Complaints and Concerns Procedure

Effective from: July 2025
Policy Owner: Academic Board
Review Date: July 2028

Purpose

The purpose of this policy is to set out the College’s approach to dealing with complaints.

Scope

The complaints procedures can be used by anyone in receipt of college services, including patients/clients, students, and recent students. 

Introduction

The Northern College of Acupuncture NCA confirms its commitment to providing high-quality services and to resolve any problems as quickly as possible. Complaints are an important source of information for improving services for the future. 

Implementation

The Complaints Procedure is split into informal and formal complaints. The College hopes to resolve most complaints on an informal basis, but if a complainant wishes to pursue a formal complaint from the outset, this should be clearly stated.

Complaints should be made within 6 months of the event. This time limit can be waived if there are good reasons why a complaint couldn’t be made earlier.

There are some circumstances where the Principal or College Manager may decide that swift action must be taken in response to a complaint. These include situations  where there is a risk of serious harm, where the impact of the issues raised may have detrimental consequences for the complainant’s mental health, or where the complaint relates to disability support, to serious and repeated failure and/or significant delay in our service, or to issues of a highly sensitive nature. 

Definition of a Complaint

We define a complaint as ‘an expression of dissatisfaction relating to academic, clinical or administrative services, when the complainant has drawn their concern to the attention of the College’.  

This definition does not include complaints that are covered by the following separate College procedures:

• Student Disciplinary Procedures and Appeals
• Student Grievances and Appeals 

Appeals relating to admissions processes and decisions, including eligibility for transferred credit, should be dealt with by following the Admissions Appeals and Complaints Policy in the first instance and the Application Appeals procedure in the second instance. 

These complaint procedures do not apply in situations where a student wishes to make a formal academic appeal. We define a formal academic appeal as ‘a request for a review of a decision taken by an individual or academic body charged with making decisions on students’ progression, assessment and awards’. These decisions include: 

• Marks awarded for assessments and examinations
• Arrangements and guidance provided to students for assessments and examinations
• Requirements for awarding qualifications

 The College and University Verification and Appeals Procedures cover these.  

On occasion a student may submit a complaint which is better dealt with as an appeal or as a grievance, or vice versa. The College Manager, in consultation with the Principal, will decide on re-classification of appeals as complaints or grievances and vice versa. Similarly, sometimes an appeal may also contain elements of a complaint, or vice versa. These cases will normally be dealt with using the appropriate appeals procedures, but variations are possible at the discretion of the Principal. 

Professional Negligence

Any serious case of clinical professional negligence by a member of staff should be referred to the relevant professional body in the UK. Further details of this procedure can be obtained from the British Acupuncture Council (BAcC), the Register of Chinese Herbal Medicine (RCHM) or for nutritional therapy the Complementary and Natural Healthcare Council (CNHC). 

Protocol for Students to Raise Concerns and Resolve Problems

This protocol is designed to ensure that students are able to raise concerns in the most effective way possible and with the least delay. It is important that concerns / complaints are taken through to resolution.

For group issues you should talk first to your student representative who will either raise the issue at any course related meeting or refer the matter using the following protocol. Individual matters may be referred directly using the same protocol. 

Issues related to the teaching clinic or observation days, which cannot be resolved with the Clinic Supervisor should be discussed with the Clinic Director in the first instance.  

Please use this process flow to request support with your complaint:

Early Resolution of Concerns and Informal Complaints

If you experience problems with any aspect of our academic, clinical or administrative services, you should raise your concerns immediately by contacting a member of staff. You can do this verbally face to face or in an online meeting, by email or online message, or in a letter. Our team may be able to resolve your concerns without the need to make a more formal complaint.  

• Please address your concern or complaint to the member of staff most directly involved in the event leading to the concern or complaint, if at all possible, in order to give that person the opportunity to address your concerns. 
• If for any reason you do not feel that this is possible, you should seek advice from the College Manager, Principal or Course Director in order to identify an appropriate alternative mechanism of early resolution.
• Students should also see the “Protocol for Students to Raise Concerns and Resolve Problems” above for further guidance.
• When you raise a concern³ or make an informal complaint, please tell us what outcome(s) you are hoping to achieve.
• It is possible to make an informal complaint anonymously. This may helpfully alert us to an issue we should investigate and address, particularly if we have received other similar complaints. 

How we will respond to your concern or informal complaint: 

In some cases, a staff member will be able to take rapid corrective action, often acting together with other College staff (for example, a lecturer may need to involve the Course Director or Student Services).  

Other options for resolving an informal concern or complaint include: 

• arranging a face-to-face discussion (in person or online) 
• an informal arbitration process (in person or online)
• an informal internal enquiry as a first attempt to find a resolution

The College’s “sorting out” process provides a helpful structure for a face-to-face discussion. Where necessary or requested, a third party can be involved in this process to provide informal arbitration.  

If an informal internal enquiry is necessary, one or more members of staff who are not involved in the complaint will be asked by the College Manager or Principal to conduct an initial investigation and make recommendations. The investigator(s) will make every effort to enable the clear articulation of the issue and to resolve the complaint simply and quickly. The investigator(s) may invite you to a meeting to discuss the matter in an attempt to reach a resolution. At any point in the investigation of an informal concern or complaint, the College Manager or Principal may decide that the concern or complaint should be treated as a formal complaint. 

The staff member dealing with your concern or informal complaint will respond to you within 10 working days of receiving your communication. If we can’t give you a full response within that time, we will advise you when we will be able to do so. 

The staff member dealing with your concern or informal complaint will keep a brief written record of your concern or complaint and our response to it. Where appropriate and proportionate we will write to you setting out the outcome. Records will be stored securely within your student file. 

If you have told us about problems and you are not satisfied with our response, you may wish to make a formal complaint. The formal complaints policy and procedure is detailed below. 

Formal Complaint

To make sure that we record your formal complaint accurately you should put it in writing (if you have a disability that makes it difficult for you to send a written complaint, please contact us so that we can discuss alternatives) and send it to us by post or email. Concise numbered points can be a helpful way to set the situation out clearly. Please tell us what outcome(s) you are hoping to achieve from your complaint. You must provide your name in order to make a formal complaint⁴.  

We will share your name and details of your complaint with staff involved in running the complaints procedure and with staff appointed to investigate your complaint when an investigation is necessary. We will also normally share these details with any person(s) complained about and any witnesses; you can ask us not to do this in situations where it would be inappropriate, but please be aware that this may seriously limit our ability to investigate and resolve your complaint.  

It is possible for the Principal or the College Manager to decide to treat an informal complaint or a Stage One formal complaint as a Stage Two complaint. This will normally apply when the issues raised are complex and will require detailed investigation, for example where a complaint relates to the conduct of staff members or covers a number of different incidents. 

Stage One

Contact the member of staff responsible for providing the service you are complaining about. For example, your Course Director for a complaint about teaching and learning, Student Services for a complaint about communications or record keeping, the Clinic Supervisor for a complaint about clinical services. If you want to complain about more than one area, you should either contact each area separately or write to the College Manager. If you are not sure which member of staff to contact, ask the College Manager. Your communication with us should include: 

• Full details of your complaint and all matters relating to it  
• Details of other areas of the College that you have had contact with, in relation to your complaint  
• Copies of any previous correspondence with us related to your complaint. 
• You should also tell us what you think we should do to resolve your complaint. 

The member of staff you contacted will send you a reply within 10 working days of receiving your complaint. If we can’t give you a full reply within that time, we will advise you when we will be able to do so. To guarantee confidentiality, we will send our reply to you by email if you have a nca.ac.uk email address, otherwise we will reply by post unless you specifically ask us to reply by email. In the case of a complaint from a student that relates to academic standards or the quality of the learning opportunity, we will also inform the validating University.  

The Principal or the College Manager may decide at any point that a Stage One formal complaint should be treated as a Stage Two formal complaint. 

Stage Two

If you are not satisfied when you receive our reply to your complaint that we have done everything possible to answer it, you can ask the College Principal to further investigate your case. You should include the same information listed under Stage One.   

The Principal or their representative will send you an acknowledgement of your complaint within five working days of receiving it and will tell you who they have appointed to investigate your complaint. To investigate your complaint, the Principal will either: 

• Appoint a senior member of staff 
• Or appoint two or more members of staff 
• Or, for serious complaints, appoint one or more members of staff plus an external person to assist the investigation 

The investigator(s) will send you a full response within 10 working days of the date of the Principal’s acknowledgement letter or, if that is not possible, contact you to let you know when you can expect a full reply. We will do our best to provide you with an estimate of how long the investigation may take. 

The investigator(s) will make every effort to enable the clear articulation of the issue and to resolve the complaint simply and quickly. The investigator(s) may invite you to a meeting to discuss the matter, to ensure they fully understand your complaint, and in some cases to attempt to reach a resolution. You will be allowed to be accompanied by a friend to support you, if you wish. The investigators may also interview others involved in your complaint (e.g. students or members of staff) and scrutinise documents, and they may ask you to provide evidence relevant to your complaint, which may include independent medical evidence, reports by professionals, financial information or witness statements. The investigators will produce a written report summarising their findings, whether your complaint is upheld, partially upheld or not upheld, and giving any recommendations. Their report will be shared with you, usually with others involved in the complaint, and with the Principal. If your complaint involved another student or member of staff, it may not be appropriate for us to share specific details with you, particularly where disciplinary action is being taken. 

The Principal or a senior member of staff appointed by the Principal will respond to your complaint and to the report of any investigation carried out. This response will give you clear reasons for decisions we have reached. If actions for the College have been identified, we will state which College Board or Committee will have oversight to ensure that appropriate action is taken. Wherever appropriate we will use the information gathered in the complaint process to improve our services to students and patients.  

All complaints will be handled sensitively with regard to confidentiality. Information will be released only to those who need it for the purposes of investigating or responding to your complaint. However, it may be necessary to ask staff or students involved in the complaint to comment on reports or statements made. In some circumstances it may be possible to provide anonymised reports or statements, but this is not always possible. As a result, we may not be able to investigate your complaint if you do not wish it to be disclosed to people involved in the complaint. If this is the case, we will make a brief note of your complaint and close the complaint. 

You can choose to nominate a friend or, with their agreement, a student representative to support, advise or represent you at this and subsequent stages of the process.  

Stage Three - Review by the Board of Directors/Trustees

Once you have a full reply from the senior member of staff, if you are still not satisfied that we have done everything possible to answer your complaint, you can ask the Principal to refer it for review by the Board of Directors/Trustees. You can ask for a review on grounds including: 

• A review of the procedures we have followed in relation to a formal complaint. 
• A consideration of whether the outcome was reasonable. 
• There is new material evidence which you were unable, for valid reasons, to provide earlier in the process. 

The Principal or their representative will acknowledge your request within five working days. The Chair of the Board of Directors/Trustees will normally ask one or more of the trustees to investigate and then advise the Board as to whether we have handled the matter fairly in line with our policy and procedures, whether the decision reached was reasonable, and whether we should do anything else. The Directors/Trustees will reply in writing to your complaint within 15 working days of the date of the Principal’s acknowledgement letter or, if that is not possible, contact you again to let you know when you can expect a full reply. The reply will set out the Board’s decision. It is possible for the Board to recommend referring your complaint back to stage two for reconsideration. 

This stage may take longer because the Directors/Trustees will need to see previous correspondence and documentation and may seek advice from other areas, and may also wish to discuss things with you. The reply from the Directors/Trustees will explain the basis of their decision. The Directors’/Trustees’ decision is final within the NCA’s procedures, however students may refer the matter to the validating university and thereafter the Office of the Independent Adjudicator for Higher Education (the OIA) by following stage four of this procedure. All students have the right to refer the matter to the OIA once internal procedures have been completed. 

Stage Four – Review by the Validating University

If you are dissatisfied with the NCA’s Board of Directors / Trustees outcome, you may refer the matter to the Deputy Vice-Chancellor (Education) at the validating university for review within 21 days from receiving the NCA’s Board of Directors / Trustees outcome. 

You may refer the outcome for review to the validating university’s Deputy Vice-Chancellor (Education) if: 

a) The NCA’s procedures were not followed properly. 

b) The outcome was not reasonable. 

c) You have new material evidence which, for valid reasons, you were unable to provide earlier in the process. 

To request a review of the outcome, you should write to the Registrar at the HSU () providing a copy of the outcome and an explanation of why you are requesting a review, in addition to any evidence to support your request. 

Further to the review, the validating university’s Deputy Vice-Chancellor (Education) may either uphold the original outcome or refer the case back to the formal stage for reconsideration by the NCA. 

Where the case is referred back to the formal stage, reconsideration of the case will be undertaken as soon as possible by the NCA, and where practicable within 90 calendar days. 

The decision of the validating university’s Deputy Vice-Chancellor (Education) will be final and a Completion of Procedures Letter shall be provided to you as soon as possible and within 28 days confirming the reasons and review decision outcome. 

Thereafter you have the right to refer the matter to the OIA (http://www.oiahe.org.uk/). You must refer the matter to the OIA within 12 months of the date of your Completion of Procedures letter. 

Rights and Responsibilities 

We will: 

• Deal with all complaints within the time limits set out in this document
• Make sure that we deal with all the points you raise, and that our replies explain the outcomes clearly
• Handle your complaint confidentially and only give people the information that is needed to carry out a proper investigation and make a full response
• Keep records of all complaints 
• We will store records of complaints separate from other records
• Make sure that no complaint you have made in good faith will be used to your disadvantage in the future
• Treat all complaints with equal importance 
• Treat an anonymously made complaint as an informal complaint
• Always be polite, act reasonably and fairly and treat the processes with respect

If you are making a complaint, you should: 

• Give us full details of your complaint
• Deal sensitively with issues that involve students or staff
• State your name and contact details, if making a formal complaint
• Always be polite, act reasonably and fairly towards other students and staff, and treat the processes with respect

The College has a responsibility to protect our students and staff against unacceptable behaviour. This includes abusive or aggressive behaviour or language, unfounded accusations, unreasonable persistence, unreasonable demands or expectations of our resources, and intransigence. In these circumstances we may restrict your access to our staff and our complaints procedures. We will inform you if we decide to do so, and you can ask the Board of Directors/Trustees to review such a decision. 

Complaints against the Principal

Complaints against the Principal should be sent to the College’s Board of Directors/Trustees. 

Vexatious Complaints

A complaint can be rejected at any stage if an investigation into the complaint finds that it is vexatious in nature. A vexatious complaint is one that is manifestly unjustified, inappropriate or improper. In deciding whether a complaint is vexatious, the investigation will consider the motive, context and history in which a complaint is made. In identifying vexatious complaints, we will do our best to distinguish between complainants who are raising genuine concerns and people who are simply being difficult. We recognise that:  

• complainants may often be aggrieved, frustrated or have other reasons for their behaviour, and therefore the focus must be on careful consideration of the merits of the case rather than the attitude of the complainant; and 
• every complaint must be considered on its merits and, even if someone has made a vexatious complaint in the past, it must not be assumed that any other complaint they make will also be vexatious. 

The need to consider every complaint on its merits cannot be over-emphasised. However, indicators of vexatious complaints include abusive or aggressive language, unfounded accusations, personal grudges, frequent or overlapping complaints, unreasonable persistence, unreasonable demands or expectations of our resources, intransigence, trivial or frivolous complaints which are out of proportion to their significance,  complaints which remain vague and undefined despite our attempts to help you to clarify them, complaints which are obsessive, harassing or repetitive, complaints which may be meritorious but are pursued in an unreasonable manner, complaints which are designed to cause disruption or annoyance, and demands for redress which lack any serious purpose or value. 

If your complaint is found to be frivolous or vexatious we will write to you explaining our reasons for rejecting your complaint and terminating procedures. You can appeal this decision in writing to the Board of Directors/Trustees. 

Sources of Advice

If you would like advice prior to making a complaint or at any point in the complaint procedure, the College Manager or Principal will be happy to help you.

Support and advocacy

Various forms of support and advocacy are available to complainants. Please ask the College Manager or Principal for advice.  

Students are encouraged to ask for support during the complaint process from their personal tutor or their student representative. Our counselling service may also be helpful. 

The Principal or College Manager may make reasonable adjustments to the complaints procedures to take account of the individual needs of a student. They will keep a record of any such adjustments. 

Group Complaints

Occasionally a group of people may wish to complain. A group must nominate a single spokesperson to speak on their behalf. The College will work with the spokesperson to ensure as far as possible that the views of all members of the group are fairly represented. 

Complaints to the Office of the Independent Adjudicator (OIA)

Once the College’s complaints procedures have been exhausted, you may be able to complain to the Office of the Independent Adjudicator. The OIA’s website contains details all the pertinent details at www.oiahe.org.uk 

We will write to you at the completion of any formal complaint process or appeals process, and this letter will meet the OIA’s requirements for a “completion of procedures” letter. 

Complaints to Professional Bodies

If you are not satisfied after pursuing the College’s complaints process you can contact:

Complaints to NTEC

It is possible to complain to the NTEC if you think there is a breach of an Essential Requirement, criterion, policy or procedure of the NTEC. NTEC will not normally pursue a complaint unless you have already followed the College’s grievance and complaints procedures.  

Ensuring Effectiveness of the Procedure

The Board of Directors/Trustees and the Academic Board will receive a summary of all formal complaints from students, and of informal complaints from students when they are cumulative. These are standard agenda items for both Boards. Summaries will include information on the complaint and on recommendations and agreed actions. The validating university will receive a summary of formal complaints from students and of informal complaints when they are cumulative as part of annual monitoring and reporting processes. 

These reports to Boards and the validating university will not normally name the complainant(s) and confidential information will not be shared.  

The sharing of summaries of complaints, recommendations and agreed actions at Academic Board enables us to provide this information to staff and student representatives. The Board may decide to share this information more widely with staff and students, particularly when this will help to raise awareness of the procedures and build confidence in their transparency and effectiveness. 

Management team agendas also have a standard item “Corrective and Preventative Actions” which is used to discuss any complaints, concerns or other feedback received from students, staff or patients/clients (as well as any positive praise received). This importantly includes informal complaints or concerns.  

The focus of these processes is on ensuring that issues have been resolved to the satisfaction of all parties whenever possible, and that lessons for the future are identified and acted on. 

Formal complaints, and informal complaints when cumulative, inform our internal processes of evaluation and performance review. Reports of investigations and our responses to complaints may be copied into internal personnel files so they are readily available for performance reviews. 

The complaints procedure is reviewed every three years. Both the Academic Board and the Board of Directors/Trustees agree proposed amendments.