This procedure applies only to complaints relating to data protection matters. Complaints concerning service quality, legal advice or professional conduct should be handled through the general complaints procedure. Where a complaint contains both data protection and service-related elements, the relevant procedures may run in parallel.
SELC is committed to ensuring that data protection complaints are accessible to all individuals.
Complaints may be made:
Reasonable adjustments will be made wherever practicable to assist individuals experiencing disability, language, literacy, digital exclusion or other barriers to making a complaint.
There is no charge for making a complaint.
Where appropriate, SELC may seek to resolve concerns informally before commencing a formal investigation.
Examples may include:
Where a concern is resolved informally, a record must still be retained on the complaints register for monitoring and governance purposes.
Complaints should be directed to the Data Protection Lead (currently the Operations Manager) using the info@selc.org.uk email address.
The complaint should include, where possible:
Anonymous complaints may be considered where sufficient information has been provided to allow investigation.
All complaints must be recorded in the Data Protection Complaints Register immediately upon receipt.
The register must record:
Complaints must be acknowledged within two working days of receipt.
The acknowledgement shall:
A preliminary assessment must be carried out within two working days to determine:
Where ongoing risk to personal data, safeguarding concerns or significant compliance failures are identified, the complaint must be escalated immediately.
The Data Protection Lead, or another suitably independent manager appointed for the purpose, shall conduct a fair and proportionate investigation.
The investigation may include:
The investigator must maintain written records of all significant investigative actions and conclusions.
Where a staff member is the subject of a complaint, they must be given an opportunity to respond.
Any person with a personal involvement in, or conflict relating to, a complaint must not investigate that complaint.
Where the complaint concerns the Data protection lead or a member of senior management:
Where a complaint identifies or suggests a personal data breach, the Data Breach Procedure must be activated immediately.
Investigation of the complaint must not delay:
All such matters must be recorded on the Data Breach Register.
Where a complaint identifies a safeguarding concern involving a child, young person or adult at risk, the matter must be immediately referred to the Designated Safeguarding Lead.
Safeguarding action shall proceed independently of, and in parallel with, the complaints investigation.
SELC aims to meet the following service standards:
| Stage | Target |
| Acknowledgement | 2 working days |
| Initial triage | 2 working days |
| Final response | 20 working days |
Where a complaint is particularly complex, the response period may be extended.
The complainant must be informed:
Complaints will normally be categorised as:
The outcome letter shall include:
Where a complaint identifies failures or weaknesses, SELC will implement appropriate corrective action.
This may include:
Serious or systemic failures shall be subject to root-cause analysis and tracked until all corrective actions are completed.
Data protection complaint records shall be retained for seven years following closure of the complaint, or longer where litigation, regulatory investigation or safeguarding matters require extended retention.
Access shall be restricted to authorised personnel only.
For further information about our complaints process, please get in touch with us.