The Significance of Complaints Management

If you have survived a serious complaint situation in your RTO you probably now respond in one of two ways. You either live in fear of it happening again or perhaps despite how arduous it was you have learnt from the experience, take a proactive approach to managing compliance across your RTO and ensure you are equipped for unexpected issues.

It is almost certain that a training organisation will from time to time have to deal with complaints and assessment appeals from students. Why? Because the students that you train and assess are diverse. They bring a range of life experiences, different backgrounds and demographics, a variety of cultural expectations and a range of language capabilities. They also come with different education experience and bring different expectations of what the student experience should be.  The student experience encompasses all aspects of student life and whilst the key focus is achieving academic outcomes, the diversity of your student population dictates the need to consider the social, welfare and support needs of students. You must take seriously all complaints that arise, deal with them promptly and use the information gathered to improve your practices.

Indeed the regulator is now using the student journey and experience as the basis of their auditing approach and using data from complaints and appeals to build your RTO’s risk profile so you really should consider your current processes and identify if they are putting you at risk!

This is what we will look at in this blog post.

What do the Standards say?

Firstly let’s take a look at the Standards for RTOs 2015. Standard 6 is as follows:

‘Complaints and appeals are recorded, acknowledged and dealt with fairly, efficiently and effectively.’[1]

This Standard consists of 6 Clauses that guide the RTO on the way to manage, review and respond to complaints and appeals. The RTO must:

  • have accessible complaints and appeals policies and processes and should respond to a complainant or an appellant within 60 calendar days of finalising the complaint and appeal.
  • maintain records of all complaints and appeals, identifying the possible causes and should take action to rectify the situation.

This is of course the procedural aspect of complaints management i.e. what you must have in place to deal with the situations as they occur. But there is more to it.

The User’s Guide to the Standards for RTOs 2015 states that the RTO should:

‘Record all complaints and appeals received, and document outcomes’, and that the RTO should ‘Use this information to review (your) RTO’s processes and practices to ensure the issue doesn’t happen again.’[2]

We find that many RTOs are missing opportunities by overlooking the information gathered from complaints, appeals and issues.

Feedback and Improvement

From our experience working with a wide range of RTOs, it is typical to find that the only type of feedback gathered about RTO services is from student feedback forms. And in many cases, those forms only include questions about training so there is very little data gathered about the overall student experience or the support provided by the RTO. Oddly enough, very few RTO managers value the information that could be gleaned from complaints and issues (routine matters that are reported over the phone or face to face e.g. links that don’t work on websites, incorrect names for services etc).

But the bigger concern is that many RTOs lack a systematic approach for reviewing feedback of any kind and using the information to inform improvement activities. We believe that this leaves the RTO at risk, particularly with the new approach to auditing!

The Case Study below demonstrates this blinkered approach to complaints management and improvement. For the purpose of our case study we will refer to the RTO as The Short Course RTO.

The Short Course RTO

The Short Course RTO delivers 5 different short courses almost every day each week. On average they enrol between 15-20 students into each of their short courses so the overall number of students they deal with is very high. All students are expected to complete student survey forms at the end of the course. The questions in this survey focus only on the quality of the training and the trainer. Most students tick the boxes and provide very little written feedback. Many students have significant difficulty reading English and don’t bother to complete the form at all.

The RTO rarely reviews the information gathered from these forms. The last time they looked at the data was when they were preparing for a monitoring audit 3 years ago. Almost 100% of the respondents in all courses said that the training and the trainer were adequate. In reality the information gathered was not useful and the RTO could gain no insight about quality improvement. Due to the high number of students and the pressure on staff to enrol, train, assess and provide certification to all these students there is very little time to address operational problems and think about improving the system.

This high numbers of students also resulted in at least 10-20 issues that the RTO had to manage each month. These issues ranged from website glitches to communication breakdowns about enrolment, payment and assessment requirements. They also deal, with about 1-2 serious complaints or appeals every 6 months. These have included staff bullying other staff, students claiming that they were treated unfairly in the classroom and assessment appeals. Over the past 2-3 years students have regularly complained that the training and handouts were not sufficient to prepare them for assessment tasks.

Once complaints, appeals and lesser issues are dealt with the RTO records the information as required by the Standards. However, the information is not used as part of review and improvement, despite the fact that many of the issues are recurring.

If this RTO was to review the data collected as a result of complaints and appeals it would uncover problems such as:

  • Incomplete and poorly constructed learning materials
  • Training that does not cater for the LLN needs of students
  • Assessment that does not cater for the LLN needs of students
  • Training and assessment that focus only on knowledge and not skills
  • Students completing courses and not being equipped for the workplace
  • Intimidation of students in the classroom from trainers/assessors who wish to complete training early
  • Trainers providing answers to students to speed up the assessment process.
  • Inadequate assessment instructions for both students and staff
  • Uncooperative support staff who themselves have poor oral and spoken English.

In summary: the student feedback mechanism is not effective, information gathered is rarely reviewed and a useful source of information is ignored! The RTO is not providing a quality training and assessment experience. The RTO is also taking a reactive approach to compliance and quality management.

Structured continuous improvement

How would you address this situation?

We would recommend that the RTO implement a structured continuous improvement cycle that is proactive and:

  • Incorporates a review of all key result areas of the business, (not just training and assessment);
  • Values compliance and quality management, making compliance and risk everyone’s business and part of everyday tasks
  • Equips all staff to participate in review and improvement activities;
  • Includes regular monitoring of activities to ensure that processes are aligned to relevant standards and criteria and meets quality targets and expectations. Monitoring should use a range of information sources including student feedback, and complaints and appeals to identify gaps and determine improvements required
  • Addresses any gaps in performance and documents changes made.

The table below illustrates a cycle of review relating specifically to feedback and includes student feedback and information from complaints and appeals. Of course this cycle can be adjusted to suit the rhythm of different RTOs but you will note that the collection of data from complaints and appeals (and we would include issues such as those described in the Case Study above) is collected and reviewed on a monthly basis.  If reported routinely to management, this enables the RTO to quickly identify potential problems and deal with them before they become major complaints.


Key Result Area Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Training and Assessment (Student Feedback)     x x x x
Training and Assessment (Complaints and Appeals) x x x x x x x x x x x x


How do you gather and use feedback data?

Do you take this approach in your RTO or something similar? If not use the following questions to help analyse what needs to change:

  • Do you ask all students to provide feedback on the student experience?
  • Do your current feedback forms include questions on all aspects of the student experience?
  • How often do you review feedback forms?
  • What do you do with the information you gather?
  • What other forms of feedback do you gather e.g. interviews with employers, observation on the job after training?
  • Do you record information gathered from complaints, appeals and other issues?
  • What do you do with this information (if it is gathered)?
  • How do you use the combined feedback information to improve your RTO and minimise the risks of non-compliances, complaints etc?
  • Do your current compliance management and quality improvements processes give you confidence about your RTO’s readiness for audit or complaints/appeals?

How we can help

The Learning Community has helped many organisations to plan and change their approach to compliance management and quality improvement. You might like to check out some of our products that can help you with continuous improvement and quality management.

Our Quality Improvement Policy Pack contains a Continuous Improvement Policy that provides guidance on the RTOs approach to systematic continuous improvement. The policy consists of the policy statement and a section detailing the procedures to be followed in the RTO. The pack also includes a Compliance Scheduling tool which will assist your RTO to plan a cycle of review and improvement that addresses all key result areas of your RTO and is aligned with the Standards for RTOs 2015. This tool also contains a list of items to be included on compliance, management and staff meeting agendas each month.

Our Continuous Improvement Policy Pack contains the Continuous Improvement Policy, mentioned above. The pack also includes 13 forms and other documents to support the policy and procedures including: Complaints and Appeals forms, Validation Checklists, Continuous Improvement Schedule and a range of other registers.

If you would like to talk to us further about how you can cultivate this type of approach to compliance in your RTO, comment below or contact us on

We’d love to hear your stories.






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