Complaints policy and procedure
Policy owner - Managing Director
Approved by - Directors
Version - 2.2
Effective from - September 2026
Next review - September 2027
Review trigger - Earlier review where legislation, REC guidance, Fair Work
Agency guidance, safeguarding requirements or DCM procedures change
1. Policy statement
DCM Recruitment Ltd is committed to providing a high level of service to candidates, agency workers, clients, partner schools and other organisations. If someone is dissatisfied with our service, we want them to tell us so that we can investigate the concern, put matters right where appropriate and improve our standards.
Complaints will be handled fairly, promptly, objectively and confidentially. DCM Recruitment Ltd will not disadvantage, victimise or treat a person less favourably because they have raised a genuine complaint.
2. Scope
This procedure applies to complaints about DCM Recruitment Ltd's recruitment and work-finding services. This includes complaints relating to customer service, recruitment conduct, assignment information, pay information, terms of engagement, Key Information Documents, equality and discrimination, data handling, vetting, safeguarding, suitability, professional conduct or other aspects of our service.
Internal employment grievances raised by DCM employees about their own employment will normally be dealt with under the Company's grievance arrangements. However, any safeguarding, regulatory, data protection or public-interest concern identified through a grievance will be escalated under the appropriate DCM procedure.
3. Accessibility and communication of this procedure
DCM Recruitment Ltd will ensure that this Complaints Policy and Procedure is easily accessible to clients, candidates and work-seekers. A current copy will be made available on the DCM Recruitment Ltd website and can also be provided by email or in another accessible format on request.
Candidates and work-seekers will be made aware of this procedure during registration or onboarding and will be provided with a link to, or copy of, the current procedure as part of their engagement documentation.
Clients will be made aware of this procedure when Terms of Business are issued or at another appropriate stage when the working relationship is established.
DCM staff responsible for candidate registration, client onboarding or compliance administration must ensure the current procedure is signposted and must not direct candidates or clients to superseded versions.
4. How to make a complaint
Complaints may be made verbally or in writing. We encourage concerns to be raised promptly so they can be investigated fairly and resolved wherever possible.
In the first instance, complaints should be directed to the Managing Director / Complaints Lead using the following contact details:
• Email: admin@dcmrecruitment.com
• Post: Managing Director / Complaints Lead, DCM Recruitment Ltd, 3 Shire Garth, Welbury, North Yorkshire, DL6 2SS
• Verbally to the Managing Director, another Director or a member of DCM staff. Where a complaint is made verbally, DCM will make a written record and pass it to the Complaints Lead. A complainant may request that the process is handled entirely in writing. They do not need to attend a face-to-face meeting in order for their complaint to be investigated or resolved. Reasonable adjustments will be made where required to make the complaints process accessible.
Where possible, the complainant should provide their name and contact details, what happened, relevant dates and people involved, any supporting information and the outcome they are seeking. A complaint will not be rejected simply because all of this information is unavailable.
Anonymous complaints will be considered where there is enough information to investigate them, particularly where safeguarding, legal or regulatory concerns are raised.
5. Data protection complaints
A complaint about DCM Recruitment Ltd's handling of personal data, or the personal data of an individual represented by the complainant, may be raised under this procedure.
DCM aims to acknowledge all complaints within the general timescale set out below. In any event, a data protection complaint will be acknowledged within 30 days of receipt and investigated without undue delay. DCM will respond in accordance with applicable data protection law and its Data Protection & GDPR Policy.
Where a data protection complaint identifies a suspected personal data breach, subject access request or other data subject rights request, it will also be referred immediately to the person responsible for data protection compliance so that any separate statutory timescale can be met.
6. Safeguarding and urgent concerns
A complaint that indicates a child may be at risk of harm, or raises an allegation about a person working with children, will be treated as a safeguarding matter immediately. The ordinary complaints stages must not delay action required to protect a child.
The concern will be escalated without delay to the DCM Designated Safeguarding Lead and, where relevant, to the client school's Designated Safeguarding Lead. DCM will follow current Keeping Children
Safe in Education requirements and its safeguarding and safer recruitment procedures, including referral to the Local Authority Designated Officer, Disclosure and Barring Service, police or another relevant authority where the applicable threshold is met.
If the complaint concerns the DCM Designated Safeguarding Lead or a Director, it will be referred to another Director who is not implicated. Where a suitable internal reviewer is not available, DCM will arrange an appropriately independent review or make the required external referral.
Whistleblowing or other public-interest concerns will be dealt with under the relevant DCM arrangements.
No person will be penalised for raising a genuine safeguarding or public-interest concern in good faith.
7. Complaints procedure
Stage 1 - Informal resolution
Where appropriate, the complainant should first contact the Managing Director / Complaints Lead so that DCM can try to resolve the matter informally. DCM will aim to resolve straightforward concerns within 5 working days.
Stage 1 may be bypassed where the complaint is serious, involves safeguarding, discrimination, alleged misconduct, regulatory non-compliance, a conflict of interest or where informal resolution would otherwise be inappropriate.
Stage 2 - Formal complaint and investigation
If the complaint is not resolved informally, or informal resolution is not appropriate, it will be treated as a formal complaint.
• DCM will acknowledge the formal complaint within 3 working days and confirm the name of the person dealing with it.
• The complaint will be recorded in DCM's central complaints register within 1 working day of receipt.
• The investigator will normally be a Director who was not directly involved in the matter.
• The investigator may review emails, system records, notes, contracts, compliance documents and other relevant evidence and may seek information from the complainant, staff member, client, umbrella company or another relevant third party.
• Where appropriate, a staff member involved in the matter may be asked to provide a written response within 5 working days.
• The investigator may offer a meeting or telephone discussion where this would help clarify or resolve the matter. A complainant is not required to attend a meeting and may choose to deal with the complaint entirely in writing.
DCM will aim to issue a detailed written outcome within 15 working days of receiving the formal complaint. The outcome will explain the findings, whether the complaint is upheld in full, upheld in part or not upheld, and any action DCM proposes to take.
If DCM cannot meet the stated timescale, the complainant will be informed of the reason for the delay and given a revised timescale.
Stage 3 - Internal appeal
If the complainant remains dissatisfied, they may request an internal appeal within 5 working days of receiving the Stage 2 outcome. The appeal request should explain why they believe the decision or process should be reviewed.
Another Director who was not involved in the original investigation will review the decision. Where this is not possible because of a conflict of interest or the involvement of all Directors, DCM may appoint a suitably independent external reviewer.
The review will normally be completed within 10 working days. DCM will then provide the complainant with its final internal decision within 5 working days of the review being completed, explaining the reasons for the decision.
If these timescales need to change, DCM will inform the complainant and explain why.
Stage 4 - External review or regulatory complaint
If the complainant remains dissatisfied after DCM's internal process, they may raise the matter with an appropriate external body. Use of DCM's internal process does not remove or restrict any statutory or regulatory right to approach an external body at an earlier stage.
• Recruitment and Employment Confederation (REC): complaints about potential breaches of the REC Code of Professional Practice may be referred to the REC under its current Complaints and Disciplinary Procedure.
• Fair Work Agency (FWA): complaints about employment agency legislation or relevant agency worker rights may be raised with the Fair Work Agency using the current government complaints route.
• Acas: independent advice may be sought about employment rights and workplace disputes.
• Safeguarding or criminal matters may be referred to the relevant school, Local Authority Designated Officer, Disclosure and Barring Service, police or another safeguarding authority as appropriate.
DCM Recruitment Ltd will cooperate appropriately with the REC, the Fair Work Agency and other lawful regulatory or safeguarding enquiries.
In all cases, DCM will comply with any statutory procedure that applies to the complaint.
8. Outcomes and corrective action
Possible outcomes may include an explanation or clarification, correction of records, an apology where appropriate, changes to a recruitment or compliance process, staff training or supervision, contractual or disciplinary action, safeguarding action, referral to an external body or another proportionate remedy.
Where a complaint identifies a wider or systemic issue, DCM will consider whether other candidate, worker or client records may be affected and whether wider corrective action is required.
9. Staff responsibilities and training
All DCM employees, Directors and consultants who deal with candidates, workers or clients must understand this procedure and know how to recognise, record and escalate a complaint.
Complaints handling forms part of staff induction and ongoing training. Staff must:
• listen professionally and avoid becoming defensive or dismissive;
• record complaints accurately and promptly;
• avoid promising an outcome before the matter has been investigated;
• escalate safeguarding, discrimination, data protection, pay or regulatory concerns without delay;
• preserve relevant emails, messages, notes and system records;
• follow any instructions given by the Director responsible for the investigation; and
• maintain confidentiality throughout the process.
10. Confidentiality and data protection
Complaint information will be handled in accordance with DCM Recruitment Ltd's Data Protection & GDPR Policy and Data Retention & Secure Disposal Policy. Information will only be shared where this is necessary and lawful for investigating the complaint, safeguarding individuals, meeting legal or regulatory obligations or demonstrating compliance.
Where a complaint involves another person, DCM may need to share relevant information with them to investigate the matter fairly. Personal, criminal record or safeguarding information will not be disclosed more widely than is necessary and lawful.
11. Records, monitoring and continuous improvement
DCM Recruitment Ltd will maintain a central complaints register. The register will record the date received, complainant, subject matter, investigator, key actions, outcome, appeal information and any corrective or improvement action.
Complaint records, investigations and outcomes will normally be retained for six years in accordance with the Company's Data Retention & Secure Disposal Policy, unless a different legal, safeguarding or regulatory retention requirement applies.
The Directors will review complaints to identify themes, recurring issues, response times and opportunities for improvement. Learning from complaints may result in changes to training, supervision, policies, procedures or DCM's continuous improvement log.
12. Related documents
• DCM Recruitment Ltd Staff induction, training and development pack
• DCM Recruitment Ltd Customer Service and Continuous Improvement Policy
• DCM Recruitment Ltd Equality, Diversity and Inclusion Policy
• DCM Recruitment Ltd Data Protection & GDPR Policy
• DCM Recruitment Ltd Data Retention & Secure Disposal Policy
• DCM Recruitment Ltd Recruitment, Selection and Vetting Policy
• DCM Recruitment Ltd safeguarding and safer recruitment procedures
• Current REC Code of Professional Practice and REC Complaints and Disciplinary Procedure
• Current Fair Work Agency guidance for employment agencies and employment businesses
• Current Keeping Children Safe in Education statutory guidance
13. Review
This policy will be reviewed at least annually and sooner where there is a significant complaint, audit finding, change in legislation, REC guidance, Fair Work Agency guidance, safeguarding requirements or DCM Recruitment Ltd's working practices. Revisions will be approved by the Directors and communicated to relevant staff.