Agenda item

To present a draft updated Unreasonable Behaviour Policy for the Council and seek feedback from the Committee (report of the Assistant Director – Governance (Monitoring Officer) enclosed).

Consideration was given to the report of the Assistant Director – Governance (Monitoring Officer) which sought feedback from the Panel on a draft updated Unreasonable Behaviour Policy for the Council prior to consideration at Cabinet.

The Information Manager and Data Protection Officer introduced the report which included the following main points:

• The Unreasonable Behaviour Policy replaced the policy formerly known as the Vexatious and Unreasonable Behaviour Policy;
• Appendix A detailed the draft Unreasonable Behaviour Policy which had been fully reviewed and aligned across the partnership;
• The review of the policy ensured that updates were included and that the policy remained fit for purpose and complied with prevailing statutory requirements;
• Adoption of the policy ensured that the council followed clear processes when dealing with incidents of unreasonable behaviour and unreasonably persistent complainants;
• The policy had been clearly written to be accessible and understandable by officers, members, and members of the public, and set out clear processes for different situations, for example, the ‘Periodic Review of Restriction’ stated at point 7.2 of Appendix A, was deliberately left to the discretion of officers so that situations could be dealt with according to individual circumstances; and
• Appendix B outlined unreasonable behaviour statistics across the partnership provided by PSPS Customer Contact monitoring; this had evidenced an increase in abusive contact over the period and therefore the requirement of a policy.

Members considered the report and made the following comments:

• Members welcomed the policy which was well-written, and when enforced, would serve to protect officers.

• Members referred to the statistics at Appendix B and noted a significant increase in reports of received abusive behaviour from 2021/2022 to 2023/2024. Was this due to a real increase or more accurate reporting?
  • The Group Information Officer and Data Protection Officer responded that PSPS staff had received training in the identification of inappropriate behaviour which impacted the increase from 2021/2022 to 2022/2023. Therefore, the comparison of the 2022/2023 baseline data with that of 2023/2024 gave a better indication of the increased trend in actual incidents. 

• Members queried whether long call waiting times to certain council departments accounted for some of the frustrations experienced.
  • The Assistant Director – Wellbeing and Community Leadership responded that a number of mechanisms had been implemented by PSPS to deal with call waiting times, including:
    • A call-back service, which had seen calls being responded to within 30 to 40 minutes;
    • Automated notification of position within the call queuing system so that callers could choose whether to wait or select a call-back;
    • Whilst the Contact Centre endeavoured to deal with enquiries at the first point of contact, detailed enquiries were referred to relevant teams. Whilst response times of referred calls were dependent upon officer commitments/availability, service standards relevant to each department were in place; and
    • It was acknowledged that post-Covid expectations were greater and therefore the implemented Contact Centre mechanisms and reviewed Unreasonable Behaviour Policy aimed to address the issue from both angles.

• Members relayed an experience where a Contact Centre call waiting period had greatly exceeded the expected automated notification period and suggested that the automated message be reviewed to reduce potential frustration.
  • The Assistant Director – Wellbeing and Community Leadership would liaise with the Head of Customer Service regarding this matter.

• Members referred to point 2 of Appendix A regarding the purpose of the policy and queried whether each report was required to be logged as a formal complaint in the first instance.
  • The Group Information Officer and Data Protection Officer responded that the policy applied to any interaction, formal complaint or otherwise. This approach ensured that any burden could be identified and escalated.

• Members noted that the data at Appendix B was combined across the partnership and requested that a breakdown between each authority be provided.
  • The Group Information Officer and Data Protection Officer responded that:
    • The purpose of the data collation was to demonstrate the need for the policy across the partnership and the data had acted as an indicator in this respect; and
    • A response from PSPS was currently awaited regarding the possible breakdown of the data.

• Members requested that a breakdown of Appendix B statistics also be provided by department in order to obtain a true picture of officers’ experiences and therefore an understanding of issues that may affect morale, as well as ensuring that a duty of care was in place.
  • The Group Information Officer and Data Protection Officer responded that:
    • The presented data, at Appendix B, related to the contact made solely with PSPS Customer Services and that reports of abuse experienced by departments were not currently collected;
    • Observations had shown that departments with higher incidents of abuse also dealt with higher volumes of sensitive customers;
    • The policy provided an effective mechanism to deal with the burden of persistent enquirers which potentially impacted multiple officers; and
    • Whilst the policy protected staff, it also limited the controls that could be placed on individuals, for example, an individual banned from a building, or with a limited contact order, would always be given a mechanism to access services on a needs basis.
  • The Assistant Director – Wellbeing and Community Leadership added that:
    • It was unknown whether the Customer Relationship Management system was able to provide the requested data at departmental level however this would be investigated; it was noted that the request could prove burdensome if the data was not readily available;
    • Nonetheless, assurance was given that:
      • The existence of the policy provided the protection mechanism for future incidents;
      • Where high levels of inappropriate behaviour had been experienced, such as towards the Homelessness and Housing Teams, a number of training and wellbeing mechanisms had been implemented as part of the council’s duty of care to ensure that staff were both supported and protected; and
      • Assistant Directors had been consulted during the review period to ensure that the policy remained relevant to service areas.

• Members concluded:
  • That the requested departmental data be made available to inform action and ensure a duty of care to employees; and
  • That the Panel agreed the policy be referred to the Chairman of the Performance Monitoring Panel regarding potential future monitoring.

o   In response, the Business Intelligence and Change Manager confirmed that the number of vexatious calls were reported to the Performance Monitoring Panel within the quarterly Performance Reports.

AGREED:

After consideration of the draft Unreasonable Behaviour Policy at Appendix A:

a)    That the comments of the Panel be noted;

b)    That the Policy be recommended to Cabinet for approval; and

c)     That the Policy be referred to the Chairman of the Performance Monitoring Panel for potential future monitoring.