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 GCS GLOBAL  HEADQUARTERS

3A Lakeside Geneva Building

2nd Floor Versoix, CH-1290

Geneva, Switzerland

geneva@gcs-iso.com

+41 225 961 418

OPERATIONAL CENTER

101 Eisenhower Pkway,
Suite 300, Roseland, New Jersey, 07068, United States of America

usa@gcs-iso.com

(1) 973 795-1241

© 2019 by Global Compliance Service LLC

GCS COMPLAINT & APPEAL PROCEDURE

1. Purpose

The purpose of this procedure is to describe handling of incident, complaint and appeals received from the client, in house and from other parties.

2. Scope

This procedure covers all complaint and appeal received at Organization by any means, like written, verbal, e–mail etc. It also includes adverse findings during audits.

Responsibility

The Quality Manager is responsible for receiving the complaint and appeal from the clients / other parties. They in consultation with the office staff and auditors are responsible for handling, validating and analysis of the complaint and appeal to the satisfaction of the clients / other parties

For the purposes of this document “Quality System Incidents” are defined as complaints, suggestions, observations and opportunities for improvement. Quality System Incident data is entered into the Corrective Action System for proper treatment (QP-04). This procedure describes the methodology by which Global Compliance Service collects and processes incident reports; and communicates the impact to staff members.

 

Global Compliance Service recognizes that incidents occur in daily operation that collectively have an impact on the Quality Management System. In order to properly analyze and address system issues a consistent and thorough process for collection of information is vital.   

 

Complaints

Complaints are incidents of grievance or dissatsifaction with Global Compliance Service. service.  Complaints may be:

  • internal in nature - raised by a Global Compliance Service staff member with regard to internal service, operations or employee performance

  • external in nature- raised by Global Compliance Service clients, suppliers or other affiliated organizations

  • written

  • verbal

  • complaints raised by client’s customers or stake holders

 

Global Compliance Service recognizes that positive feedback is as important as negative feedback. Suggestions are vital in identifying risk and system improvement. As with complaints, suggestions may be internal or external in nature, written or verbal.

 

1. Appeals

Global Compliance Service recognizes that the client may have some reservations    or may not agree with the conduct of auditor, audit findings, certification committee decision and / or overall interaction with Global Compliance Service staff. Client is         free to communicate the same to Global Compliance Service Appeal subcommittee and this is treated as an appeal from the client.

 

2. Observations

Observations are witnessed incidents of service/operational deficiency, malfunction and or failure. Observations are often made by individuals independent of the activity witnessed and therefore objective in nature . Observations also play important role in identification of risk and system improvement

 

3. Opportunities for Improvement

Opportunites for Improvement are incidents where the system has not failed, yet greater operational efficiency may be obtained in analyzing current practice.  Opportunites for Improvement are often collected internally, but input from external sources is also beneficial

Receipt of Incidents

The quality incident may be reported by any means – verbal or written. In case of an external source, the incident report may be received by any staff member. The staff member shall fill the Incident report recording all the information and details of the complaint. The filled report shall be submitted to Quality Manager for further action. In case of internal source, the incident report shall be filled by the staff member and submit to Quality Manager.

The Quality Manager shall contact (telephone, email, letter) the external source to acknowledge the receipt of information within 5 working days of receipt. He shall understand the issue in details from the source (to avoid any error in writing the report). He may decide to personally meet the initiator, depending on the gravity and seriousness of issue.

In case of Complaints and Observations, it may be against Global Compliance Service (a system / procedure or a person) or a Global Compliance Service certified companies (client). In case of suggestion / opportunity for improvement, it is for Global Compliance Service to study the suggestion and decide.

 

All such incidents received by any means or by any one is first of all recorded in the Incident report with the details of;

  • Complaint and appeal sr. No.

  • Mode of receipt,

  • Received by,

  • Name of client / other parties,

  • Description of complaint and appeal,

  • Reference of services against, which complaint and appeal is raised along with the reference, date and other details, Client / other parties’ complaint and appeal incident report are issued to the Quality Manager for analysing the root cause.

  • Quality manager validates the complaint after checking necessary back–up records or personal interview of auditor’s / staff members (who were involved in to job).

Handling of Client Complaint and Observation

In case of a complaint / observation against Global Compliance Service, Quality manager analyses the issue to determine if there is system error or person error. He shall determine the root cause and determine correction, corrective action. The possible complaints are –

  • Administration - problems with appointments, certification files, certificates issued or issued late,

  • Auditor / subcontractor problems with incomplete audit or surveillance documentation

  • Agents – problems with general compliance with Global Compliance Service administration or audit procedures

 

The correction is effected immediately to satisfy the complainant. This may include training / counseling the person involved. The CAPA is discussed with management during next Management Review. Appropriate action is taken based on discussions (change in procedure / formats, training to all personnel etc). An email is sent out to all staff detailing the issue and remedial action (for information). A copy of the complaint and investigation details is maintained in the respective individual’s personnel file for reference at the performance appraisals.

 

In case of a complaint / observation against a certified client, the Quality Manager studies the complaint and discusses with the auditor (last audit). If the complaint is found genuine and valid i.e. indicates a system failure, the complaint is sent to the client for a response. No confidential reports or information will be sent to complainants without written permission from the client. Adequate time is given to the client for response. If required, Quality Manager follows up with the client for the response. Depending on the response, Quality manager may decide to –

  • Write to the complainant about the response and asks for his response.

  • Ask further clarification from the client

  • Depute an auditor to personally visit the client and investigate for system failure. Such visit shall be considered as special visit and charged to client.

  • Request a joint meeting with client, complainant and Global Compliance Service

The Quality manager shall communicate with the complainant at the end of the process detailing the findings and to formally close the complaint. A copy of the correspondence is kept in the client file for records and the same is passed to auditor during next audit. The details of all complaints and action taken (Correction, CAPA) are discussed in Management Review and IC meeting.

 

Handling of Appeals

Any company or organisation who fails to satisfy an audit or surveillance may appeal   against the decision. Where an appeal is received the following procedure will be followed.

  1. The MD will appoint the members of the appeals committee under the leadership of MD who will hear the appeal and determine the outcome. In case, MD are part of the audit/ certification team, MD shall decide the investigating officer for the appeals process. In such a scenario MD shall approach Impartiality Committee and/or Global Compliance Service team to provide decision on the appeal. The decision on the appeal shall be taken based on the decision by Global Compliance Service committee and the Impartiality committee. Results of the appeal will be reported to the board of directors.

  • All appeals shall be received by the Technical Manager and details of appeals shall be recorded in the Appeals Register maintained by the Technical Manager.

  • Technical Manager shall investigate the appeal made and inform the client about its plan of action for investigation and action there upon.

  • An investigation report (Incident Report) for each individual appeal shall be maintained by the Technical Manager. In case, any further corrective action is required post actions identified and taken based on Incident report – Corrective action procedure QP04 is implemented.

  • A copy of the investigation report shall be sent to the client.

  • In case of any further ambiguity, the same shall be reviewed by the board of directors and appropriate decision arrived at.

  • In case the issue still remains open; the same shall be intimated to the accreditation board for its valuable comments.

  • All appeals made are collated and analyzed on a yearly basis.

  • Necessary corrective actions shall be taken based on the appeal trend.

  • Appeal trends and corrective action taken shall also be reviewed as part of the Management committee meeting and Impartiality committee meeting.

  • Technical Manager shall ensure that details with respect to the appellant and actions there upon is not shared with the audit team members.

  • Technical Manager shall ensure that no discriminatory action is taken against the appellant.

  • The client is made aware of the appeals process and is available to him on request.

    1.      In case of an appeal made by a client against a decision made by auditor, Lead auditor or certification committee, the appeal shall be recorded by Quality Manager and forwarded to Appeal Subcommittee. Appeal subcommittee shall review the appeal, investigate (which may include discussion with concerned client, respective auditor / lead auditor and review of audit report). Appeal subcommittee may also direct any other lead auditor to visit the site and determine the validity of the appeal. The decision taken by Appeal subcommittee shall be communicated to the client and to Quality Manager for necessary action. The case is also discussed during the next MRM and Impartiality Committee meeting. In special cases, the case may be discussed with Impartiality Committee members on one-to-one basis.

  •         Handling of Suggestions /Opportunity for improvement

  • In case of suggestion / opportunity for improvement, the source is predominantly internal and the concerned staff member fills the incident report and submits to Quality Manager. The other source may be internal / external audit. 

  • Quality Manager studies the suggestion to determine any conflict with ISO17021, Global Compliance Service Global policy and Global Compliance Service Policy. In case the suggestion is in conflict, the same is communicated to the initiator. However, the suggestion is also discussed in Management review. In case the suggestion is found not in conflict, the suggestion is studied for benefits and the impact on other processes.

  • The suggestion is accepted if found beneficial and does not adversely impact any other process. Quality Manager determines the changes in existing documentation and implements through Document Change process (QP-01).

  • If any certified client or interested party asks for the appeal/complaint handling process, then it is forwarded to Quality manager. He will inform a certified client /any other interested party the appeals and complaint handling process of Global Compliance Service if any complaints / appeals are received by certified clients / interested party

 

Closing of complaint and appeal

Depending on the nature of the non–conformity, the Quality Manager / Technical Manager may follow up with requests for corrective actions. When the investigation of client complaint and appeal determines that remote operation or other external organizations contributed to the complaint and appeal, the Technical Manager or his delegate contacts these organizations and provides them with all relevant information.

  1. Every client complaint and appeal is recorded. The records are maintained by the Quality Manager / Technical Manager. When there are copies of written communication, reports and other documents related to a complaint and appeal, these records are organized into a file and are identified with the complaint and appeal number and also having records of the corresponding corrective action. The records of investigations that concern product quality or other test characteristics are maintained by Technical Manager. Based on analysis of Client / Other Parties complaint and appeal, necessary actions are taken and client is replied for closing the complaint and appeal. Quality Manager identifies need for taking corrective action to prevent such complaint and appeal in future and accordingly concerned person is informed.

  2. All the complaint and appeal received by Organization will be closed within 7 working days after receipt of the complaint and appeal. Operation Manager / Technical Manager is authorised for closing of complaint and appeal.

All Complaints and appeals can be emailed to ms@gcs-iso.com for action, someone will contact you within 1 busines day to follow up on the appeal and/ or complaint