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November 2023

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This policy aims to articulate Council’s commitment to dealing with complaints as a core
part of our business and a customer’s right to make a complaint.
Council values complaints and encourages people to contact us when they have a problem
with our services, actions, decisions, and policies. Council is committed to:
Enabling members of the public to make complaints about Council.
Responding to complaints by taking action to resolve them promptly and deal
with them efficiently, impartially and courteously.
Learning from complaints to improve our services.
Council treats every complaint on its merits through clear and consistent processes.
This policy is based on the Victorian Ombudsman’s – Guide Councils and Complaints: A
Good Practice Guide 2
Edition (April 2023).
2.1 This policy covers all complaints from members of the public about Council services,
Council officers, Council contractors and decisions made at Council meetings.
2.2 This policy applies to all council officers, including third-party contractors carrying
out services on Council’s behalf.
2.3 This policy excludes complaints governed by relevant legislation or acts subject to
statutory review that are dealt with through separate mechanisms. The following list
provides examples but is not exhaustive, and complaints falling under these must
be handled according to their respective requirements:
Building Act 1993
Charter of Human Rights and Responsibilities Act 2006
Disability Discrimination Act 1992
Health Records Act 2001
Infringements Act 2006
Local Government Act 2020
Planning and Environment Act 1987
Privacy and Data Protection Act 2014
Public Health and Wellbeing Act 2008
The Australian Standard on Fraud and Corruption Control (AS 8001:2021)
The Child Wellbeing and Safety Act 2005
The Public Interest Disclosures Act 2012
2.4 This policy does not cover complaints against Councillors or the Chief Executive
2.5 This policy does not cover internal staff grievances, internal allegations of staff or
contractor misconduct.

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For the purposes of this policy, Council adopts the following definitions:
Refer to the table below
for examples of a
A communication, whether orally or in writing, to the Council
by a person of their dissatisfaction with:
The quality of an action taken, decision made, or service
provided by an officer or a contractor engaged by the
The delay by a Council officer or a contractor engaged by
the Council in taking an action, making a decision or
providing a service.
A policy or decision made by a Council officer or a
Third parties carrying out services on behalf of Council.
Council Officer
A paid employee of Council.
The person/people (resident, ratepayer, business owner,
visitor) who has expressed dissatisfaction (refer to complaint
definition above).
Customer facing staff
Council staff whose primary role involves interacting with
customers to respond to enquiries, accept payments, and
provide subject specialist advice and services to users of
Council services.
A complaint is considered resolved once an initial
investigation has been conducted and the customer has been
updated regarding the service recovery action taken or
Service Request
Refer to the table below
for examples of a service
A request for help in obtaining a new service, getting
information from Council, or to inform us about a matter for
which Council has responsibility.
The table below demonstrates examples of a request for service and a complaint. This is an
extract from the Victorian Ombudsman’s Complaints Best Practice Guide
Service Request
My bin was out but wasn’t collected this
morning. Can you pick it up?
I forgot to put my bin out, can someone
collect it?
You haven’t sent out my rates notice.
Can you tell me when my next rates
payment is due?
The Council shouldn’t have approved a
development on Main Road.
What is the process for objecting to the
development on Main Road?
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Service Request
The Council’s website doesn’t have enough
information about when a planning permit is
needed for a pool.
Can you tell me whether a planning permit
is required for a backyard pool?
Council’s investigation into noise from a
business wasn’t rigorous, and didn’t look at
peak times. More investigation is needed.
My neighbour’s business is very noisy. Can
you make it stop?
A pothole I reported to Council two months
ago hasn’t been fixed, and is getting worse.
Could Council fill in a pothole in my street?
4.1 Commitment
Council recognises customers’ right to complain and is committed to resolving the
complaints Council receives. Council considers complaint handling part of our core
responsibility to serve the community to continually improve service delivery, so our
services are accessible equitable, inclusive, responsive and of high quality.
4.2 Accessibility
Council actively and respectfully assists the community throughout the complaints
process, tailoring our assistance to meet their specific needs. This may include providing
support in languages other than English, accommodating individuals living with
disabilities, considering various educational levels, addressing the ‘digital divide’, or any
other relevant requirements.
4.3 Transparency
Council makes it clear how to complain, where to complain and how the complaint will be
handled. The steps taken to respond are recorded and will provide a trail of what has
taken place.
4.4 Objectivity and Fairness
Complaints are dealt with courteously, respectfully, and impartially within established
timeframes. They are assessed on merit and facts while paying attention to
circumstances of hardship or other barriers to equity that the complainant might face.
4.5 Confidentiality
The complaints handling system protects the personal information of people making a
complaint in accordance with our obligations under privacy laws and internal policy.
Council provides clear information about how personal information is handled. Complaint
data is de-identified if reported on more widely.
4.6 Accountability
Council is internally and externally accountable for our decision-making and complaints
handling performance. Council will provide explanations and reasons for decisions and
ensure our actions are subject to appropriate review processes.

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4.7 Continuous Improvement
Council acts on complaints promptly, as set out in this policy. Council regularly analyses
complaints data to find ways to improve how our operations and service delivery. Council
then implements these changes.
5.1 Making a Complaint
Customers may contact us by their preferred method to lodge a complaint. Council
accepts complaints from authorised representatives if a person is unable or does not want
to lodge a complaint themselves.
9249 4000 Monday to Friday: 8.45 am – 5 pm
Feedback and Complaints
PO Box 70, Sunshine VIC 3020
Brimbank Community and Civic Centre
301 Hampshire Rd, Sunshine
Keilor Community Hub
704b Old Calder Highway, Keilor
Brimbank is committed to ensuring that the information is available to the
widest possible audience
Website Language Translations
Brimbank City Council Website can be translated into multiple languages
by visiting the following webpage Brimbank City Council Website
Language Translations and clicking on the language you wish to use.
Translating and Interpreting Service (TIS)
The Department of Home Affairs provides the TIS National Interpreting
Service for people who do not speak English and for English speakers who
need to provide information. TIS National has access to more than 1400
contracted interpreters across Australia who speak more than 160
languages and dialects.
The service is available 24 hours a day, seven days a week, for people
and organisations needing interpreting services.
Hearing and speech impaired
If you’re Deaf or Hard of Hearing, call us through the National Relay
Service (NRS).
TTY users phone NRS on 133 677 and ask for 9249 4000.
Speak and Listen (speech-to-speech) users phone NRS on 1300 555
727 and ask for 9249 4000.
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Note: Council will also accept anonymous complaints and thoroughly investigate the issue utilising all
available information. Council cannot provide feedback, responses or information on the outcome of
an anonymous complaint.
5.2 The Complaints Handling Process
Receiving the Complaint
Customers lodge their complaints via their preferred method.
Council aims to resolve complaints at the first point of contact and records all
details of the complaint.
If Council is unable to resolve a complaint at the first point of contact, it will be
referred to the relevant department for investigation.
Council will provide a reference number and let the complainant know the
expected timeframes and what happens next.
All complaints will be acknowledged within five business days.
If the complaint does not relate to Council, Council will refer the complainant to
an appropriate organisation or agency.
Four-Tier Approach to Complaints
Tier 1: Standard Complaint
What is a standard
Standard complaints relate to the quality, delay or failure to
deliver a service. The actioning officer can provide quick and
mutually acceptable solutions to address any grievances raised at
the first point of contact.
Who will it be
assigned to for
Any customer facing officer can receive and resolve a complaint.
Tier 2: Complex Complaint
What is a complex
Complex complaints are grievances that cannot be resolved at the
first point of contact and require investigation. A Council officer
will conduct an investigation, gathering additional information to
make an informed decision. You will be kept informed throughout
the process, and Council will provide you with a written
explanation of the decision at the end of the investigation.
Who will it be
assigned to for
The Complaints Resolution Officer will work with relevant staff and
Senior Council Officers to resolve the issue.

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Tier 3: Escalated Complaint
What is an
If the customer is dissatisfied with Council’s response to their
complex complaint, they will be offered the option to request an
internal review, which is Tier 3 of our process. A senior officer will
conduct an independent assessment to determine if the complaint
should have been handled differently, and this could result in
either upholding or overturning the original decision.
Who will it be
assigned to for
A senior officer who was not involved in the investigation or
services at tier 1 or tier 2 of the complaints handling process.
Tier 4: External Review
What is an external
If the customer remains dissatisfied with Council’s decision,
Council will guide the complainant on how to pursue an external
review, which is Tier 4 of our process. At this stage, customers
can refer complaints to independent oversight bodies such as the
Ombudsman, Local Government Inspectorate, or a tribunal or
court. Council actively participates and cooperates with the
external review process during Tier 4.
Who will it be
assigned to for
A senior officer will provide guidance to the complainant on the
process for engaging the appropriate external organisation. These
may include but are not limited to:
Victorian Ombudsman
Local Government Inspectorate
Office of the Victorian Information Commission
Independent Broad-based Anti-Corruption Commission
Victorian Human Rights and Equal Opportunity Commission
Victorian Electoral Commission
Victorian Civil and Administrative Tribunal (VCAT)
Fines Victoria
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5.4 Timelines for Resolving Complaints
Council will endeavour to resolve your complaint on the same day. However, if your
complaint cannot be resolved, it will be referred to the appropriate area for further
investigation. Council has committed to the following timelines to provide timely
resolutions of complaints.
Acknowledge receipt of the complaint. Within 5 business days
Investigate and resolve the standard or
escalated complaint and advise the
complainant of the outcome.
Within 30 business days
Provide updates on the progress of a
complaint or internal review where it is
taking longer than 30 business days to
investigate and resolve.
Within 30 business days and
ongoing every 30 business days
Acknowledge the request for an internal
Within 5 business days
Complete the internal review and advise
the complainant of the outcome.
Within 30 business days
5.5 Outcomes and Remedies for Resolving Complaints
Where Council finds that we have made an error, Council will always offer an
acknowledgement and apology to the complainant. Council will also take steps to address
the situation.
Possible outcomes may include:
An explanation of why the error occurred and the steps taken to prevent it from
happening again.
A reversal of a decision.
A subsequent change in policy, procedure or practice.
Disciplinary action.
Referral to another agency.
5.6 Unreasonable Complaint Conduct
Most complainants who lodge a complaint with Council act reasonably and responsibly in
their interactions with us.
Unreasonable conduct is behaviour by a complainant which, because of its nature or
frequency, raises substantial health, safety, resource, or equity issues. Complainant’s
behaviour will be inappropriate and unacceptable when they involve:

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Unreasonable persistence – can include excessive communication, seeking
different answers from various officers, reframing old complaints, and refusing to
accept investigation outcomes.
Unreasonable demands – can involve insisting on immediate responses,
addressing every minor point, demanding unauthorised information, and seeking
higher-level involvement without reason.
Unreasonable lack of cooperation – encompasses sending excessive information,
providing minimal details, offering information incrementally, rejecting reasonable
requests for information.
Unreasonable arguments – can involve emphasising minor issues and making
baseless allegations.
Unreasonable behavior – can entail verbal abuse, aggression, harassment, and
making threats.
Unreasonable complainant conduct will be monitored and recorded by Council. Where
Council identifies a complainant has become unreasonable, Council has the responsibility
and authority to restrict access for the complainant, and may apply one or more of the
following limitations:
Who the complainant has contact with - limiting a complainant to a sole contact
What the complainant can raise with us - restricting the subject matter of
communications that Council will consider and respond to.
When the complainant can have contact - limiting contact with our organisation to
a particular time, day, or length of time, or curbing the frequency of contact.
Where the complainant can make contact - limiting the locations where face-to
face interactions are held to secured facilities or areas of the office.
How the complainant can make contact - limiting or modifying the forms of contact
Council takes the action of applying limitations very seriously. Before limiting contact,
Council will consider the Victorian Charter of Human Rights and Responsibilities Act 2006
and any other legal obligations. Council will ensure that limits imposed on customers are
proportionate to the conduct. Initial restrictions may be reviewed, and further restrictions
applied if the complainant fails to follow the measures put in place.
The complainant will be informed in writing of the measures being implemented, the
reason for the measures and the effective date. A review of restrictions will occur at least
every six months to consider whether it is appropriate to retain the restrictions.
5.7 Other Complaints
Privacy complaints
If a person is dissatisfied with Council’s handling of their personal, sensitive or health
information, a complaint may be made to Council’s Privacy Officer.
Complaints should be made in writing to:
Senior Freedom of Information and Privacy Officer
Brimbank City Council, PO Box 70, Sunshine Victoria, VIC, 3020
or via email to:
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Disclosures about improper conduct, including corrupt conduct
Alleged improper conduct, which includes corrupt conduct, can be reported as Public
Interest Disclosures. Disclosures may be made to the Council’s Public Interest Disclosures
Coordinator, Public Interest Disclosures Officer (PID) or the CEO, and they will be handled
in accordance with the Council’s Public Interest Disclosures Act Procedure.
The PID Coordinator may be contacted on 9249 4947 or 0409 421 690 or
Complaints about Councillors
Complaints about Councillors will be dealt with in accordance with the relevant legislation
and procedures, depending on the nature of the complaint and whether it comes from a
member of the public, Council officers, another Councillor or from a group of Councillors.
Relevant legislation includes the Local Government Act 2020, Public Interest Disclosure Act
2012 and the City of Brimbank Public Interest Disclosures Procedures. There are a range
of external integrity agencies that deal with complaints regarding Councillors, depending on
the nature of the complaint. These include the Victorian Ombudsman, IBAC and the Local
Government Inspectorate.
In the first instance, a complaint about a Councillor should be directed to the Manager
Governance, who will undertake a preliminary assessment of the complaint and assist the
complainant(s) in progressing the matter.
The Manager Governance may be contacted on 9249 4000 or
Complaints about the Chief Executive Officer
Complaints about the Chief Executive Officer will be handled in accordance with the Local
Government Act 2020, Public Interest Disclosure Act 2012 and City of Brimbank Public
Interest Disclosures Procedures.
5.8 Privacy and Confidentiality
Council uses your information to respond to your complaint and may also analyse the
information you have provided for the purpose of improving services that relate to your
When gathering information to respond to a complaint, Council will only:
Use it to deal with the complaint or to address systemic issues arising from the
Release the information in a de-identified format when disclosing data to the
Share the information with Council staff on a need to know basis.
Details about how Council collects and uses personal information can be found in the
Information and Health Privacy Policy 2023
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6.1 All Staff
Are responsible for:
Complying with this policy
Receiving, acknowledging, and assessing complaints and, where possible, resolving
at the point of contact within the scope of their role.
Escalating complaints that cannot be resolved at the first point of contact to the
appropriate officer for investigation and handling.
6.2 Actioning Officers
Are responsible for:
Carrying out investigations and handling complaints assigned for actioning.
Ensuring complaint recovery action is accurately recorded in centralised systems.
Ensuring customer receives adequate communication about the complaint.
Escalating complaints to their direct supervisor when the complainant is unsatisfied
with the outcome of the initial investigation and response.
6.3 Coordinator Customer and Digital Experience
Is responsible for:
Identify recurring trends and patterns of complaints to improve council customer
service management and experience.
Administering Internal Review complaints and nominating the key contact person.
Providing information to relevant departments on the analysis of complaints data.
Providing guidance and advice to departments on the handling, investigation and
resolution of complaints.
Reviewing incidents of unreasonable customer conduct and producing action plans
for managing ongoing unreasonable conduct.
6.4 Manager Customer Experience and Service Innovation
Is responsible for:
Encouraging an environment where complaints are handled transparently,
seriously and comprehensively.
Ensuring the operationalisation of this policy
Reporting complaints data to the Executive Leadership team
Ensuring resourcing for the function is adequate to meet the requirements of this
policy and to raise any issue or concerns in relation to resourcing levels with the
relevant Director.
6.5 Team Leaders, Coordinators and Managers
Are responsible for:
Ensuring actioning officers are managing complaints allocated to them in timely
Managing escalated complaints that have not been resolved at the first or second
point of contact within their team.

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Providing oversight of the complaints management process within their team.
Escalating complex complaints to the next leadership level and redirecting out of
scope complaints to the appropriate unit.
Ensuring officers and contractors understand this policy.
Ensuring the Mayor and Councillor support and Councillors are advised of the
complaint resolution where complaints have been received via Councillors.
Ensuring the customer is provided with an explanation including apology (if
required) and confirmation of action taken when a complaint has been resolved
Working with the Coordinator Customer and Digital Experience and their team to
improve processes based on learnings from complaints data.
Alerting the Coordinator Digital and Customer Experience to any conflict of interest
prior to conducting independent assessments.
6.6 Directors and CEO
Are responsible for:
Ensuring officers understand this policy.
Ensuring that issues identified by the analysis of complaints data are investigated
and improved.
Ensuring the Mayor and Councillor support and Councillors are advised of the
complaint resolution where complaints have been received via Councillors.
6.8 Councillors
Are responsible for:
Encouraging residents to lodge their complaint directly with Council for it to be
actioned accordingly under this policy.
Forwarding a complaint for it to be actioned as outlined in this policy.
A Councillor cannot direct or influence the complaint handling process and the complaint
will be investigated as outlined in this policy.
6.9 Contractors
Are responsible for:
Ensuring they and their employees understand this policy.
Ensuring contractual documentation complies with this policy.
Managing any referred complaints in accordance with this policy and guidelines.
Notifying Council’s contract manager if they receive a complaint directly.
Complying with this policy.
Responsible Director:
Director, People, Partnerships and Performance
Responsible Officer:
Manager Customer Experience and Service Innovation
People, Partnerships and Performance
Customer Experience and Service Innovation

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Approved by:
Local Government Act 2020
Building Act 1993
Charter of Human Rights and Responsibilities Act 2006
Disability Discrimination Act 1992
Health Records Act 2001
Infringements Act 2006
Planning and Environment Act 1987
Privacy and Data Protection Act 2014
Privacy and Health Information Policy 2023
Public Health and Wellbeing Act 2008
The Australian Standard on Fraud and Corruption Control (AS 8001:2021)
The Child Wellbeing and Safety Act 2005
The Public Interest Disclosures Act 2012
Version Version notes
Review date
12 December
November 2027

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