRRO in the first instance. All actions undertaken in accordance with this Procedure must be conducted under the oversight of SRRO in the interest of fairness, quality and assurance in the handling of complaints. The SRRO will provide procedural support and guidance at all stages of the process.
54. The University is responsible for ensuring this Procedure and associated materials are accessible to students. It must also ensure that expectations and processes established in accordance with this Procedure are applied and enforced.

Procedure

Submitting a Complaint

55. Complaints to be considered under this Procedure can be submitted by completing the following Complaint Form for Students.
56. A student is advised to email the SRRO (student.complaints@nulondon.ac.uk) for support in accessing or submitting the Complaint Form for Students, if required.
57. Complaints submitted to the University must be directed to SRRO at the earliest opportunity. 
58. A submitted complaint will be initially assessed to determine eligibility for consideration under this Procedure. This assessment will be conducted by SRRO. Additional enquiries and/or requests for further articulation may be undertaken to determine if a complaint is eligible for consideration. Confirmation of eligibility will be provided where a complaint can be pursued under this Procedure. Where this is not the case, guidance will be provided to a student to assist them in their decision-making. 
59. A complaint is required to clearly state what is causing dissatisfaction and the preferred remedy.
60. A student can typically anticipate a response within seven calendar days.

Stage 1 – Initial Response

61. In the first instance, a complaint will be assigned to the relevant Head of Service/Discipline that is responsible for the specific part of the University where the concern is placed.
62. Matters relating to teaching/learning on a course will typically be assigned to the relevant Head of Discipline.
63. An initial response is typically based on the papers and includes providing additional information/clarification regarding the concern being communicated. Based on the circumstances of the case and discretion of the Stage 1 responder, an initial response may include additional enquiries as considered appropriate. A remedy can be put forward at this stage to ensure a swift resolution. 
64. A student should contact the University immediately after the incident, normally within 14 days.
65. A written response will be provided by the assigned Stage 1 responder, which may also include a verbal discussion. All written outcomes will be issued by SRRO.
66. A Stage 1 outcome will typically be issued within 21 days of a complaint being categorised as a Stage 1 complaint. In some circumstances, it may take longer to issue an outcome and, in such cases, the student will be notified of the delay.

Stage 2 – Formal Investigation

67. The Formal Investigation stage applies when a student has received a response to their Stage 1 (Initial Response) complaint and the outcome received has not addressed their concerns. If this occurs, a student can ask for their concern to be investigated further. This is known as a Stage 2 complaint.
68. In exceptional circumstances, the University may take a decision to escalate a complaint immediately to this Stage 2 Formal Investigation. Students will be informed if this is determined to be the appropriate course of action, when they submit their initial concern to the University. The University decision on the categorisation of a complaint is final.
69. A student should submit a Stage 2 request within 14 days of receiving a Stage 1 (Initial Response) outcome.
70. A Stage 2 request can be submitted by email to the SRRO (student.complaints@nulondon.ac.uk). A complaint form must be completed if not previously done so.
71. All Stage 2 complaints are overseen by the Director for Student Engagement. The SRRO manages this process on their behalf.
72. Prior to a Stage 2 Formal Investigation commencing, a student can expect:
    1. An acknowledgement of receipt when they successfully submit their request. 
    2. Contact from the University about their complaint, usually within seven days, and may ask for more details so the University fully understands the concern(s) communicated.
    3. Confirmation on whether a request is eligible to be investigated at Stage 2.
73. As part of the investigation the University will:
    1. Appoint an appropriate senior member of staff to investigate, with no relevant prior involvement with the complaint subject matter. This can typically be the Faculty Director (for an academic related complaint) or a Professional Services Director/Manager. This member of staff will act as the Stage 2 Investigator to the complaint.
    2. An investigator will consider all appropriate complaint materials and documentation; and
    3. Complete a written report explaining their findings.
74. The Investigator may contact a student or other applicable parties for more information to help them during the investigation process.
75. The Director for Student Engagement will issue a student with a Stage 2 outcome letter to conclude a Stage 2 complaint, taking into account the Investigator’s findings.
76. A Stage 2 outcome will usually be issued within 28 days of a complaint being categorised as a Stage 2 complaint. In some circumstances, it may take longer to issue an outcome and, in such cases, a student will be informed of the delay.

Stage 3 – Review

77. The Review stage of the Procedure only applies when a student has received a Stage 2 (Formal Investigation) response, and they continue to have concerns. In such circumstances, they can ask for a Stage 3 Review.
78. A review is not a reinvestigation but considers a complaint on any of the following three grounds. The three grounds for Review are:
    1. There were procedural irregularities in the investigation of the complaint.
    2. New evidence can be presented which could not be reasonably presented earlier in the process and would have a material impact on the outcome.
    3. The outcome of the investigation is unreasonable based on the weight of the evidence.
79. A Stage 3 Review request should be submitted within 14 days of receiving a Stage 2 outcome. Requests received later than this are not normally considered.
80. To request a review, a student should submit an email to the SRRO (student.complaints@nulondon.ac.uk). The review will be considered solely based upon the contents of the review request. The review request email must contain:
    1. A full articulation of the review request, including the grounds upon which the review is sought.
    2. Any applicable evidence to be considered as part of the review request.
81. A student is advised to email the SRRO for support if required. 
82. All Stage 3 Reviews are conducted by the Registrar. SRRO liaises with all parties on behalf of the Registrar. Where the Registrar has been involved in an earlier stage of a complaint, this function will pass to a different member of the Executive Committee (or appropriate seniority).
83. The Stage 3 Review process will consist of the following steps:
    1. A response will be issued to confirm receipt of a Stage 3 Review request.
    2. The University will contact a student about the submitted review request, usually within seven days, and may ask for more details.
    3. Confirm whether the Stage 3 Review request is eligible.
84. A student will be notified of the outcome of their Stage 3 Review, and the reason for the decision, normally within 21 days of the date a Stage 3 Review request has been accepted and eligibility for consideration has been confirmed. This will also include confirmation of Completion of Procedures. In some circumstances it may take longer than a month to issue an outcome and, in such cases, the University will inform the student of the delay.

Remedies

85. Academic remedies cannot be provided via this Procedure.
86. A range of remedies may be considered and afforded in accordance with this Procedure. Guidance will be provided by the SRRO at all stages where remedies are being considered, however any remedy must be within the gift of the University (in accordance with University policy and procedure).

Alternative Methods to Express Views

87. Feedback is often informal and directed to the applicable area of the University involved with the matter to be discussed. If a student is unsure regarding who to contact, or wishes for feedback to be passed on to the applicable department on their behalf, they can make this request by contacting the Student Regulatory Resolution Office.  
88. Student Voice permits all students to express their views and concerns both formally and informally. The University is committed to maintaining an open environment for views to be discussed. Students can express their views through a range of personnel/roles and can be taken directly into account in university decision-making. Further details can be located here. 
89. The Student Union represents students directly and has the opportunity to directly engage with management and leadership of the University, including through formal governance structures. Students should contact them directly to discuss any comments or concerns present. Further details can be located here.
90. In certain circumstances, the use of mediation or facilitated early-resolution discussions may be a more appropriate method to address a concern. The objective of this process is to provide all parties with an opportunity to be fully heard, to hear each other’s perspectives and to decide how to resolve disputes mutually. All parties must agree to engage in such a process and no party can be compelled to do so. For further details, do get in contact with the Student Regulatory Resolution Office. 
91. The University reserves the right to close/pause a case where alternative methods are being used. 

Office of the Independent Adjudicator for Higher Education

92. Students who have exhausted the University’s internal procedures will be issued with a Completion of Procedures letter and informed that they may make a complaint to the OIA. The OIA’s website (www.oiahe.org.uk) contains full details of the scheme. Students will typically have 12 months to then contact the OIA for external consideration of their case, in accordance with their rules (should a student consider this necessary). 

Data, Disclosing and Reporting

93. All information, including confidential information, is managed in accordance with the University’s data protection obligations and internal policies. 
94. Data on all complaints (including anonymous reports) will be used to regularly inform monitoring and review purposes conducted by the University.
95. It is expected that all students/parties involved with the Complaints Procedure for Students will keep information about the case confidential, and process any information disclosed to them in a lawful manner. 
96. The University will disclose information relating to complaints to the extent that is necessary to comply with legal obligations and they may provide any information that they believe is appropriate to any relevant accreditation, professional, or regulatory body.
97. The Director for Student Engagement will produce an annual report on disciplinary cases for Northeastern London Board. This will detail the number of cases handled at each Level, a summary of the outcomes and highlight any areas for improvement.
98. In addition to the annual report, the Director for Student Engagement will provide Northeastern London Board with quarterly reports, focusing on quantitative data for monitoring purposes. Any significant or outlier cases can be flagged to the Board during these quarterly reports.

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