The objective of the audit was to assess the effectiveness of the Australian Broadcasting Corporation’s (ABC’s) management of complaints.

Summary and recommendations

Background

1. The Australian Broadcasting Corporation (the ABC), established in 1932, is one of Australia’s two national public broadcasters. It produces a variety of media content including television, radio and online. The ABC receives a large amount of audience feedback each year, including complaints that range from minor issues of personal preference to allegations of breaches of the ABC’s Editorial Policies. In 2016–17 the ABC received 58 477 written audience contacts of which 30 881 (53 per cent) were complaints.

Audit objective and criteria

2. The objective of the audit was to assess the effectiveness of the ABC’s management of complaints. To form a conclusion against the audit objective, the ANAO adopted the following high level criteria:

  • Is the ABC’s complaints process clear, accessible and responsive to the public?
  • Does the ABC have sound processes and practices to effectively manage complaints?
  • Does the ABC regularly analyse and report complaint outcomes and review the effectiveness of its complaints management process?

Rationale for undertaking the audit

3. Effective complaints management assists the ABC to be transparent, accountable and continuously improve its content and services. The ABC’s management of complaints was selected for audit to provide assurance that the ABC has effective processes and procedures in place to manage complaints, and regularly analyses and reports on complaints outcomes to inform improvements to its broadcasted content and other services.

Audit methodology

4. In undertaking the audit the ANAO:

  • referenced the Commonwealth Ombudsman’s Better Practice Guide to Complaint Handling and the Australia/New Zealand Standard Guidelines for complaint management in organizations (AS/NZS 10002:2014), in order to benchmark the ABC against better practice (see Appendix 1 for more information);
  • reviewed and analysed policy documents, guidelines, procedures, and relevant files;
  • examined the management of a randomly selected sample of 270 complaints (36 editorial and 234 non-editorial) received by the ABC in 2016–17; and
  • interviewed or received written input from staff in the relevant sections of the ABC.

Conclusion

5. The ABC effectively manages complaints handled by its central complaints management area. The ABC’s limited visibility over content areas’ handling of complaints reduces the overall effectiveness of its complaints management.

6. The ABC’s complaints process is accessible to the public, easy to navigate and responsive to complainants. The ABC has effective processes and practices in place for complaints managed by its central complaints management unit, Audience and Consumer Affairs (A&CA). The ABC monitors complaints managed centrally but it has limited visibility over the progress and outcomes of the less significant but higher volume complaints managed directly by content areas.

7. The ABC analyses and reports complaints to internal and external stakeholders. The external information that the ABC publishes on complaints assists in maintaining its transparency and accountability as a public broadcaster. The ABC provides analysis of complaints data to relevant decision-makers to inform continuous improvement of its programs and services.

Supporting findings

8. Clear information and guidance on the ABC’s complaints management process and procedures is accessible to the public from the ABC website. The complaint lodgement methods offered by the ABC are clearly identified in the available guidance and are easy to use.

9. The ABC acknowledges complaints, provides investigation progress updates on request and informs complainants of the outcomes following an investigation into their complaint.

10. A&CA has processes in place to record, allocate, monitor, investigate and respond to complaints. The ABC content areas that were reviewed had processes in place to manage complaints referred to them for direct response. The ABC does not, however, have central visibility over content areas’ responses. The ABC’s key complaints handling guidance is consistent with better practice complaints management principles, but could be improved to make it clearer and more user-friendly.

11. The ABC has suitable complaints management software in place to support the central complaints management function administered by A&CA. Content areas do not use the system but employ other tools to manage complaints, such as email or spreadsheets.

12. A&CA manages written complaints in accordance with the ABC’s policies and procedures. In the absence of consistent or complete record-keeping by content areas, it was not possible to review the level of content area compliance with policies and procedures.

13. The ABC records the timeliness of its responses to complaints managed by A&CA; complete records are not kept on the timeliness of the content areas’ responses. In 2016–17, A&CA responded to 98 per cent of complaints within 60 days and approximately 60 per cent of complaints were finalised within the ABC’s 30-day target.

14. A&CA effectively monitors the allocation and progress of the complaints it investigates. As the ABC does not have central oversight of the less significant but higher volume complaints managed by ABC content areas, it is not in a position to monitor these complaints.

15. The ABC maintains the confidentiality of complainant data. It has a suitable approach in place for collecting, storing, and sharing complaint information and only those staff requiring access to complaints can view complainants’ details. Complainant details are not included in public or internal reports on complaints.

16. A&CA’s responses to written complaints are clear and address the issues raised by complainants. A&CA monitors the implementation of remedial action required to address a complaint. As there is limited visibility of complaints managed by content areas, it is unclear whether content areas’ responses effectively address the complaints.

17. The ABC regularly produces a range of internal reports on complaints which are tailored to target groups such as the ABC Board or ABC staff. The ABC also publishes complaints information on its website.

18. The ABC analyses the complaints held in its central complaints database, and publishes this analysis through various internal and external complaints reports. The analysis is distributed to the appropriate areas and decision-makers within the ABC for consideration in the context of improving content and services.

19. The ABC’s last major review of its complaints management process was in 2009.

Recommendation

Recommendation no.1

Paragraph 3.48

The ABC ensures that it has visibility over content areas’ management of and response to complaints, in order to have assurance that their processes are effective. To support this the ABC should implement record-keeping requirements, including a baseline level of information that content areas are required to document regarding complaints and outcomes.

ABC response: Partially agreed.

Summary of the Australian Broadcasting Corporation’s response

20. The ABC is Australia’s leading national broadcaster—each week, 12.3 million Australians watch ABC TV, 4.8 million listen to ABC Radio and millions more engage with us online through various digital channels. Each of these audience members forms an impression of the ABC and its content; some make contact with us to share these impressions.

21. Audience feedback, including complaints, is valuable to the ABC and we appreciate the time people take to pass on their views.

22. The vast bulk of complaints received by the ABC reflect individual audience members’ likes and dislikes based on their personal tastes and preferences (‘non-editorial complaints’). Examples routinely include critiques of presenters’ speech and appearances; the fact that the ABC broadcasts program repeats; and views that particular subjects should have received more or less coverage on a given day.

23. A smaller number of complaints received by the ABC assert that we have failed to meet our published editorial standards (‘editorial complaints’). Editorial complaints, can raise serious matters going to the ABC’s integrity and the trust Australians have in us. Editorial complaints are largely managed centrally by ABC Audience and Consumer Affairs.

24. The ABC’s proportionate approach to complaint handling deliberately applies greater controls and resources to editorial complaints, while allowing non-editorial complaints to be dealt with in more flexible ways, usually handled directly by content teams.

25. We are gratified that the ANAO has found that Audience and Consumer Affairs manages complaints effectively, with processes in place to record, allocate, monitor, investigate and respond to these complaints. The ANAO found that Audience and Consumer Affairs provides clear and relevant responses to complaints, and monitors implementation of remedial action. The ANAO review also recognises that the ABC uses complaints data collected to identify trends or issues, informing continuous improvement of content and service delivery.

26. We acknowledge that the ANAO found fewer controls in place for minor complaints managed directly by content areas, and that the audit was not always able to sight documentary evidence demonstrating how a particular complaint had been handled. The ABC is generally satisfied that this is consistent with the proportional approach outlined above, as well as the ABC’s ongoing focus on reducing administrative costs in order to maximise funding of content initiatives. In our view, implementation of the ANAO’s recommendation would impose an unwelcome and ongoing cost on content teams that would be disproportionate to the benefits of achieving full visibility over every complaint received and handled by the ABC. The ABC intends taking targeted action to obtain assurance, confident that this will address the issue.

27. The ABC periodically reviews and improves its Complaints Handling Procedures and associated guidance for staff. The most recent update, made in 2017, is acknowledged in the ANAO report. The ABC will continue to evaluate our practices, including by reference to leading practice externally.

28. ABC Group Audit will monitor the action arising from the ANAO review and will continue to periodically evaluate complaints management as part of its cyclical coverage of key ABC process.

Key learnings for all Australian Government entities

Below is a summary of key learnings identified in this audit report that may be considered by other Commonwealth entities managing existing programs.

Policy/program implementation

Records management

1. Introduction

Background

1.1 The Australian Broadcasting Corporation (the ABC), established in 1932, is one of two national public broadcasters in Australia. The functions of the ABC include the provision of:

  • broadcasting services across the national, commercial and community sectors;
  • news, current affairs, entertainment and cultural enrichment to other countries;
  • digital media services; and
  • encouragement and promotion of musical, dramatic and other performing arts in Australia.1

1.2 The ABC is subject to the Australian Broadcasting Corporation Act 1983 (ABC Act) and to the Editorial Policies established by the ABC Board.2 The purpose of the Editorial Policies is to assist the ABC to provide content which fulfils its functions under the ABC Act to a high standard. The Editorial Policies cover:

  • independence, integrity and responsibility;
  • accuracy;
  • corrections and clarifications;
  • impartiality and diversity of perspectives;
  • fair and honest dealing;
  • privacy;
  • harm and offence;
  • children and young people;
  • public access and participation;
  • announcements about ABC programs and activities;
  • advertising and sponsorship restrictions;
  • commercial references; and
  • external funding relationships.

1.3 The ABC Act3 requires the ABC Board to develop a Code of Practice4 relating to its television and radio programming. The ABC collectively refers to its Code of Practice and Editorial Policies as ‘editorial standards’ and this term is used throughout this report.

1.4 The ABC is also subject to the Broadcasting Services Act 1991 which promotes diversity of content and provides the regulatory framework to facilitate an efficient, competitive and responsive broadcasting industry. The Broadcasting Services Act applies to the ABC primarily in relation to complaints escalation, spectrum5 and technical matters.

1.5 Under the Broadcasting Services Act, the Australian Communications and Media Authority (the ACMA) performs an independent role where complaints are made regarding a national broadcaster’s compliance with its code of practice and the complainant is not satisfied with the broadcaster’s response. The Broadcasting Services Act also requires the ABC to notify its Code of Practice to the ACMA.

Organisational structure and budget

1.6 On 12 February 2018, the ABC implemented a new structure with the former four content divisions—Television, News, Radio and Regional—restructured into three divisions:

  • Entertainment and Specialist, which includes children’s content, music and creative development, factual and entertainment, drama, comedy and Indigenous programming;
  • News, Analysis and Investigations for state coverage, network news and investigations and in-depth reporting; and
  • Regional and Local which includes the rural and regional teams as well as capital city and regional production.

Figure 1.1: ABC organisational structure

A high-level depiction of the ABC’s structure, including the three content divisions which contain the majority of the ABC staff.

Source: ANAO representation of the ABC’s documentation.

1.7 The ABC’s Annual Report 2016–17 stated that the ABC employed 4769 staff across Australia during that year, with the majority (70 per cent) employed in content areas. In 2016–17, the ABC received $1.04 billion in government funds and $70.4 million from other sources.6 The ABC is a corporate Commonwealth entity operating under the Public Governance, Performance and Accountability Act 2013.7

Complaints management in the ABC

1.8 In 2016–17 the ABC received 58 477 written audience contacts of which 30 881 (53 per cent) were complaints.8 The remaining contacts were requests, suggestions, comments of appreciation or other matters.

1.9 Figure 1.2 sets out the top ten categories of complaints managed by the ABC in 2016–17. The largest category was ‘management issues’ which refers to the ABC’s decisions around content, in particular ceasing production or broadcasting of a program. This type of complaint generally does not relate to the ABC’s editorial standards.9

Figure 1.2: Most common complaints by primary category, 2016–17

A bar chart showing the top ten most common complaint categories by editorial and non-editorial. Most complaints fall under Management issues or Standards of presentation.

Notes: The definition of editorial and non-editorial complaints is discussed from paragraph 1.14.

Complaints were categorised into 21 primary categories, the 10 categories displayed represent 90.1 per cent of complaints managed in 2016–17.

A complainant can raise one or more issues in a single complaint (for example, both bias and accuracy). In 2016–17, the ABC finalised 30 881 complaints, covering 31 063 issues.

Source: ANAO analysis of ABC complaints data 2016–17.

1.10 The ABC categorises complaints into 20 genres where applicable, and the 10 genres displayed in Figure 1.3 represent 67.6 per cent of complaints managed in 2016–17.

Figure 1.3: Most common complaints by genre, 2016–17

Most common complaints by genre 2016-17

Notes: The definition of editorial and non-editorial complaints is discussed from paragraph 1.14.

Complaints which had no genre allocated or were categorised as either ‘non-applicable’ or ‘other’ were excluded.

A complainant can raise one or more issues in a single complaint (for example, both bias and accuracy). In 2016–17, the ABC finalised 30 881 complaints, covering 31 063 issues.

Source: ANAO analysis of ABC complaints data 2016–17.

1.11 Figure 1.4 shows the genre of complaints by category of complaint.

Figure 1.4: Genre of complaints by category of complaints, 2016–17

Genre of complaints by category of complaints 2016-17

Source: ANAO analysis of ABC complaints data 2016–17.

Audience and Consumer Affairs

1.12 Audience and Consumer Affairs (A&CA) is a unit within the ABC which is separate to the content areas and reports to the ABC Editorial Director. A&CA has two roles in responding to audience complaints:

  • A&CA’s Audience Liaison Team manages general complaints which do not relate to editorial standards and may include such matters as personal opinion and preference, for example program scheduling changes; and
  • where a written complaint suggests that the ABC may have breached its editorial standards, the A&CA Investigations Team may investigate the complaint and determine whether there was a breach.

1.13 The ABC distinguishes between non-editorial and editorial complaints; the distinction determines the amount of time and resources used to deal with a complaint.10 In 2016–17 the ABC received a total of 30 881 complaints, comprising 3613 editorial complaints and 27 268 non-editorial complaints.

Non-editorial complaints

1.14 The ABC’s editorial guidance classifies a complaint as non-editorial if it:

  • is anonymous, or the complainant has not provided sufficient contact details to allow a response to be sent11;
  • does not refer to a specific item of ABC content or ABC service (for example, a complaint that a particular presenter was biased, but did not include examples);
  • clearly demonstrates that no response or action was required (for example, complainants using webforms may be asked to indicate whether they wish to receive a response);
  • refers to content that has not yet been broadcast or published (noting that there are some rare exceptions to this general rule);
  • relates to a personal preference rather than the editorial standards (for example, a preference for coarse language to be avoided or for a particular political party to receive less coverage);
  • relates solely to the ABC’s values and standards of workplace behaviour rather than the editorial standards (noting that there can be areas of overlap); or
  • relates solely to compliance with the law rather than the editorial standards (noting that there can be areas of overlap).12

1.15 A&CA may respond to non-editorial complaints on behalf of content areas. A&CA may also coordinate non-editorial complaints which are more complex or require input from several areas.

Editorial complaints

1.16 An editorial complaint is a written complaint about one or more specific items of ABC content, alleging a breach of the ABC’s editorial standards and:

  • expressing dissatisfaction about one or more specific items of ABC content or a specific ABC service;
  • explicitly or implicitly demonstrating an expectation of a response and action by the ABC; and
  • relating to the ABC’s editorial standards.13

1.17 A&CA initially reviews and assesses written editorial complaints to determine if an investigation is required. Where a complaint is accepted for investigation, A&CA assesses the seriousness and complexity of the matter to determine the extent of resources required to undertake the investigation.

Responses, investigations and findings

1.18 Where an editorial complaint is accepted for investigation, A&CA will liaise with the respective content area as necessary in order to form a preliminary finding and a subsequent final outcome in terms of the following three categories:

  • resolved—complaints are resolved where the ABC took remedial or corrective action14;
  • upheld—complaints are upheld, either fully or in part, where the ABC editorial standards are determined not to have been met; and
  • not upheld—complaints are not upheld where the ABC editorial standards are determined to have been met.

1.19 A&CA finalised 2348 investigations in 2016–17, of which 6.9 per cent were upheld.

Audit approach

1.20 Effective complaints management contributes to transparency, accountability and the continuous improvement of services and products. The ABC’s management of complaints was selected for audit to provide assurance that the ABC has effective processes and procedures in place to manage complaints, and that it regularly analyses and reports on complaints outcomes to inform improvements to its broadcasted material and other services.

1.21 The objective of the audit was to assess the effectiveness of the ABC’s management of complaints. The audit focussed on the key processes of receiving, handling and recording complaints, as well as complaint reporting and analysis.

1.22 The merits or content of complaints, and the ABC’s decision-making and associated responses to complaints, were not examined as part of the audit.

1.23 To form a conclusion against the audit objective, the ANAO adopted the following high level criteria:

  • Is the ABC’s complaints process clear, accessible and responsive to the public?
  • Does the ABC have sound processes and practices to effectively manage complaints?
  • Does the ABC regularly analyse and report complaint outcomes and review the effectiveness of its complaints management process?

1.24 In undertaking the audit the ANAO:

  • referenced the Commonwealth Ombudsman’s Better Practice Guide to Complaint Handling and the Australia/New Zealand Standard Guidelines for complaint management in organizations (AS/NZS 10002:2014), in order to benchmark the ABC against better practice (see Appendix 1 for more information);
  • reviewed and analysed policy documents, guidelines, procedures, and relevant files;
  • examined the management of a randomly selected sample of 270 complaints (36 editorial and 234 non-editorial) received by the ABC in 2016–17; and
  • interviewed or received written input from staff in the relevant sections of the ABC.

1.25 The audit was conducted in accordance with ANAO Auditing Standards at a cost to the ANAO of approximately $337,000.

1.26 The team members for this audit were Renina Boyd, Barbara Das, Samuel Meredith and Deborah Jackson.

2. Clarity, accessibility and responsiveness of the complaints process

Areas examined

This chapter examines whether the Australian Broadcasting Corporation’s (ABC’s) complaints process is clear, accessible and responsive to the public.

Conclusion

The ABC’s complaints process is accessible to the public, easy to navigate and responsive to complainants.

Is it easy to lodge a complaint and is clear guidance available to the public?

Clear information and guidance on the ABC’s complaints management process and procedures is accessible to the public from the ABC website. The complaint lodgement methods offered by the ABC are clearly identified in the available guidance and are easy to use.

Lodging a complaint

2.1 There are a number of ways a person can lodge a complaint with the ABC:

  • Online—through the ‘Lodge a Complaint’ webform on the ABC’s website.15 Webpages for specific ABC content (such as specific television programs, news sites, ABC Shop and ABC radio stations) also provide the option to make contact via their direct email addresses. These webpages direct people to make more formal complaints through the complaints webform.
  • The ABC also receives comments and feedback on social media and text messaging services—the ABC specifies on its website that contact through these mediums is not considered a formal complaint. When a content area sees a social media post or text message that appears to be making a more serious complaint, they can direct the person to the complaints webform.
  • Mail—by writing to the ABC.
  • Telephone—by calling the ABC’s national telephone number, which is listed on the ABC’s website and in the White Pages directory. A switchboard operator will transfer the caller to the relevant content area to which the complaint relates. The ABC advises that it seeks to manage telephone complaints immediately or via return call. In instances where the complaint is of a serious nature, the ABC switchboard operator will request the caller to put their complaint in writing through the complaints webform.

2.2 The ABC recognises that some complainants may be unable to put their complaint in writing and ABC staff may log verbal complaints on a person’s behalf where appropriate. The ABC also provides information on the Translating and Interpreting Service for complainants who use a language other than English and a teletypewriter service for complainants who experience hearing or speech difficulties. The Department of Communications and the Arts and the Australian Communications and Media Authority (the ACMA) also link to the ABC’s complaints information on their websites.

2.3 Overall, the ABC provides a suitable range of methods to lodge a complaint. The complaints webform is easy to use and clearly identifies that once lodged, the complaint will be forwarded to Audience and Consumer Affairs (A&CA).

Guidance material

2.4 Sufficient guidance is available to the public about the ABC’s complaints process and how to make a complaint. The ABC provides information on its ‘Lodge a Complaint’ webform and information is also available from content area webpages.

2.5 The ABC’s public guidance communicates the key points of information outlined in the Australian/New Zealand Standard for complaint management, as described in Table 2.1.

Table 2.1: ABC’s publicly available complaint management information

AS/NZS guidelinesa

Information communicated by the ABC

Where, how and when complaints can be made

Guidance on how to make a complaint is provided on the ABC’s website. Complainants are informed that complaints regarding the ABC can be made online, via post and over the telephone and should be lodged within six weeks of the original broadcast.

When acknowledgement of complaints could be expected

Complainants are informed that ‘the ABC aims to respond to complaints within 30 days of receipt and in some cases proportionate handling would mean the complainant received no more than the automated acknowledgement email’.

What information should be provided by the complainant

Complainants are informed that their complaint should clearly outline the nature of their concerns such as the specific item of ABC content that had possibly breached ABC’s Code of Practice or Editorial Policies. Complainants are advised to provide their name and contact information; the option to remain anonymous is also communicated.b

The organisation’s process for handling complaints

The ABC website outlines the process for handling complaints. More detailed information is made available in the ABC’s Complaint Handling Procedures.

Time periods associated with the process

In addition to informing complainants of the ABC’s aim to respond within 30 days, the ABC’s Complaint Handling Procedures discuss the general timeframes for the complaints management process.

Where appropriate, possible options for redress and the complainant’s options for review

The ABC website informs complainants that, where relevant, they will be advised of any remedial action that would be or had already been taken by the ABC to address the complaint. Where the complaint related to the ABC Code of Practice, complainants are advised that they will be provided with the option to refer the matter to the ACMA.

How the complainant could obtain feedback on the status of their complaint

The ABC website reiterates that not all complainants will receive a response but if a response is expected, complainants are advised to contact A&CA using the webform and cite the reference number of the original complaint.

   

Note a: Summarised from the AS/NZS 10002:2014

Note b: The ABC website states that anonymous complaints will not receive a response; it does not state that the complaint will be considered to be non-editorial in nature.

Source: AS/NZS 10002:2014, Section 8.1 and ANAO analysis of ABC’s information.

2.6 On 1 December 2017, updates were made to the information on the ABC’s ‘Complaints process’ and ‘Lodge a complaint’ webpages and to the automated complaint acknowledgement email. The changes addressed the risk of a complainant expecting that a response would be provided when they included their name and a valid email address. The ABC set clearer expectations, with complainants informed that they may not receive a response beyond the automated acknowledgement email in accordance with the ABC’s proportionate approach to complaints management. The changes clarified that where complaints are made about personal taste, preference or other non-editorial matters, A&CA would note the concern and ensure it was made available to the relevant content area.

Does the ABC provide complainants with information regarding their complaint, such as an acknowledgement, updates on investigation progress and final outcomes?

The ABC acknowledges complaints, provides investigation progress updates on request and informs complainants of the outcomes following an investigation into their complaint.

2.7 The ABC’s Complaint Handling Procedures do not state that communication with complainants needs to be made at specific points throughout the complaint handling process, but rather it focuses on communication at the beginning and end stages of the process.16 Complainants are also informed of the option to contact A&CA regarding their complaint if they are expecting a response and it has not been provided.

2.8 Complaints lodged using the webform, where a valid email address is included, receive an automated acknowledgement email. The email acknowledges that the complaint has been received and provides a reference number. The acknowledgement clearly communicates the circumstances where a response would not be provided, the ABC’s 30 day goal for responding to complaints, and links to key information such as the ABC’s editorial policies and the ABC’s Current Topics webpage.17 The Current Topics webpage contains the ABC’s responses to topical or trending issues being raised through the complaints process and can negate the need for the ABC to respond individually to a large volume of complaints on the same issue.

2.9 The ABC advised that complaints received by content areas through direct email and hardcopy mail are acknowledged where appropriate and the content areas apply the proportionality approach in determining which complaints require a response.18 The six content areas interviewed by the ANAO stated that directly-received complaints of an editorial nature are forwarded to A&CA. The ANAO was unable confirm this practice as the origin of complaints was not recorded for those in the ANAO’s sample.

2.10 As required by the ABC’s Complaint Handling Procedures, following the investigation of a complaint by A&CA, the ABC advised the complainant, where applicable:

  • the actions taken in response to the complaint;
  • whether the complaint outcome was determined to be not upheld, upheld (fully or in part) or resolved;
  • reasons for the decisions made;
  • the remedy or resolution; and
  • information about other avenues that are available to the complainant such as referring the matter to the ACMA.

2.11 In the sample of complaints reviewed by the ANAO, responses were provided to complainants about investigated complaints, where applicable. The responses complied with the ABC’s Complaint Handling Procedures, included a rationale and were easy to understand.19

3. Complaint management processes and practices

Areas examined

This chapter examines whether the Australian Broadcasting Corporation (the ABC) has sound processes and practices in place to effectively manage complaints.

Conclusion

The ABC has effective processes and practices in place for complaints managed by its central complaints management unit, Audience and Consumer Affairs (A&CA). The ABC monitors complaints managed centrally but it has limited visibility over the progress and outcomes of the less significant but higher volume complaints managed directly by content areas.

Areas for improvement

The ANAO made one recommendation aimed at ensuring that the ABC has visibility over content areas’ management of and response to complaints.

Is a complaints management system in place, supported by effective guidance material?

A&CA has processes in place to record, allocate, monitor, investigate and respond to complaints. The ABC content areas that were reviewed had processes in place to manage complaints referred to them for direct response. The ABC does not, however, have central visibility over content areas’ responses. The ABC’s key complaints handling guidance is consistent with better practice complaints management principles, but could be improved to make it clearer and more user-friendly.

3.1 The ABC has established processes for managing complaints, including recording and allocating written complaints, and roles and responsibilities for managing complaints are clearly assigned. The processes are articulated in guidance material, primarily the ABC Complaint Handling Procedures, which is discussed later in this section (paragraphs 3.15 to 3.18). Overall, the ABC’s core complaints management process is well-documented and its key features reflect better practice complaints management principles. ABC staff interviewed by the ANAO were familiar with the key aspects of the ABC’s central complaints management processes.

3.2 Figure 3.1 outlines the processes from receipt to allocation of a complaint. Written complaints received by A&CA are recorded in Resolve, the ABC’s central complaints management database.20

Figure 3.1: ABC’s complaint management – receiving and allocating complaints

This diagram sets out the initial process that the ABC follows when receiving, logging and allocating complaints that come in through the ‘Make a Complaint’ webform on the ABC website.

Source: ANAO analysis of ABC documentation.

3.3 ‘Proportionality’ determines the amount of time and resources applied by the ABC to address each complaint. The ABC has set criteria for determining proportionate complaints management21 and advised that it takes a ‘common-sense’ and individual approach to applying the proportionality criteria to each complaint.

3.4 Table 3.1 shows the allocation of complaints finalised in 2016–17.

Table 3.1: Allocation of written complaints finalised in 2016–17

ABC area

Type of complaint

Complaintsa

 

 

Number

Percent

Investigations (A&CA)

  • editorial complaints (significant)

2 188

7.1

Audience Liaison and Investigations teams (A&CA)

  • non-editorial complaints and some editorial complaints that did not require investigation but received a response

5 362

17.4

A&CA-managed subtotal

7 550

24.5

Various content areas

  • editorial complaints (minor)

1 277

4.1

  • non-editorial complaints

11 487

37.2

Content area-managed subtotal

12 764

41.3

No response (complaints recorded and noted, not allocated for action or a response)

  • complaints—where typically no response was requested, often simply expressing a general personal preference
  • offensively written complaints

10 567

34.2

Total complaints finalised

30 881

100

       

Note a: A complainant can raise more than one issue (for example, both bias and accuracy) which are recorded in Resolve separately and handled individually. In 2016–17, the ABC finalised 30 881 complaints, covering 31 063 issues.

Source: ANAO analysis of ABC complaints finalised in 2016–17.

A&CA complaints management

3.5 Within A&CA, protocols support consistent and appropriate receipt, logging, assessment, allocation and investigation of complaints. Figure 3.2 outlines A&CA’s investigation steps.

Figure 3.2: ABC’s complaints management – A&CA investigation steps

This diagram sets out the process that the ABC’s A&CA unit follows when conducting an investigation into a complaint. The key steps are: investigate the complaint, draft a response based on the preliminary findings, and send the final complaint response t

Source: ANAO analysis of ABC documentation.

3.6 The ABC Complaint Handling Procedures outline the ABC’s expected timeframes for communication between A&CA investigators and relevant content areas regarding editorial complaints. Investigators are to provide relevant content areas notification that a complaint has been accepted for investigation, the editorial standards relevant to the investigation, and any request for access to content usually within three days. Investigators are also to request comment from the content area on how it had sought to meet the editorial standards. In turn, content areas should respond to investigators usually within seven days. Refer to Table 3.2 for the ANAO’s findings against these requirements.

3.7 Communication during complaint investigations is primarily by email, both within the ABC and with complainants. Due to the nature of complaints received and A&CA’s ability to access and review broadcast material, it is not necessary for the ABC to hold in-person discussions with complainants to obtain the facts necessary to complete an investigation.

Content area complaints management

3.8 Content areas receive complaints either by referral from A&CA or directly from the public. At a high-level, the ABC Complaint Handling Procedures provide a process for content areas to manage written and telephone complaints. The Procedures require content areas to forward editorial complaints received directly from the public to A&CA and retain any non-editorial complaints for direct handling. The ABC advised that content areas inform telephone complainants of the option of submitting a written complaint where the matter is complex, or where the complaint relates to editorial standards. Content areas do not keep detailed records of telephone complaints and their content, so the ANAO was unable to verify this that this occurred in practice.

3.9 A&CA refers complaints to content areas for direct management and a response where the matters are minor editorial or non-editorial. A&CA may also forward complaints it determines do not require a response to the content area for information. In 2016–17, A&CA allocated 12 764 complaint issues (41 per cent of all written complaints) to content areas for direct management.

3.10 Complaints are devolved to content areas to manage with no requirement that they report back to A&CA, and content area responses are not recorded in Resolve. As such, the ABC does not maintain a central record of action taken by content areas, including responses to complaints.

3.11 The ANAO reviewed the complaints management practices in six content areas that had an editorial complaint in the ANAO’s sample. The six content areas interviewed did not have documented processes for managing complaints, however they appeared to have satisfactory complaints management practices in place, including:

  • complaints receipt, assessment and allocation by designated staff, for consistency;
  • oversight by senior staff, usually Executive Producers, who draft or clear complaints responses; and
  • a process for storing complaints and responses.22

3.12 The six content areas kept most of the correspondence and records relating to editorial complaints within email folders, with two teams also keeping records on a shared drive. Four areas also maintained a separate register or log of audience correspondence.

3.13 Staff in the content areas reviewed advised the ANAO that they manage non-editorial complaints they receive directly from the public in broadly the same way as they manage complaints allocated by A&CA.23 A&CA is not notified of these directly received non-editorial complaints and they are not recorded in Resolve.

3.14 Content areas described a broadly consistent approach to monitoring ABC social media accounts and managing responses to serious negative feedback. They also stated that they encourage people to submit a written complaint using the ABC’s web form if the comment seems to be editorial in nature. The ABC does not consider comments posted to social media as complaints and the approach content areas advised the ANAO they take with these comments reflects the ABC’s social media policies.24

Guidance material

3.15 The ABC’s guidance material covers key complaints handling policies and processes and is consistent with better practice complaints handling principles.25 The material includes the ABC Complaint Handling Procedures and other supporting guidance developed by content divisions specific to their requirements. Overall, the key guidance material is:

  • accessible by staff from the intranet;
  • written in plain English;
  • largely up-to-date, reflecting the ABC’s current practice of complaints handling;
  • linked to (or references) other relevant guidance; and
  • consistent with better practice complaints management principles.

3.16 The key guidance document, ABC Complaint Handling Procedures, is accessible to ABC staff and members of the public, contains information on complaints policy and processes and has a detailed focus on managing editorial complaints. While the document meets the minimum requirements of better practice complaints handling, it could be improved if it included: a clear description of its purpose and intended audience; separated discussion of procedures/processes from policy; a high level step-by-step process to guide staff on how to manage a complaint; and record-keeping requirements.26

3.17 Each of the three content divisions had developed guidance material to complement the ABC Complaint Handling Procedures. Overall, these divisional guides are suitable and well-written, although the level of detail varies and they do not consistently include clear descriptions of the roles and responsibilities for complaints management within divisions. Only one of the six content areas reviewed by the ANAO referred to the complaints guidance published by their division. The ABC should encourage staff awareness and use of the guidance material.

3.18 In 2017 the ABC updated its guidance material. The ABC Complaint Handling Procedures were updated to reflect a minor change in the way disagreements are resolved between A&CA and content areas over complaint outcomes. In September 2017, the ABC published a supplementary complaints guidance document, Editorial Guidance Note: Complaints Handling27, which included material from the ABC Complaint Handling Procedures and two other internal better practice guides. While this document is useful, at the time of audit the better practice guides remained prominent on the intranet and did not refer to the new guidance note.28 Overall, implementation of stricter version control over all of the complaints management guidance material would assist ABC staff to quickly locate the most current and relevant guidance when needed.

Are suitable IT systems in place to support complaints management?

The ABC has suitable complaints management software in place to support the central complaints management function administered by A&CA. Content areas do not use the system but employ other tools to manage complaints, such as email or spreadsheets.

3.19 The ABC has suitable software in place, Resolve, which supports the management of complaints by A&CA. Resolve is an off-the-shelf case management system implemented by the ABC in 2015. Resolve effectively supports the recording, management and reporting of complaints and investigations. The system is user friendly—allowing for easy data entry and simple searches of data fields—and has an effective reporting functionality to support monitoring and analysis of complaints.

3.20 Although complaints allocated to content areas are closed in Resolve before being finalised, A&CA records the complaint details in Resolve prior to allocation.29 As a result, there is sufficient data on all complaints assessed by A&CA to support useful reporting and analysis.30 Reporting and analysis is discussed further in Chapter 4.

3.21 While Resolve is capable of being configured to enforce a particular workflow or order in the complaints management process, the ABC chooses not to automate workflows. A&CA’s work to assess, record and allocate complaints relies on staff judgement and manual entry and its investigations into complaints do not always follow a linear process. Overall, the flexibility in the Resolve system supports the way A&CA manages complaints.

3.22 Content areas have limited access to a small number of Resolve licenses but typically do not use this system. Twenty-one ABC staff, including 11 A&CA team members, have access to Resolve and can view the database contents. When Resolve was first implemented, the ABC had expected it to be adopted progressively by more content areas, but this broader take-up did not eventuate. The ABC advised the ANAO that in 2018 it would assess the impact of the organisational restructure on the need for Resolve licenses for content areas.

3.23 Instead of Resolve, content teams use a variety of tools to manage complaints, most commonly ABC email accounts. Four of the six content teams reviewed by the ANAO supplemented their use of email by recording and managing complaints using a Microsoft Word or Excel log, and two teams also stored complaint records in Microsoft Windows folders. Two ABC internal audits into complaints management, undertaken in 2014 and 2017, noted that content areas used a number of systems to manage and record complaints.31 The 2017 internal audit’s key recommendation was that the ABC undertake a cost benefit analysis for increased access to Resolve. A&CA produced a discussion paper in response, but a cost benefit analysis has not been completed.

3.24 Resolve automatically sends email reminders to users who have been allocated a complaint where a specific task allocated as part of the complaint investigation is overdue or the complaint itself is open beyond 30 days.32 While A&CA advised that the reminders are useful, they are of less benefit where tasks have been allocated to staff outside A&CA who do not have access to Resolve. Where complaints are managed by A&CA and a content area response is overdue33, A&CA manually sends email reminders to content areas that do not have Resolve access and, where necessary, copies in the relevant Editorial Policy Advisor.

3.25 The content areas interviewed by the ANAO consider the methods they use to manage complaints suitable to their needs. However, the ANAO identified instances of ineffective record-keeping by some content areas as discussed at paragraph 3.32. The ABC would gain greater assurance of the effectiveness of content areas’ complaints management if those areas were required to keep a record of standard complaint information as outlined in the ABC’s Editorial Guidance Note – Complaints Handling, which states34:

Teams that respond to complaints more than intermittently should consider establishing a basic tracking system (such as a spreadsheet) to record complainant details, complaint issues, status of response and any outcome or specific commitments given. This information assists with providing timely responses, and can also serve as an audit trail and a source for internal reporting and information.

3.26 A tailored IT system may not be necessary for content areas that receive low numbers of complaints, but there are risks to relying solely on email systems (such as emails being inadvertently deleted or overlooked). These risks were found to have been realised during this audit35 and the ABC should take steps to ensure greater compliance with its record-keeping requirements.

Are complaints managed in accordance with established policies and procedures?

A&CA manages written complaints in accordance with the ABC’s policies and procedures. In the absence of consistent or complete record-keeping by content areas, it was not possible to review the level of content area compliance with policies and procedures.

3.27 The ANAO reviewed a sample of 270 complaints that the ABC finalised in 2016–17. The sample was comprised of complaints assessed by A&CA and recorded in Resolve. The sample did not include non-editorial complaints that content areas received directly from the public and retained for direct management and response.

3.28 Figure 3.3 shows where the sample complaints were allocated.

Figure 3.3: Allocation of sampled complaints across the ABC

a bar chart showing the ANAO’s analysis of the sample of complaints, and sets out the five key areas within the ABC where complaints were allocated. Most of the complaints were allocated to content areas but the majority of complaints were actioned as ‘No

Source: ANAO analysis.

3.29 Post-allocation actions were recorded in Resolve for the 55 complaints managed by A&CA’s Audience Liaison and Investigation teams. As the ABC does not maintain central records of content area responses, aspects of how those content areas managed complaints could not be tested for 107 complaints. The ANAO separately reviewed the 15 editorial complaints in the sample allocated to content areas for a direct response. Observations from this review are discussed further at paragraph 3.32.

3.30 The ANAO observed that for all sampled complaints, procedures were followed pre-allocation for complaints managed by A&CA, and procedures were mostly followed post-allocation. Observations are set out in Table 3.2.

Table 3.2: ANAO review of ABC complaints

Areas assessed

Sample observation

Comment

Appropriate classification of complaints for action

  • All 270 complaints were suitably allocated for action or noting, and to the appropriate area.
  • The complaint description/issue was appropriately recorded in all cases.

A large proportion of complaints (108) were classified for ‘noting only’ as the complainant did not request a response, or the complaint indicated a personal opinion, not a broadcast issue.

Responses were sent to complainants who requested one

  • A&CA responded to all 55 complaints it managed.

Responses sent by content areas are not centrally tracked. As a result, the total number of complainants who received a response is not known.

The ABC kept appropriate complaint records in its complaints database, Resolve

  • Complaints were accurately and consistently logged in Resolve.
  • Where managed by A&CA, complaint outcomes were always recorded.
  • Complete records were kept for 13 of the 19 investigated complaints in Resolve; for the remaining six, five were part of a campaign.a

A&CA advised that if a large number of complaints are received on the same issue they can become a ‘campaign’, with records saved centrally in Resolve rather than against each individual complaint within the campaign.

Complaints were finalised within the ABC’s 30-day target timeframe

  • Of the 55 sampled complaints that A&CA managed:
    • 33 were responded to within 30 days; and
    • the median response time was 27 days.

Response timeliness is discussed from paragraph 3.38.

A&CA notified ABC content teams promptly (within three days) when it began to investigate a complaint, and the content areas responded within seven days

  • Of the 19 investigated complaints:
    • for 10, the content area was promptly notified;
    • for three, notification was over three days;
    • for six, the timing was unknown from the records as they were part of a campaigna; and
    • seven content areas responded within seven days, a further seven content areas did not have records of the complaint and five did not meet the timeframes.

The ABC Complaint Handling Procedures state that: A&CA will notify a content area of its decision to accept an investigation usually within three days; and content areas will respond to A&CA usually within seven days.

There are instances where A&CA do not need to involve the content area in an investigation, therefore the content area is notified once the investigation is complete and an outcome known.

A&CA notified ABC’s content areas of the relevant editorial standards against which complaints were investigated

  • Of the 19 investigated complaints:
    • for nine, A&CA detailed the relevant editorial standards;
    • for four, A&CA did not give the content area this detail;
    • five were part of a campaigna; and
    • for one complaint, records were incomplete.

The ABC Complaint Handling Procedures state that A&CA will inform content teams of the applicable editorial standards.

Relevant published or broadcast content was reviewed

Content was reviewed in all complaint investigations.

-

Responses included a rationale and were easy to understand

Responses to all investigated complaints included a rationale, were clearly written and easy to understand.

-

     

Note a: Of the five complaints in the sample which were part of a campaign, four referenced the campaign number and one did not.

Source: ANAO analysis of ABC’s documented guidance and Resolve.

3.31 The ABC’s management of complaints relies on individual staff judgement (for example, in categorising complaints), which could lead to minor inconsistencies. The ANAO’s review of the sample found that overall the ABC’s complaints management process operated consistently. In terms of recording and allocating complaints, the ANAO observed no instances of inappropriate categorisation.

3.32 The ANAO sought details of the 15 editorial complaints in the sample that A&CA had allocated to content areas for a direct response. The complaints were allocated across 14 content areas and of these, eight were able to provide details of how they managed the complaint. In total:

  • four complaints were responded to and the responses were timely and included a rationale;
  • three complaints were not responded to because the issue was minor36;
  • one complaint had a suitable draft response prepared but it was unclear if this had been sent to the complainant; and
  • for seven complaints, the content areas had not retained records of the complaints or were unable to show what action had been taken or whether a response had been sent.

3.33 Content areas did not consistently comply with the ABC’s Records Disposal Authority which specifies the following retention periods for audience-related contacts, set out in Table 3.3.

Table 3.3: ABC’s record retention requirements

Broadcast platform

Record type

Record retention period

Radio

Records documenting public reaction that is of a simple or non-serious nature, such as telephone comments where the caller only requires views to be noted or complaints relating to personal tastes or preferences.

Includes complaints or compliments made via email, telephone, short message service (SMS) or in writing.

Two years after action completed

TV or online content

Seven years after action completed

All

Records documenting the handling of complex public enquiries about the organisation and its programs, products and services, such as historical enquiries about former programs and personalities.

One year after action completed

     

Source: ANAO summary of the ABC’s Records Disposal Authority.

3.34 The ABC regards complaints allocated by A&CA to content areas for direct response as low risk matters, although they represented 41 per cent of the total complaints received by the ABC in 2016–17. As records are closed by A&CA in Resolve once allocated, the ABC does not have any central oversight of these complaints.37 Inconsistent record-keeping by the content areas regarding these referred complaints meant that the ANAO was unable to review the quality of the management of complaints by content areas.

Are complaints resolved within timeframes?

The ABC records the timeliness of its responses to complaints managed by A&CA; complete records are not kept on the timeliness of the content areas’ responses. In 2016–17, A&CA responded to 98 per cent of complaints within 60 days and approximately 60 per cent of complaints were finalised within the ABC’s 30-day target.

3.35 Under Section 150 of the Broadcasting Services Act 1992 members of the public who complain to the ABC may seek a review from the Australian Communications and Media Authority (the ACMA) if they are dissatisfied with the ABC’s response to a Code of Practice complaint or if they do not receive a response to a complaint within 60 days.

3.36 The ABC has an internal target of responding to complaints within 30 days of receipt. While the ABC was unable to confirm the basis on which its 30-day target had been selected, its guidance expresses a commitment to meeting the timeframe and performance against the target is routinely reported (reporting is discussed in Chapter Four). A&CA response times are shown in Table 3.4.

Table 3.4: Timeliness of A&CA responses to complaints in 2015–16 and 2016–17

 

2015–16

2016–17

Total complaints A&CA responded to

(as a percentage of all written complaints)

6503

(26.3%)

7550

(24.5%)

Responses sent within 30 days

4778

(73.5%)

4624

(61.2%)

Responses sent within 60 days

6482

(99.7%)

7416

(98.2%)

     

Note: Of the 14 053 complaints A&CA responded to in 2015–16 and 2016–17 (combined), 67 per cent were responded to within 30 days.

Source: ANAO analysis of the ABC’s complaints records in Resolve.

3.37 The ANAO’s sample of 270 complaints included 19 editorial complaints investigated by A&CA. Of these, eight (42 per cent) were responded to within 30 days and 17 (90 per cent) within 60 days. The reason timeframes were not met for the complaints reviewed was not clear from the available records. The ABC advised that delays often arose due to the complexity of matters being investigated, and a small team with fixed resources managing sharp increases in complaints and other audience contacts (for example, where a broadcast generates significant controversy).

3.38 Of the 15 editorial complaints reviewed that were referred to content areas for a direct response, the 30 day target was met for four and a further three were assessed by the ABC as not requiring a response. Timeliness could not be verified for the remaining eight complaints (53 per cent) as the content areas were unable to locate records of the responses. While A&CA recorded the timeliness of responses to complaints it managed, it did not keep records on the timeliness of the content areas’ responses to complaints. The ABC would be better positioned to manage complaint response timeliness if it had oversight of the responses sent by content areas, particularly responses to editorial complaints.

Does the ABC effectively monitor the allocation and progress of complaint investigations and responses?

A&CA effectively monitors the allocation and progress of the complaints it investigates. As the ABC does not have central oversight of the less significant but higher volume complaints managed by ABC content areas, it is not in a position to monitor these complaints.

3.39 Complaints allocated to A&CA investigators appear in their Resolve ‘home page’ in chronological order showing the oldest first and the number of days that the complaint has been active in the system. This allows the investigator to see which complaints require action sooner, including those over 30 days which Resolve ‘red flags’ as a visual cue. Investigators are required to independently monitor and manage their workloads and the Manager, Investigations, is responsible for monitoring and adjusting the overall workload to ensure appropriate distribution across the team.

3.40 A&CA managers monitor the allocation and progress of investigations using Resolve weekly workflow reports and daily supervision of each team member’s current workload. Managers can also refer to the Resolve ‘Staff Load’ tab which includes a chart and table showing the number and type of cases currently allocated to Resolve users (mainly A&CA staff). Further support for timely responses came from automated Resolve email reminders where open complaints passed 30 and 50 day milestones, as well as investigators tracking information received from content areas.

3.41 As such, A&CA has a structured process in place to monitor complaints using Resolve. It effectively monitors the allocation and progress of editorial complaints it investigated, as well as non-editorial complaints retained within A&CA’s Audience Liaison team for handling.

3.42 Content area responses are not recorded in Resolve. For example, the six content areas reviewed used the ABC’s email system to action complaints and methods varied for storage of complaints records and tracking. The content areas advised they had implemented a process that suited their specific requirements and available resources and had informal practices for checking that all complainants requiring a response had been sent one.

3.43 There was no systematic approach to monitoring and overseeing all complaints received, including editorial complaints that may contribute to improving the quality of content. The lack of visibility for monitoring editorial complaints referred by A&CA to content areas was also identified as an issue in two ABC internal audit reports completed in 2014 and 2017.38 Both audits identified a lack of visibility for monitoring editorial complaints that were referred by A&CA for direct handling by content areas. The 2017 audit also found that information on complaints handled directly by content areas was held in different repositories across the ABC. The ANAO confirmed this by interviewing the six content areas which were part of the sample.

3.44 Having oversight of all complaints, including those managed by content areas, would provide the ABC with assurance that complaints are being managed effectively and may assist the ABC to identify improvements in the quality of its broadcasting content and services.

Recommendation no.1

3.45 The ABC ensures that it has visibility over content areas’ management of and response to complaints, in order to have assurance that their processes are effective. To support this the ABC should implement record-keeping requirements, including a baseline level of information that content areas are required to document regarding complaints and outcomes.

Entity response: Partially agreed.

3.46 The ABC’s approach to complaints management aims to apply the Corporation’s finite resources in a proportionate and targeted way, commensurate with the issues raised in complaints and the risks they pose.

3.47 Complaints which are assessed as higher risk are centrally recorded, closely managed and an independent conclusion made about the merits of the complaint. The ABC welcomes the ANAO’s finding that there is clear visibility over complaints handled centrally, providing assurance that processes for handling more significant complaints are effective and well managed.

3.48 Complaints which are assessed as low risk may be handled in a decentralised manner, in most cases by the teams closest to the matter being raised. This decentralised handling places a lower administrative burden on teams and comes at a lower cost to taxpayers. It allows content teams to concentrate their time and resources on producing outstanding content for audiences.

3.49 The ANAO found that record-keeping for complaints handled directly by content teams was inconsistent. Information was not always readily available to document non-editorial complaints received directly by content teams or demonstrate how every complaint had been handled. The ANAO’s recommendation seeks to address this observation.

3.50 A small number of the low risk complaints referred to content teams for direct handling are minor editorial complaints. As these complaints relate to the ABC’s compliance with its editorial standards, there is a marginally greater risk to the ABC if these complaints are not handled effectively. The ABC agrees that there is room for improvement in the management of these complaints. Accordingly, with the assistance of Audience and Consumer Affairs, content team directors will be required to:

  • contact each content area that has received minor editorial complaints for direct handling from Audience and Consumer Affairs over the last six months;
  • remind these teams of the need to have a method to keep track of responses sent; and
  • provide Audience and Consumer Affairs with information about the methods used, to enable future review.

3.51 The ABC considers that this action strikes an appropriate balance between tracking these minor editorial complaints that pose minimal risk to the ABC, and the operational impact of achieving visibility over every complaint received and handled by content teams.

Is confidentiality of complainant data maintained?

The ABC maintains the confidentiality of complainant data. It has a suitable approach in place for collecting, storing, and sharing complaint information and only those staff requiring access to complaints can view complainants’ details. Complainant details are not included in public or internal reports on complaints.

3.52 Complainants are required to submit minimal personal details to the ABC when making a complaint through the webform. The ABC collects the complainant’s first and last names, email address, and state/territory. Postal addresses are kept for the small proportion of complaints received by hardcopy letter. It is possible for complaints to be lodged using an abbreviated or false name, however, in order to receive a response by the ABC the complainant must enter a valid email address. Anonymous complaints can also be lodged.

3.53 Complainant details are retained in Resolve and not readily accessible to wider ABC staff. Only 21 ABC staff, including 11 A&CA team members, have access to Resolve and can view the database contents. Outside A&CA, four of the six content areas reviewed by the ANAO kept a record or log of complaints they received. Such details are stored on a local file or email system and are not easily accessible by staff outside that content area.

3.54 No complainant identifiers are included in either the ABC’s public or internal reports on complaints.

4. Reporting and analysis of complaints

Areas examined

This chapter examines the effectiveness of the Australian Broadcasting Corporation’s (ABC’s) complaints reporting and analysis and whether the ABC regularly reviews the complaints management process.

Conclusion

The ABC analyses and reports complaints to internal and external stakeholders. The external information that the ABC publishes on complaints assists in maintaining its transparency and accountability as a public broadcaster. The ABC provides analysis of complaints data to relevant decision-makers to inform continuous improvement of its programs and services.

Do the ABC’s responses address complaints and does it monitor implementation of complaint outcomes/remedies?

39Audience and Consumer Affairs’ (A&CA’s) responses to written complaints are clear and address the issues raised by complainants. A&CA monitors the implementation of remedial action required to address a complaint. As there is limited visibility of complaints managed by content areas, it is unclear whether content areas’ responses effectively address the complaint.

4.1 The ABC provided a response to the 55 complaints directly managed by A&CA in the ANAO’s sample. The responses included a rationale where appropriate and all were easy to understand. For the five upheld and resolved complaints in the sample, the ABC’s responses directly addressed the complaint and the information recorded in Resolve was the same as the information published on the ABC website. The ABC website reports the action taken to remedy a complaint. As previously discussed, responses to complaints managed by content areas are not recorded in Resolve. It is unclear whether the content areas’ responses to complaints effectively address the complaint.

4.2 Where A&CA determines that a complaint should be upheld or partly upheld, it may recommend a remedy which the content area is responsible for actioning. When a complaint is determined by A&CA to be resolved, the content area must have taken adequate and appropriate action to address or remedy the complaint. The content area must advise A&CA that this has been completed before a response is sent to the complainant and the complaint is marked as ‘finalised’ in Resolve.

4.3 Part of the Editorial Policy Advisor’s role is undertaking internal quality assurance for editorial complaints investigated by A&CA. Editorial Policy Advisors assist A&CA in those complaint investigations where required and endorse A&CA’s final response when a complaint is found to be upheld, partly upheld or resolved. The Editorial Policy Advisors also monitor the implementation of complaint remedies within the content areas.

4.4 Under the Broadcasting Services Act 1992, where a person has made a complaint that the ABC has breached its Code of Practice, the complainant can take their complaint to the Australian Communications and Media Authority (the ACMA) if, after 60 days, the ABC fails to respond to the complaint or the complainant considers the ABC’s response inadequate. This applies only to content broadcast by television or radio.40

4.5 The Broadcasting Services Act also requires the ABC to formally respond to an ACMA investigation which finds that a breach of the ABC Code of Practice has occurred and the ACMA recommends that action be taken.41 If action is not taken by the ABC, then the ACMA may report this to the Minister for Communications. To date this has not occurred.

4.6 In 2016–17, the ACMA investigated 14 cases relating to the ABC and in 12 cases found that no breach of the ABC Code of Practice had occurred.42 The ACMA found that in two cases there was a breach relating to compliance with television captioning requirements. The ACMA was satisfied with the ABC’s advice about the remedial action that was taken.

4.7 Complainants can also seek a review of a complaint decision made by the ABC through the Commonwealth Ombudsman. This does not occur often. In 2016–17 there were two cases submitted to the Ombudsman—one that was not upheld and the other was still open for investigation at the time of writing.

Does the ABC regularly report on complaints received and the outcomes?

The ABC regularly produces a range of internal reports on complaints which are tailored to target groups such as the ABC Board or ABC staff. The ABC also publishes complaints information on its website.

4.8 The ABC prepares nine key internal complaints reports, as set out in Table 4.1.

Table 4.1: ABC complaints—internal reporting

Audience

Frequency

Content related to complaints

ABC Board

Bi-monthly

The ‘Editorial Director’s Report’ is tabled at ABC Board meetings and includes a section on complaints covering volumes, timeliness, analysis of notable issues and any ACMA activity.

Managing Director

Weekly

‘Complaints – Hot Issues’ is an informal weekly email from the Head of A&CA outlining key complaints and matters A&CA managed in the previous week. Recent reports include trending complaints.

Senior management in Editorial Policies, News and Television divisions

Weekly

‘A&CA Audience Contact Highlights’ is emailed to key management and covers trending complaints.

Editorial Policy Advisors: Radio, News and Television divisions

Monthly

Tailored reports are emailed to each Editorial Policy Advisor outlining audience contacts and complaints relevant to their allocated division as well as outcomes. The Radio report also includes trend analysis.

A&CA managers, Editorial Policy Advisors, Commercial, and Audience division representative

Monthly

The emailed ‘Audience Contact Summary’ contains high level statistics on numbers of complaints and discussion of programs and services that received the most complaints or appreciative comments.

All ABC staff

Daily

The ‘Audience contact database’ is updated daily on the ABC’s intranet. The searchable database contains all feedback received by A&CA. It includes summary descriptors such as of the issue and program, as well as current status.

Various staff

Daily

The emailed ‘Switchboard report’ shows calls logged by switchboard operators between 6pm–8pm weekdays, categorised by type of contact, with a brief summary of the issue.

     

Source: ANAO analysis of ABC’s internal published reports.

4.9 The internal reports are a combination of system-generated data for complaint statistics, manual analysis, and compilations of information for the qualitative aspects of the reports. A&CA extracts data from Resolve to generate the complaint statistics for a specific period. The more significant reports, such as the Editorial Director’s Report, are checked and endorsed by the Head of A&CA.

4.10 Overall, the reports provide useful information on complaint numbers, an overview of key issues or trends occurring during the reporting period, and information on investigation outcomes for upheld or resolved complaints.

4.11 In terms of external reporting to the public, there is no requirement under the ABC Act or the Broadcasting Services Act for the ABC to report on complaints. However, the ABC publishes regular external reports on complaints on its website and these are outlined in Table 4.2.

Table 4.2: ABC complaints—external reporting

Report

Frequency

Purpose

ABC Annual Report

Yearly

The ABC reports on complaints and other audience contact submitted through A&CA, including annual statistics, a breakdown of the subject matter of contacts received, analysis of timeliness of responses, and complaint outcomes. The annual report also includes data showing performance against the 60 day timeliness target.

Report on Audience Comments and Complaints

Quarterly

This webpage provides a statistical overview of complaints received over the past 11 years and links to all quarterly reports published since 2002.

Upheld complaints

Monthly

All actions or outcomes resulting from an upheld complaint are published on the ABC website.

Resolved complaints

Monthly

All actions or outcomes resulting from a resolved complaint are published on the ABC website.

Corrections and Clarification

Monthly

Corrections and clarifications made by the ABC to television, radio or digital content, as a result of a complaint or any other reason, are published on the ABC website.

Current Topics

As required

The Current Topics webpage contains responses to the questions and concerns that are being frequently raised at any one time. The Current Topics page aims to deter people from submitting a complaint on a topic that has already been addressed.

     

Note: The Upheld, Resolved, Corrections and Clarification and Current Topics webpages are not formal reports and do not contain data but publish remedies in response to complaints.

The outcomes of complaints which are determined be resolved or upheld are published on the ABC website. Although these are not reports in the usual sense, they do provide information on the actions the ABC has taken to address complaints.

Source: ANAO analysis of ABC’s published reports on the ABC website.

4.12 The ANAO reviewed the accuracy of the two formal external complaints reports—the ABC Annual Report and the quarterly Report on Audience Comments and Complaints. The data contained in both reports was accurate. The resolved or upheld complaints information reported publicly was consistent with records in Resolve.

4.13 Content areas can request that accuracy issues be published on the Corrections and Clarifications webpage, including editorial policy breaches or issues with broadcast or digital content that occur outside of the complaints process. In 2016–17, 41 corrections and clarifications were published and around 80 per cent were the result of an investigated complaint that was found by A&CA to be upheld or resolved. The remainder were the result of another reason, such as legal proceedings or an internal editorial review.

4.14 Overall, the ABC’s complaints reporting assists in upholding its editorial standards and ensures that its obligations to be accountable and provide high quality content and services are supported by effective and transparent reporting.

Does the ABC analyse complaints to inform continuous improvement of its broadcasting services?

The ABC analyses the complaints held in its central complaints database, and publishes this analysis through various internal and external complaints reports. The analysis is distributed to the appropriate areas and decision-makers within the ABC for consideration in the context of improving content and services.

4.15 Better practice principles for complaints handling (see Appendix 3) state that complaints should be analysed and reported in order to identify trends or systemic issues, and areas for improvement.

4.16 The various internal and external ABC complaints reports contain some form of analysis, whether in a ‘snapshot’ or summary form, or a more comprehensive discussion of trends on upheld and resolved complaint outcomes. A range of formal and informal settings within the ABC allow management and staff to review complaints reports and undertake analysis to inform improvements to its broadcasting services.

4.17 There are two key forums where written complaints are discussed and analysed—the monthly Editorial Policy Group and the weekly Editorial Policy Team meetings, both of which comprise senior staff. The primary focus of these meetings is to discuss the editorial policies, how they have been interpreted, whether additional guidance is needed for content areas, and what types of complaints have been occurring and why.

4.18 The content areas interviewed as part of the audit advised that they also discussed complaints on an informal basis, particularly when there was a trend or a contentious program had recently aired. The content areas also advised that where they create controversial programs they may discuss the program content with the relevant Editorial Policy Advisor prior to it airing to ensure that they are not breaching editorial standards.

4.19 Regular monthly reports are provided by A&CA to each Editorial Policy Advisor in a format specific to their requirements to assist in ensuring they are aware of trends and issues occurring in their divisions.

4.20 The ABC’s recording, reporting and analysis of non-editorial complaints may also inform improvements to its content and services. For example, in 2016–17 the ABC received 1673 complaints about the refresh of ABC News, primarily in relation to the legibility of a new graphical interface. As a result changes were made to improve visibility of the text and graphics.43

4.21 Complaints may also provide input into Editorial Reviews, which examine the ABC’s performance against its editorial standards. The ABC Board determines which topics to review and the reviews are undertaken by the Editorial Policy Advisors and the Editorial Director.

Does the ABC review or evaluate the effectiveness of its complaint process?

The ABC’s last major review of its complaints management process was in 2009.

4.22 The ABC has made changes to its Complaint Handling Procedures over time. The last significant review of it complaints management was in September 2009, when the ABC undertook a Self-Regulation Framework Review which examined:

  • how the ABC sets its editorial standards;
  • training for staff in interpreting and applying the standards;
  • complaints management and other audience contacts;
  • reporting on complaints and audience responses; and
  • analysing the results to inform continuous improvement of the editorial standards, training and content development.44

4.23 Overall, the review found that ‘the ABC’s self-regulation framework needs renovation, not replacement. It has weaknesses, excess layers and stresses, but it also has strengths.’ The review led to a more decentralised complaints management system, with new complaints handling procedures and revised Editorial Policies released in 2011.

4.24 A key finding of the review was that ‘written complaints should continue to be referred to A&CA. A&CA should be enabled to refer less serious matters back to local managers and program handling teams [content areas] for handling, with appropriate oversight and a clear option for the audience member to revert to A&CA’. As discussed throughout this report, there is no central oversight and without this in place, the ABC has limited assurance that complaints are being managed effectively by content areas. The ANAO has made a recommendation that the ABC ensures it has visibility of how content areas manage complaints (see paragraph 3.48).

4.25 The review also noted that ‘A striking feature of the contemporary media environment is the speed of change. For this reason the ABC should again openly review its self-regulation framework no later than 2012’. To date, a subsequent review has not occurred.

Appendices

Appendix 1 Entity response

Appendix 1: ABC responseANAO response:

In its response to the ANAO’s proposed report, the ABC has expressed some concerns with the way the audit proceeded. Throughout the audit, the ANAO followed all standard ANAO processes and regularly updated the ABC regarding the progress of the audit and our findings and conclusions. Following issue of the proposed report, the ANAO had several discussions with the ABC on the audit findings and the recommendation, providing the ABC with ample opportunity to comment.

Appendix 2 Functions of the ABC

Section 6(1) of the Australian Broadcasting Corporation Act 1983 sets out the ABC’s functions.

(1) The functions of the Corporation are:

(a) to provide within Australia innovative and comprehensive broadcasting services of a high standard as part of the Australian broadcasting system consisting of national, commercial and community sectors and, without limiting the generality of the foregoing, to provide:

(i) broadcasting programs that contribute to a sense of national identity and inform and entertain, and reflect the cultural diversity of, the Australian community; and

(ii) broadcasting programs of an educational nature;

(b) to transmit to countries outside Australia broadcasting programs of news, current affairs, entertainment and cultural enrichment that will:

(i) encourage awareness of Australia and an international understanding of Australian attitudes on world affairs; and

(ii) enable Australian citizens living or travelling outside Australia to obtain information about Australian affairs and Australian attitudes on world affairs; and

(ba) to provide digital media services; and

(c) to encourage and promote the musical, dramatic and other performing arts in Australia.

Appendix 3 Better Practice for Complaints Handling

In 2009, the Commonwealth Ombudsman published the revised Better Practice Guide to Complaint Handling, which outlines five elements of effective complaint handling, as described in Table A.1.

Table A.1: Five elements of effective complaint handling

Element

Description

1. Culture

Agencies must value complaints as a means of strengthening their administration and improving their relations with the public. Agency culture recognises the value of complaints and requires all staff to be committed to effective complaint resolution.

2. Principles

A complaint handling system must be modelled on fairness, accessibility, responsiveness, efficiency and integration.

3. People

Skilled personnel are essential for effective complaint handling so agencies should have: sound recruitment practices; ongoing training opportunities; and provide effective performance reviews and feedback.

4. Process

Processes are documented clearly and are easy to understand and apply.

5. Analysis

Complaints data is regularly analysed to identify key issues and areas for improvement. The system should be able to generate regular and ad hoc reports. Agencies should report publically on their performance against both quantitative and qualitative complaint handling measures and the complaint system should be regularly reviewed to assess its ongoing effectiveness.

   

Source: Commonwealth Ombudsman’s Better Practice Guide to Complaint Handling, 1 April 2009.

The Australia/New Zealand Standard, Guidelines for complaint management in organizations (AS/NZS 10002:2014) was published in October 2014. The Standard’s guiding principles for complaints management are summarised in Table A.2.

Table A.2: Guiding principles for complaint management in organisations

AS/NZS 10002:2014 Summary of guiding principles

Enabling complaints

  • Focus on people
  • No detriment to complainant
  • Visibility and transparency
  • No charges (fees)

Managing the parties

  • Behaviour of parties
  • Work health and safety
  • Complaints involving multiple parties
  • Empowerment of staff

Managing complaints

  • Responsiveness
  • Objectivity and fairness
  • Equity
  • Privacy and disclosure
  • Communication

Accountability, learning and prevention

  • Accountability
  • Continuous hhh improvement
  • Prevention of ongoing disputes
   

Source: AS/NZS 10002:2014.

Footnotes

1Australian Broadcasting Corporation Act 1983, Charter of the Corporation, s.6(1). The relevant section of the legislation has been reproduced in Appendix 2.

2 Australian Broadcasting Corporation, Editorial Policies, available from <https://edpols.abc.net.au/policies/> [accessed 4 December 2017].

3Australian Broadcasting Corporation Act 1983, s.8(1).

4 Australian Broadcasting Corporation, Code of Practice 2016, available from <http://about.abc.net.au/reports-publications/code-of-practice/>, [accessed 9 October 2017].

5 ‘Spectrum’ means the range of frequencies within which radiocommunications are capable of being made.

6 The ABC receives income from other sources such as its commercial activities, for example the ABC Shop.

7 A corporate Commonwealth entity is a Commonwealth entity that is a body corporate.

8 These contacts were received through the ABC’s Audience and Consumer Affairs unit.

9 Of the 5523 management issues, one related to the ABC’s editorial standards.

10 The ABC aims to ensure that a proportionate level of time and resources are applied to dealing with audience complaints, depending on the nature and seriousness of each complaint (see Chapter 3, paragraph 3.3).

11 In 2016–17 the ABC received approximately 1 820 anonymous complaints; almost six per cent of total complaints.

12 Australian Broadcasting Corporation, Editorial Guidance Note: Complaints Handling 2017, available from <https://edpols.abc.net.au/guidance/complaints-handling/>, [accessed 8 January 2018].

13 The complaint does not need to specifically reference the ABC Editorial Policies or Code of Practice or use the language of those standards to be considered an editorial complaint.

14 The ABC can also take remedial or corrective action in response to any complaint.

15 Australian Broadcasting Corporation, Lodge a Complaint webform, available from <http://www.abc.net.au/contact/complain.htm>, [accessed 11 January 2018].

16 Sixty-three per cent of investigated complaints lodged with A&CA in 2016–17 were finalised within 30 days and 99 per cent were finalised within 60 days.

17 Australian Broadcasting Corporation, Current Topics webpage, available from <http://about.abc.net.au/topics/>, [accessed 11 January 2018].

18 Proportionality is discussed in Chapter 3 (paragraph 3.3).

19 The sample is discussed in more detail in Chapter 3.

20 Written complaints received directly by content areas are not entered into Resolve (noting that only a small number of content areas have access to Resolve) unless the matter is potentially editorial in nature and the content area sends the complaint to A&CA.

21 The ABC’s proportionality criteria are: seriousness of the matter; likelihood of harm; potential to mislead; proximity of person raising the matter to the substance of the matter; scale of audience response; and the degree of risk of damage to public trust and confidence in the ABC.

22 Two of the six reviewed content areas could not locate their response to the specific complaint in the ANAO’s sample but were able to show the ANAO where they usually stored complaints and examples of responses to other complaints.

23 Content areas are not required to record how a complaint was received. As a result, the ANAO could not verify that this practice occurred.

24 Australian Broadcasting Corporation, Editorial Guidance Note—Moderating User Generated Content, available from <https://edpols.abc.net.au/guidance/moderating-user-generated-content/>, [accessed 23 January 2018].

Australian Broadcasting Corporation, Editorial Guidance Note—Operating Official ABC Social Media Accounts, available from <https://edpols.abc.net.au/guidance/operating-official-abc-social-media-accounts/>, [accessed 23 January 2018].

25 Appendix 1 provides an overview of better practice in complaints handling.

26Editorial Guidance Note – Complaints Handling outlines expectations about the details that content areas should consider recording.

27 Australian Broadcasting Corporation, Editorial Guidance Note—Complaints Handling, available from <https://edpols.abc.net.au/guidance/complaints-handling/>, [accessed 8 January 2018].

28 In March 2018 the ABC advised that the two better practice guides had been removed from the ABC intranet.

29 A&CA records information such as the program/service and subject of the complaint.

30 Non-editorial complaints received by content areas directly from the public are retained and managed locally rather than being forwarded to A&CA for assessment. Therefore, they are not included in the Resolve database.

31 ABC Internal Audit of Complaints Management, June 2014; and ABC Internal Audit of Editorial Complaints Management Final Report, May 2017. At the time of the 2014 audit a capital project for a replacement database [Resolve] for complaints management was in progress. As a result, the report did not include any recommendations on this issue.

32 Automated reminders were also sent for complaints still open at 50 days.

33 Content areas are requested to provide A&CA with comment on complaints usually within seven days.

34 Australian Broadcasting Corporation, Editorial Guidance Note: Complaints Handling 2017, available from <https://edpols.abc.net.au/guidance/complaints-handling/>, [accessed 8 January 2018].

35 See paragraph 3.32 for examples.

36 The ABC’s guidance encourages content areas to use their judgement in deciding whether a complaint merits a response. The ANAO agreed with the content areas’ assessment that these particular complaints were minor.

37 In 2016–17 A&CA allocated 12 764 complaints to content areas—11 487 non-editorial (37 per cent of total complaints) and 1277 minor editorial (four per cent of total complaints).

38 ABC Internal Audit of Complaints Management, June 2014, and ABC Internal Audit Editorial Complaints Management Final Report, May 2017.

39 As discussed at paragraph 1.22 this audit did not review the nature of complaints but rather the process followed to manage complaints.

40Broadcasting Services Act 1992, s.150(1).

41Broadcasting Services Act 1992, s.153.

42 Australian Communications and Media Authority, Annual Report 2016–17, p. 172.

43 Australian Broadcasting Corporation, Investing in Audiences Annual Report 2016–17, p. 59, available from <http://about.abc.net.au/reports-publications/2016-17-annual-report/>, accessed 23 November 2017.

44 Australian Broadcasting Corporation, Review of the ABC’s Self-Regulation Framework, September 2009, available from <http://about.abc.net.au/wp-content/uploads/2012/06/ReviewOfABCSelfRegulationFrameworkOct2009.pdf> [accessed 9 November 2017].