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Section 3 - Managing engagement

In this section, we consider situations where a person’s engagement with us is such that an unfair or disproportionate amount of resource is being used. These situations need to be addressed. This section considers both how an organisation and individual staff members can respond to these situations by managing the engagement.

We concentrate on the impact on time: the key resource of the staff member or organisation. Managing engagement with customers who are unacceptably using too much of your time can free up time for other work and customers. We also look specifically at the situations we find difficult at SPSO and how we respond to them.

The general approach is very simple and can be used for creating policies, responding to an individual or dealing with a broad range of situations.

The DESC model is a simple and effective one and the ideas and suggestions below build around or on this.

D - Describe the situation

E - Explain the impact that the situation is having

S - Suggest how the engagement needs to change

C – Consequences (what will happen if the engagement changes and, what will happen if it does not)

The first two steps are very important. In particular, they may help the person to understand their engagement is having an impact they do not intend. It also may give them an opportunity to explain the reason for this. This may allow you to work together to put in place a Suggested approach which works for both of you.

It is important that you can fairly and consistently identify engagement which is having a negative impact on resources. It can be a one-off interaction or the result of a build-up of communication over time. SPSO have identified some types of engagement that cause us problems in our Engagement Policy. This helps us make sure we can identify this objectively and impartially. While it is important to be consistent, there is always an element of subjectivity: the level of resource that you should be using for an individual complaint will vary from one organisation to another depending on the role of your organisation, and within organisations it may vary depending on the needs of the individual customer. This means that you can take into account your organisation’s size, capacity and role when assessing the impact of the engagement.

You should also think about the individual and why they may require more of your time. Remember, not all disability is open, some can be hidden. Someone may genuinely need more time and, as referred to in the governance section of this guidance, organisations must always take into account their commitment and responsibilities to equality.

You should always be able to Describe the specific issue and Explain why that is a problem in an individual case; but it can be helpful to also think through as an organisation what engagement, in general, causes you problems and why. This can allow you to pre-empt some problems.

Our revised approach to engagement includes a shift on emphasis to supporting positive engagement. This guide is not focused on that aspect of the revised approach which goes much further than managing difficult interactions. Yet even within this narrower focus, there are steps that can be taken. For example, ensuring the public receive timely and good information about what they can expect from the complaint process can reduce the number of people who are contacting you because they are confused about what is happening or unsure what to do next.

The way you provide information, and when, will depend on your customers. This information has to be useful for them at the time they receive it. The complaints you have already received and your experiences of situations which became difficult are a good resource for this. You can use them to identify any repeated problems, pre-empt repeated questions by providing answers upfront.

It will not work in all cases but you can help reduce some problems by letting people know:

  • the timescales you work to
  • what you expect from people who approach you
  • what you can and cannot do.

We will look at an example based on SPSO’s Engagement Policy to show how the DESC model can work in practice. This is a situation where the level of contact with an individual is using a disproportionate amount of resource.

Describing and Explaining the problem

There are a few aspects to this:

  • identify what you would normally expect
  • identify the level you are experiencing
  • ensure you have considered whether there are additional needs which mean additional support is reasonable
  • What: be clear why this is a problem, explain the impact (this may not be clear)
  • When: act early before it becomes an established pattern

Let’s look at this in more detail.

Identify what you would normally expect

The first step is to identify clearly what level of interaction you would normally expect (this may be part of the pre-emptive approach above). This is useful because it gives you a framework to work from when you are considering whether a particular situation is problematic.

The level of contact you have with an individual will depend on the service you are providing. This may vary and you may find that while it is appropriate for the person to have very regular contact about the direct service (particularly in a health care setting), they may well have less contact with the person handling their complaint.

You should be mindful that there is a difference between what is normal and the maximum you allow. For example:

  • some individuals will exceed the average without this being a problem – their complaint may be more complicated and the extra contact may be useful
  • some people will have specific communication needs which you have to take into account and that may take more time
  • some complaints are more sensitive
  • some people find the process very difficult and may need more support

The person handling the complaint may feel that, while the resource being used is more than usual, in this case it is not unreasonable for a number of reasons. It may be helpful to note this on file so that anyone else dealing with the complaint does not take action to limit the level of contact without considering those reasons.

Identify what would be a problem

Once you know what you would expect, and why, you are in a better position to understand what levels of contact will cause you problems to the extent that you need to take action. Again this can reflect your role and your organisation's capacity. The key point is to consider what level affects your resources.


Be aware of your personal trigger points, if someone who acts in a way that you find annoying or irritating you may be more likely than a colleague to identify their behaviour as unacceptable. You need to have a neutral way of identifying what is problematic. At SPSO, to ensure consistency and support for staff, we have developed an Engagement Policy that sets out what kinds of engagement we might need to manage, and how. This is available to both staff and our customers.

As part of this process, organisations should consider how staff can share or identify problems early. For example: Can you quickly identify if someone is raising the same concern through multiple entry points? Or using up a lot of time of two or more colleagues and the effect is cumulative rather than only on one member of staff?

This is how we let people know in our policy what would cause us a problem:


Sometimes the volume and duration of contact made to our office causes problems. This can occur over a short period, for example, a number of calls in one day or one hour. It may occur over the life-span of a complaint when someone repeatedly makes long telephone calls to us or inundates us with information that has been sent already or that is irrelevant to the service we are providing or sends repeated emails raising the same or similar issues.

We consider that the level of contact has become unacceptable when the amount of time spent on the telephone, or responding to, reviewing and filing emails or written correspondence or managing the contact impacts on our ability to provide a service to that person or organisation, or to provide a service to others.

Do not delay

It is important that the type of engagement does not become established. It can feel very unfair to an individual who has been allowed to act in a way for some time to then be told that this is unacceptable and contact will be controlled. They can quite rightly feel aggrieved that this was not raised with them sooner or that no one explained this to them. They may feel that the reason you are now labelling the engagement unacceptable is not the engagement but some other reason. It becomes very difficult at this point to find any way to rebuild the relationship.

Acting before it becomes a problem

Once you are clear what will be unacceptable, you can spot early signs of this developing. This allows you to address the situation before it becomes unacceptable. The advantage of raising the issue early is that you can do so in a more exploratory, neutral fashion. You can ask why the engagement is occurring in that way, and this may well help you to solve the problem together with the customer. You should record that you have raised the issue. If you come to an agreement with the customer, you may want this in writing, to let the customer know you will honour this or to record any undertakings they have made.

When the situation has become unsustainable

If this early contact does not work or is inappropriate because the specific situation has already become unacceptable, you need to make it clear why the engagement is a problem and make a specific request that it change using the DESC model.

This can be done by telephone, in person or in writing. If in oral communication, you should follow this up in writing to make sure the individual understands the next steps. You need to identify the specific, particular issue and impact of the current situation. You should try to do this in a neutral way, focusing on the situation, rather than the person or their actions. Use ‘we’ or ‘I’ rather than ‘you’. The goal is to refocus the engagement in a more productive way and to rebuild the relationship, where possible. While you can refer to the organisation’s policy on managing engagement, it is often unnecessary to do this (and can escalate the situation unnecessarily).

It is important that you do not deliver the message that the engagement needs to change more than once, or at most twice, before acting on the consequences you have set out. Otherwise your customer will think you are not telling the truth and that the situation is not having an unsustainable impact. This means they are likely to feel you are acting unfairly and for reasons of personal preference if you do subsequently need to put restrictions in place.


In some situations you may need to put in steps to manage the interaction. When deciding what restriction is needed you should link this closely to the problem. For example, if someone is contacting you through lots of routes and that is causing you problems, you could restrict their contact to one point of contact. If someone is calling or emailing too often, you may restrict a method of contact. In some cases, you may combine these, for example by insisting on one point of contact and only in writing, or one point of contact and by telephone.

You should always aim to put in place the least possible restriction to manage the engagement. You will also need to explain in writing what you are doing and why, and let the person know how they can challenge your decision to do so.

In some rare cases, it may be proportionate to manage or restrict a person’s access to the complaint procedure for a time. This should be a last resort, and the organisation should be careful to balance the person’s right of access to the complaint procedure with the impact on the organisation.

Describe and explain

In this case, we set out in our policy very clearly why we may need to manage this situation. Individuals with complaints about SPSO or a public service provider have the right to pursue their concerns through a range of means. They also have the right to complain more than once about an organisation with which they have a continuing relationship, if subsequent incidents occur. However, this contact becomes unreasonable when the effect of the repeated complaints is to harass, or to prevent an organisation from pursuing a legitimate aim or implementing a legitimate decision. We consider access to a complaints system to be important and it will only be in exceptional circumstances that we would consider such repeated use is unacceptable – but we reserve the right to do so in those exceptional cases.

Describing exceptional

This again has to be linked back to the specific resources available. An example of when we may consider this is when an individual was using the complaints procedure in response to every contact and while these were new, they were trivial complaints.

It is important to identify whether the complaints look new but are an attempt to reopen a decision that has been made by either reframing or seeking to prevent the work needed to implement the decision. In such cases, the person is being persistent and we would not restrict their access to the complaints procedure overall, as that problem can be dealt with more simply in another way (see the section on ‘Persistence’). An example of this is a person who disagrees with the decision to involve a social worker in some aspect of their lives, and makes a new complaint about the way they were treated every time they come into contact with the social worker.

Putting it in practice

Before considering using this very strong strategy, staff should prepare a report that itemises all the complaints received over a reasonable period and the topics and outcomes. This is to ensure you are taking an objective view of the position. We would aim to give the person a clear chance to manage this themselves by letting them know the consequences of continuing to complain about certain issues. Only if the situation continues would we move to this restriction. You do need to communicate in an appropriate way but this decision will always require confirmation in writing to ensure the person has a record.

The complaints process is an important safeguard and this is why this decision does need the highest possible sign-off.

<< Section 2 - Difficult for you                                                                                          Section 4 - Persistence >>

Updated: November 17, 2021