Complaint Handling Policy

1. Purpose

This policy outlines our approach and provides information on what customers can expect when making a complaint to South East Water. 

2. Principles of the Policy

We support healthy and liveable communities by delivering water, sewerage and recycled water services to 1.77 million people who rely on us every day and every night. We aim to meet or exceed your expectations in relation to the range of services we provide.

We recognise that, despite our best efforts, customers may at times be dissatisfied with our services or decisions.

South East Water is committed to enabling customers to raise complaints regarding our services, actions, decisions and policies. We respond by taking timely action to resolve concerns and use complaint insights to drive continuous improvement in our services.

We’re committed to treating all customers with understanding, empathy and respect. Every complaint is considered on its individual merits and addressed through clear, consistent and fair processes.

3. Scope

This policy applies to all of our customers and anyone else who is impacted by our operations. 

Our Trade Waste customers can refer to the Trade Waste Customer Charter and their Trade Waste business contacts for additional information and escalation options.

4. Definitions

What are not complaints handled under this Policy?

• Where there is a specific South East Water policy or procedure dealing with complaints about an issue, and the complaint would be better managed under that policy.
• Where there is a review right under legislation, such as the Freedom of Information Act 1982 in the case of some Freedom of Information decisions, we will generally advise you that your complaint will need to be addressed via the statutory mechanism.
• Service requests and feedback are not considered complaints and will not be handled under this policy. Service requests and feedback that we receive will be referred to the relevant area of the business and dealt with as appropriate. Some service requests may be considered complaints for regulatory reporting purposes, however are not managed under this policy.
• Enquiries are not considered complaints. If you request a written response to an enquiry, we will respond to you within 10 business days. If your enquiry is complex and we need more time to consider and respond, we’ll let you know when to expect a response.
• Allegations of improper or corrupt conduct, which will be managed in accordance with our Public Interest Disclosures Policy.
• Workplace grievances, lodged by South East Water staff or contractors.
• Matters that are subject to an external dispute resolution process, such as complaints that a customer has referred to EWOV.

5. How to contact us to raise a complaint

We encourage customers to raise concerns as soon as possible and directly with the South East Water employee or contractor delivering the service in the first instance. This supports timely resolution and helps to achieve prompt, mutually acceptable outcomes.

If the complaint cannot be resolved, or a more thorough investigation is required, you can request the complaint to be escalated directly with the team member assisting you or lodge a complaint via the following methods:

Tell us what happened

To help us understand what has happened and what you would like us to do, we need some important details from you which may include:

• your name and contact details (phone and email preferred). Please tell us how you'd like us to contact you, otherwise we'll get back to you the same way you made the complaint. You can complain anonymously, but this may limit how we can respond to you;
• a description of the action, decision, or service your complaint relates to and why you are dissatisfied;
• relevant information such as dates, times, location, reference numbers, names of employees that have assisted you in this matter previously;
• any documentation you think is important to your complaint;
• any explanations you think are important;
• what outcome you’re seeking from us; and
• whether you have any particular communication, accessibility or support needs and we will work with you to ensure our complaints process is accessible.

Without this information we may not be able to progress investigation or resolution of your complaint.

Communication Assistance

If you need assistance to communicate with us: 

• In a language other than English, you can access free interpreting services by contacting the National Translating and Interpreting Service (TIS) on 1800 131 450.
• If you are deaf, hard of hearing or have a speech impairment, the National Relay Service provides free assistance
• If you need an Auslan interpreter, visit National Auslan Interpreter Booking and Payment System 

Who can complain?

Customers and others who have been affected by our operations can make a complaint.

You may nominate a representative to submit a complaint or communicate with us on your behalf. To protect your privacy, we’ll ask for your representative or support person’s name, contact details and evidence of authorisation before communicating with them.

We understand that sometimes people prefer to remain anonymous when making a complaint. We accept and investigate anonymous complaints, provided there is enough detail to allow us to do so. If you don’t tell us who you are, we won’t be able to provide updates or advise you of the outcome, but will include any investigation outcomes in our continuous improvement processes. 

6. Complaint Handling Procedure 

South East Water uses a three-tiered approach to investigating and resolving complaints:

Tier 1 – Early resolution

When you complain to us, we will initially assess your complaint to decide how we will handle it. After our initial assessment, we may:

• seek further information to clarify your complaint and the outcome sought;
• take action to resolve your complaint;
• refer your complaint to the relevant team or someone more senior for investigation;
• decline to deal with your complaint if:
• the matter is under review by an external dispute resolution forum such as EWOV;
• the complaint is considered frivolous, vexatious, trivial or not made in good faith;
• your complaint relates to something we aren’t responsible for, in which case we will direct you to the authority or organisation we think is most appropriate;
• your complaint is outside the scope of this policy, e.g. if an alternative statutory process applies, in which case we will advise you that your complaint needs to handled via that process.

Where possible, we will attempt to resolve your complaint at the time you first contact us. This may include escalation to a supervisor, team leader or manager if required.

If you request a written response, we may take up to 10 business days to provide a response.

Early resolution of a complaint may involve providing advice or explaining why we are not going to take action on your complaint.

We will record details of your complaint and upon request we can provide you with your case number.

Tier 2 – Investigation

If we are unable to resolve your complaint at a Tier 1, or your complaint requires detailed investigation or coordination between multiple stakeholders, we will escalate your concerns for assessment and investigation by South East Water's specialist team.

Our specialist senior case managers work with internal departments, our industry partners and our customers to investigate and resolve complaints.

While we aim to provide a substantive response to non-complex complaints within 10 business days, we may need more time to investigate and respond to complex complaints.

Complex complaints, because of their nature, scope, seriousness or sensitivity, require a more extensive assessment, investigation, consultation or coordination than would ordinarily be required to resolve a routine complaint. Complaints may be considered complex and require some more time to investigate if they:

• include multiple issues
• require investigation or input from multiple departments or our external contractors or other third parties, or
• relate to property damage.

We will always do our best to resolve your matter as quickly as possible, and when we do need some more time, we will let you know and keep you updated.

When we have completed our investigation and decided the outcome, we will provide you with:

• The outcome of your complaint and reasons for our decision
• Any relevant legislation or policy that we may have based our decision on, if it’s appropriate
• Information about your right to escalate the matter to a manager or to an appropriate external dispute resolution scheme if you are unhappy with the complaint outcome

Complaints about staff conduct will be investigated and managed in accordance with our Code of Conduct and other relevant policies. Due to privacy and confidentiality, we may not be able to provide details on the outcome or actions taken in relation to the staff member.

Tier 3 – External review avenues for complaints

If you are not satisfied with our response, there are external organisations that can deal with different complaints relating to South East Water, including:

7. Complaint outcomes

Outcomes and remedies we provide to resolve complaints may include, but are not limited to:

• An explanation or clarification of the circumstances in dispute
• An apology
• Payment support options aligned with our Customer Support policy
• A billing or account adjustment
• Account refunds or credits
• Reimbursement of reasonable expenses incurred
• In-field maintenance or other activities

We will determine remedies based on the individual circumstances of each complaint. Remedies will be fair, reasonable and proportionate to the issues identified, taking into account the available evidence, relevant obligations, and the need for consistency across similar cases.

As a public water corporation, we must also manage public resources responsibly. Any remedy provided will reflect our obligation to balance the interests of the individual customer with our responsibility to deliver equitable and sustainable services for the broader community.

We will cease handling a complaint under the following circumstances:

When we have asked you for further information relevant to the handling of your complaint, and:

• within 10 business days (or otherwise advised) you have not provided us with the requested information or contacted us to explain why or make alternative arrangements for providing the requested information; and
• we are unable to provide you with a substantive outcome without the requested information

When you have been provided with a complaint outcome, and

• within 10 business days you have not requested an internal review, either from our Resolutions team or a manager; or
• within 10 business days you have not escalated your complaint to EWOV or another external dispute resolution forum

When you have been provided with the outcome of an internal review from our Resolutions team or a manager and within 10 business days you have not escalated your complaint to EWOV or another external dispute resolution forum.

When you have escalated your complaint to EWOV or another external dispute resolution forum and that process has concluded.

8. Disputes about non-payment

If your complaint is a dispute about non-payment, we will not seek to recover that amount until your complaint has been resolved.

It’s our priority to work with you directly until we reach a resolution, and we’ll consider a dispute about non-payment resolved if we’ve provided you with our complaint outcome and you have not escalated your complaint internally, or to EWOV or another external dispute resolution forum within 10 business days.

If you choose to escalate your complaint to EWOV or another external dispute resolution forum, we will not consider the complaint resolved until that process has been finalised.

9. Customers whose conduct is unreasonable  

While most customers who make complaints have legitimate concerns and genuinely seek resolution, a small proportion of customers demonstrate Unreasonable Complainant Conduct.

Unreasonable Complainant Conduct is any behaviour by a person which, because of its nature and frequency, raises substantial health, safety, resource or equity issues. Conduct can be unreasonable due to:

• Unreasonable persistence
• Unreasonable demands
• Unreasonable lack of cooperation
• Unreasonable arguments
• Unreasonable behaviour

When we encounter Unreasonable Complainant Conduct we will take appropriate and proportionate action to manage the behaviour. The appropriate strategy for dealing with Unreasonable Complainant Conduct will depend on the specific circumstances and will be incident specific.

10. How we learn from complaints

Complaints provide us with valuable feedback about how we are performing.

We record and regularly analyse our complaint data to identify trends and potential issues that require further attention. We use this information to identify how we can improve our services.

We record the following information for each complaint:

• customer details
• the complaint was received
• a description of the complaint
• location of the issue where relevant
• customer’s desired outcome (if known)
• Council officer responsible for handling the complaint (if applicable)
• any action taken, including contact with the customer, response times and the outcome

We are transparent about the complaints we have received through public reporting to the Essential Services Commission.

11. Privacy

To receive and handle complaints it is necessary for us to collect personal information about you and other persons affected by your complaint. We use the information you provide to investigate and respond to your complaint. We also use your information for the purpose of improving services that relate to your complaint.

We may share information about you and your complaint with internal staff and our contractors, agents, and other third parties (including other public entities, government agencies or councils) where the information is relevant to the performance of their duties, functions or powers and we consider it is appropriate to do so. For example, if you make a complaint about a service provided by one of our contractors, we may discuss your complaint with them and collect information about you from them.

For further information about how we handle personal information see our Privacy Charter.

12. Related policies

BS 2485 Customer Charter Customer Charter | South East Water

MC 1783 Trade Waste Customer Charter Trade Waste Customer Charter | South East Water

BS 1055 Privacy Charter Privacy charter | South East Water

BS 2144 Customer Support Policy Customer Support Policy | South East Water

BS 2792 Domestic and Family Violence Policy Domestic and Family Violence policy | South East Water

13. Legislative Compliance

Water Industry Standard – Urban Customer Service

Water Act 1989

Water Industry Act 1994

14. Approval