COMPLAINTS POLICY & PROCEDURE
For: Alison Taylor Medical Cosmetics Ltd
Clinic Address: Blushes, 16/17 Montpellier Walk, Cheltenham, Gloucestershire, GL501SD
Registered Nurse: [Alison Pearce
Email: alison.taylormedical@gmail.com
Telephone: +44 7887808680
Review Date: September 2027
1. Purpose
Alison Taylor Medical Cosmetics is committed to providing safe, professional, respectful
and patient-centred aesthetic care.
We recognise that, despite our best efforts, patients may occasionally have concerns or
complaints about their treatment, communication, clinical care, results, aftercare, fees or
other aspects of their experience.
The purpose of this policy is to ensure that:
• patients know how to raise a concern or complaint;
• complaints are taken seriously and treated respectfully;
• complaints are handled promptly and fairly;
• patients are not disadvantaged because they have complained;
• clinical concerns are appropriately assessed and managed;
• complaints are investigated as objectively as possible;
• lessons are identified and acted upon;
• appropriate records are maintained;
• confidentiality and data protection are maintained throughout;
• serious concerns are escalated appropriately; and
• the clinic's complaints process supports the professional responsibilities of the
NMC-registered nurse.
This policy applies to all complaints relating to the services provided by [CLINIC NAME].
2. Scope
This policy applies to complaints concerning, for example:
• consultation and assessment;
• clinical treatment;
• treatment outcomes;
• adverse events or complications;
• consent and information provided before treatment;
• aftercare;
• communication;
• appointment arrangements;
• waiting times;
• fees, refunds or cancellation charges;
• behaviour or professionalism;
• confidentiality and privacy;
• handling of personal information;
• clinical records;
• photographs;
• advertising or information provided about treatments; and
• any other aspect of the patient's experience.
A complaint may be made by:
• the patient;
• a parent or guardian where appropriate;
• a person authorised by the patient;
• a representative acting on behalf of a patient where appropriate; or
• another person who has a legitimate concern about the care provided.
Where a complaint is made by someone other than the patient, appropriate consent or
authority may be required before confidential patient information is disclosed.
3. Regulatory and Professional Framework
The clinic operates as an independent, non-CQC-registered aesthetic practice.
The fact that the clinic is not registered with the Care Quality Commission does not
remove the professional responsibilities of the registered nurse.
The nurse will maintain professional practice in accordance with the current
requirements of the:
• Nursing and Midwifery Council (NMC) Code;
• applicable professional standards and guidance;
• UK data protection legislation;
• UK GDPR and Data Protection Act 2018, as applicable;
• relevant medicines legislation and guidance;
• applicable consumer and advertising legislation;
• relevant health and safety requirements; and
• requirements of the clinic's professional indemnity insurer.
The NMC advises that nurses have a professional duty to put the interests of people in
their care first and to act to protect people where they may be at risk.
4. Our Approach to Complaints
The clinic will aim to ensure that complaints are:
Fair
The complainant will be listened to and given a reasonable opportunity to explain their
concerns.
Respectful
Complaints will be handled without hostility, judgement or discrimination.
Proportionate
The investigation will reflect the seriousness and complexity of the complaint.
Confidential
Information will only be shared where necessary and appropriate.
Objective
The clinic will seek to establish what happened rather than simply defend the treatment
or clinician.
Patient-focused
Where something has gone wrong, the clinic will consider what can reasonably be done
to put matters right.
Learning-focused
Complaints will be used to identify improvements to clinical practice, documentation,
communication and patient safety.
Making a complaint will not affect a patient's right to receive appropriate care or to seek
treatment elsewhere.
5. Informal Concerns
Where appropriate, patients are encouraged to raise minor concerns as soon as possible.
Many concerns can be resolved quickly through discussion.
For example, a patient may wish to discuss:
• dissatisfaction with communication;
• an appointment issue;
• aftercare instructions;
• a misunderstanding about treatment;
• a minor administrative matter; or
• a concern about the expected treatment outcome.
The nurse will listen to the concern, clarify what has happened and attempt to resolve the
matter appropriately.
An informal discussion does not prevent a patient from making a formal complaint.
Where an informal concern relates to clinical safety, an adverse event, significant
dissatisfaction, consent, professional conduct or a potential legal issue, it should be
recorded and managed under the formal complaints process where appropriate.
6. How to Make a Formal Complaint
A complaint may be made:
By email:
alison.taylormedical@gmail.com
By post:
Blushes, 16/17 Montpellier Walk, Cheltenham, Gloucestershire GL501SD
By telephone / WhatsApp:
07887808680
In person:
By prior arrangement with the nurse.
A complaint may be made verbally or in writing.
However, where a complaint involves clinical care, an adverse event, alleged negligence,
consent, a serious allegation or a potential legal claim, the clinic may ask the complainant
to provide the concerns in writing so that they can be accurately investigated.
Patients are not required to use legal terminology when making a complaint.
A complaint should, where possible, include:
• the patient's name;
• contact details;
• date of treatment or relevant event;
• treatment received;
• details of the concern;
• what the patient believes went wrong;
• the effect the issue has had on them;
• what outcome they are seeking; and
• any relevant supporting information.
The clinic will make reasonable adjustments where a patient has a disability or other
communication need.
7. Acknowledgement of Complaint
Written complaints will normally be acknowledged within 5 working days.
The acknowledgement will:
• confirm receipt of the complaint;
• explain who will deal with it;
• explain the anticipated timescale;
• identify whether further information is required; and
• explain what will happen next.
Where the complaint is straightforward, the clinic may provide a substantive response
within this period.
8. Complaints Investigation
The investigation will be proportionate to the nature of the complaint.
The nurse will:
1. Review the complaint carefully.
2. Establish the issues that require consideration.
3. Review the relevant clinical records.
4. Review consultation and consent documentation.
5. Review treatment notes and photographs where relevant.
6. Review relevant correspondence and aftercare advice.
7. Consider whether the treatment was undertaken in accordance with the clinic's
SOPs and professional standards.
8. Consider whether any adverse event or complication occurred.
9. Consider whether appropriate information and consent were provided.
10. Consider whether further clinical assessment is required.
11. Consider whether another professional opinion is appropriate.
12. Document the findings.
13. Identify any actions required.
The investigation will seek to distinguish between:
• dissatisfaction with a treatment outcome;
• a recognised treatment complication;
• an unexpected adverse event;
• inadequate communication;
• failure to follow an agreed procedure;
• an administrative problem;
• a potential clinical error; and
• allegations of professional misconduct or negligence.
9. Lone Practitioner and Independent Review
Because Alison Taylor Medical Cosmetics is a lone-practitioner clinic, the nurse may be
the person who provided the treatment and the person initially receiving the complaint.
Where a complaint is significant, complex or potentially involves:
• clinical negligence;
• serious harm;
• a significant adverse event;
• a breach of professional standards;
• consent concerns;
• an allegation of dishonesty or misconduct;
• a potential safeguarding concern;
• a data breach;
• a threatened legal claim; or
• a complaint which the nurse considers cannot be investigated objectively,
the nurse should seek an independent review.
This may be provided by an appropriately qualified:
• NMC-registered nurse;
• medical practitioner;
• clinical adviser;
• professional indemnity insurer;
• solicitor;
• professional adviser; or
• other suitably experienced independent person.
The person conducting the independent review should have no personal involvement in
the matter wherever reasonably possible.
The clinic will cooperate with its professional indemnity insurer where a complaint may
potentially give rise to a claim.
10. Immediate Clinical Safety Concerns
If a complaint indicates that a patient may currently be at risk of harm, patient safety will
take priority over the administrative complaints process.
The nurse will:
• assess the patient's immediate clinical needs;
• provide appropriate advice and treatment;
• arrange urgent medical assessment where necessary;
• refer to the patient's GP, NHS service, emergency department or other appropriate
healthcare professional where indicated;
• document the assessment and advice;
• consider whether the treatment should be suspended;
• consider whether the relevant product, device or procedure should be temporarily
withdrawn;
• contact the professional indemnity insurer where appropriate; and
• consider whether any external notification or referral is required.
A complaint investigation must never delay necessary clinical treatment.
11. Serious Adverse Events
Where a complaint identifies a serious adverse event or possible patient harm, the nurse
will undertake an appropriate clinical review.
This may include reviewing:
• the patient's medical history;
• contraindications;
• consent;
• treatment parameters;
• product details and batch number;
• treatment site;
• clinical photographs;
• treatment records;
• aftercare advice;
• communications with the patient; and
• any relevant manufacturer's guidance.
Where appropriate, the nurse will seek independent clinical advice.
The event will be recorded separately within the clinic's adverse-event/incident records
where applicable.
12. Complaint Response
The clinic will aim to provide a full written response within 20 working days of receiving a
formal complaint.
Where this is not possible because the investigation is complex or requires independent
clinical advice, the patient will be informed of the reason for the delay and provided with a
revised timescale.
The final response should:
• acknowledge the concerns raised;
• summarise the investigation undertaken;
• explain the relevant facts;
• provide a clear response to each significant point;
• explain whether the complaint is upheld, partially upheld or not upheld;
• apologise where appropriate;
• explain any action taken;
• explain any learning identified;
• explain any further steps available to the patient.
The response should be written in clear, respectful and non-defensive language.
13. Possible Outcomes
Following investigation, a complaint may be:
Upheld
The investigation identifies that the complaint is substantially justified.
Partially upheld
Some aspects of the complaint are justified but others are not.
Not upheld
The available evidence does not support the complaint.
Inconclusive
There is insufficient evidence to establish what happened.
An outcome does not necessarily determine whether a patient has a legal right to
compensation or whether professional negligence has occurred.
14. Apologies and Duty of Candour
Where the clinic has made an error, the nurse will be open and honest with the patient.
An apology may be offered where appropriate.
An apology does not necessarily constitute an admission of legal liability.
Where something has gone wrong, the nurse will explain what is known, what is being
done to address the situation and, where appropriate, what steps will be taken to prevent
recurrence.
15. Complaints Involving Clinical Records
Clinical records must not be altered retrospectively in response to a complaint.
If an amendment or clarification is required, the original record must remain identifiable
and any amendment must be dated, attributable and transparent.
The nurse will preserve relevant records during the investigation.
This includes, where relevant:
• consultation records;
• medical history;
• consent forms;
• treatment notes;
• photographs;
• product batch numbers;
• device settings;
• prescriptions;
• aftercare advice;
• correspondence;
• emails;
• text messages; and
• other relevant communications.
16. Data Protection Complaints
Complaints concerning the handling of personal information will be treated as data
protection complaints where appropriate.
Examples include concerns about:
• confidentiality;
• unauthorised disclosure;
• photographs;
• medical records;
• personal information;
• marketing communications;
• subject access requests;
• data security; or
• retention of information.
The clinic will maintain a process for handling data protection complaints.
Under current ICO guidance, organisations must provide a means for people to make
data protection complaints, acknowledge such complaints within 30 days, investigate
them appropriately and communicate the outcome without unnecessary or unjustifiable
delay.
Where appropriate, patients will be informed of their right to complain to the Information
Commissioner's Office (ICO).
17. Confidentiality
Complaints will be treated confidentially.
Information will only be disclosed where:
• the patient has consented;
• disclosure is required by law;
• disclosure is necessary to protect the patient or another person;
• disclosure is necessary for safeguarding;
• disclosure is necessary to obtain appropriate professional advice; or
• disclosure is otherwise permitted or required by law.
Where an independent adviser is involved, only information reasonably necessary for the
review will be disclosed.
18. Third-Party Representatives
A patient may ask another person to act on their behalf.
Where the complaint involves confidential clinical information, the clinic may require
appropriate consent or evidence that the representative is authorised to act.
Where the patient lacks capacity, the clinic will consider the appropriate legal and
professional requirements before disclosing confidential information.
19. Complaints From Solicitors or Legal Representatives
If correspondence is received from a solicitor or legal representative alleging negligence,
injury, breach of duty or seeking compensation, the matter should be referred promptly
to the clinic's professional indemnity insurer.
The nurse should:
• acknowledge receipt where appropriate;
• avoid making admissions of liability;
• preserve all relevant clinical records;
• avoid altering or retrospectively rewriting records;
• maintain confidentiality;
• cooperate with the insurer's investigation; and
• obtain appropriate legal advice where required.
A patient may make a complaint and pursue a legal claim simultaneously.
The clinic's complaints process does not prevent a patient from seeking independent
legal advice.
20. NMC Concerns
The nurse recognises that patients and members of the public may raise concerns with
the Nursing and Midwifery Council where they believe an NMC-registered nurse may be
putting patients or the public at risk.
The NMC generally recommends that concerns are first raised with the nurse's place of
work where possible, although serious professional concerns may be referred directly to
the NMC.
Nothing within this complaints procedure prevents a patient from contacting the NMC.
The nurse will cooperate appropriately with any NMC investigation.
21. External Escalation
If a patient remains dissatisfied following the clinic's final response, they may seek advice
or make a complaint to an appropriate external organisation depending upon the nature
of their concern.
This may include:
Nursing and Midwifery Council (NMC)
For concerns about the professional conduct, competence or fitness to practise of an
NMC-registered nurse.
Information Commissioner's Office (ICO)
For concerns relating to the handling of personal data or data protection.
Trading Standards / Citizens Advice
For appropriate consumer-related concerns.
Professional indemnity insurer
Where appropriate in relation to clinical or legal matters.
Legal adviser
Where a patient believes they may have a clinical negligence or other legal claim.
The clinic will not discourage a patient from exercising any lawful right to seek
independent advice or make a complaint to an appropriate regulatory or statutory body.
22. Unreasonable or Abusive Complaints
The clinic recognises that patients may be upset or distressed when making a complaint.
Patients will not be labelled as unreasonable merely because they are persistent or
dissatisfied.
However, the clinic may take reasonable steps where behaviour becomes abusive,
threatening, discriminatory or excessively repetitive.
Examples may include:
• threatening behaviour;
• abusive or discriminatory language;
• harassment;
• repeated contact after the complaint has been fully answered;
• demands that are disproportionate or impossible to fulfil;
• contacting the clinic through multiple channels repeatedly about the same issue;
or
• threatening staff.
Where necessary, the clinic may:
• request that communication remains in writing;
• limit communication to a nominated method;
• set reasonable communication boundaries; or
• seek appropriate professional or legal advice.
Any restriction will be proportionate and will not prevent the patient from raising a
legitimate clinical safety concern.
23. Complaints Register
The clinic will maintain a confidential complaints register.
The register will record:
• complaint reference number;
• date received;
• patient identifier;
• nature of complaint;
• treatment involved;
• seriousness/risk assessment;
• actions taken;
• whether independent advice was obtained;
• outcome;
• date response sent;
• learning identified;
• corrective action;
• date closed.
The complaints register will be maintained securely and separately from routine patient
records where appropriate.
24. Learning From Complaints
Complaints will be viewed as an opportunity to improve the quality and safety of the
service.
Following a complaint, the nurse will consider whether changes are required to:
• clinical practice;
• consultation;
• consent;
• treatment protocols;
• patient selection;
• aftercare;
• record keeping;
• photography;
• communication;
• patient information;
• staff training;
• equipment;
• product selection;
• infection prevention;
• emergency procedures; or
• clinic policies and SOPs.
Where appropriate, changes will be documented.
25. Annual Complaints Review
At least annually, the nurse will review complaints and significant concerns received
during the previous year.
The review will consider:
• number of complaints;
• nature of complaints;
• recurring themes;
• clinical incidents;
• adverse events;
• response times;
• outcomes;
• corrective actions;
• patient safety implications;
• whether policies or SOPs require updating; and
• whether further education or training is required.
A short annual complaints review record will be retained.
26. Record Retention
Complaint records will be retained securely in accordance with the clinic's records
management and data retention policy.
Records will not be destroyed or altered while a complaint, investigation, legal matter,
regulatory investigation or insurance matter remains ongoing.
27. Equality and Accessibility
The clinic will make reasonable efforts to ensure that patients can access the complaints
process regardless of disability, communication difficulty, age or other protected
characteristic.
Reasonable adjustments may include:
• allowing complaints verbally;
• allowing a representative to assist;
• providing information in an alternative format;
• allowing additional time;
• using accessible communication methods.
28. Staff and Professional Conduct
Although the clinic is a lone-practitioner service, the nurse will ensure that any person
working on behalf of the clinic understands the importance of:
• patient confidentiality;
• respectful communication;
• accurate documentation;
• reporting concerns;
• patient safety; and
• cooperation with the complaints procedure.
29. Patient Information
The following statement may be included on the clinic website, treatment information
and/or displayed within the clinic:
We welcome feedback and take complaints seriously.
If you are unhappy with any aspect of your care or treatment, please contact us as soon as
possible so that we can understand your concerns and try to resolve them.
You can make a complaint verbally, by email or in writing. You will not be treated
differently because you have complained.
We will acknowledge formal complaints promptly, investigate them fairly and provide a
written response.
As an independent nurse-led clinic, we aim to resolve concerns directly wherever possible.
Where a matter is serious or requires independent clinical review, we may seek advice
from an appropriately qualified independent professional or our professional indemnity
insurer.
Making a complaint to the clinic does not prevent you from contacting an appropriate
external organisation, including the Nursing and Midwifery Council (NMC) where your
concern relates to professional practice, or the Information Commissioner's Office (ICO)
where your concern relates to personal data.
30. Complaints Contact Details
Complaints Contact:
Alison Taylor
Clinic:
Alison Taylor Medical Cosmetics
Email:
alison.taylormedical@gmail.com
Telephone:
07887808680
Postal Address:
Blushes, 16/17 Montpellier Walk, Cheltenham, Gloucestershire GL501SD
Professional Indemnity Insurer:
HFIS as Alison Pearce
31. Complaints Procedure – Quick Reference
Step 1 – Complaint received
Record the date, patient's details and nature of the concern.
Step 2 – Assess immediate risk
Determine whether there is an immediate clinical or safeguarding concern.
Step 3 – Acknowledge
Acknowledge the formal complaint within 5 working days.
Step 4 – Investigate
Review the clinical records, treatment, consent, communications and relevant evidence.
Step 5 – Independent review
Obtain independent clinical, professional, legal or insurance advice where appropriate.
Step 6 – Respond
Provide a clear written response, normally within 20 working days.
Step 7 – Corrective action
Where appropriate, apologise, rectify the issue and implement improvements.
Step 8 – Record
Document the complaint, investigation, outcome and learning.
Step 9 – Escalate
Where appropriate, refer or notify the relevant professional, regulatory, legal or insurance
organisation.
Step 10 – Review
Include significant complaints and learning in the annual complaints review.
32. Policy Review
This policy will be reviewed at least annually or sooner if:
• legislation changes;
• NMC standards or guidance change;
• the nature of the clinic's services changes;
• a significant complaint identifies a weakness in the procedure;
• an adverse event occurs; or
• professional indemnity or other relevant advice requires amendment.