Quality Handbook Section 17E - Student Complaints Procedure

2.1 Principles of fairness are:

• setting out a clear process for how we manage student complaints;
• ensuring that the process is applied consistently to all students;
• ensuring that cases are reviewed without bias or the reasonable perception of bias;
• operating reasonable timescales and ensuring the process is completed without undue delay, and
• providing the opportunity for both the student and the University to be equally heard.

2.2 We will ensure that students with protected characteristics, as defined under the Equality Act 2010, are treated fairly and without discrimination.

2.3 If there are concerns regarding your wellbeing, any notifications and communications to you will be managed appropriately, such as through a personal conversation.

2.4 This Procedure is internal to the University and does not have the same degree of formality as a court of law. As such, legal representation is not considered to be necessary or appropriate in the circumstances.

2.5 We may transfer your complaint to another procedure if we feel that your concerns could be more appropriately addressed through a different University process. For example, complaints relating to University staff will be transferred to the Staff Disciplinary Policy and Procedure. If your complaint is transferred, we will inform you of this and direct you to relevant guidance and/or support.

2.6 We may not respond to each individual point raised in a complaint, but where appropriate points may be grouped together when providing a response.

2.7 If your concern has already been raised through a different University procedure, then you may not pursue it at the same time through the Complaints Procedure; equally, if you have raised a concern through the Complaints Procedure, then you may not pursue it at the same time through other procedures.

2.8 If a complaint is settled at any stage of the process, i.e., compensation is offered and accepted, you cannot then escalate your complaint to a later stage in the process.

2.9 Freedom of speech and expression is at the heart of what universities are for, where the freedom to express ideas and debate opinions within the law is a fundamental principle. The application of this procedure will therefore be undertaken in accordance with this principle. More information on the University’s approach to Freedom of Speech and Academic Freedom can be found in its Code of Practice.

2.10 The existence of this procedure does not stop you from discussing any issues or concerns about your studies informally with your School. Staff in your School or the relevant Professional Service can be the first point of contact for you to discuss any concerns that you may have.

3.1 You can seek independent advice from the Student’s Union Information and Advice Service.

3.2 Your School and/or Academic Registry can provide you with advice and guidance on using this Procedure.

3.3 If you are under 18 years of age and you raise a complaint, Academic Registry will notify your parent/guardian that you have submitted a complaint and will keep them informed of progress, unless you ask us not to.

3.4 Throughout the complaints process, you may be accompanied to any meetings by a representative of the NTSU Information and Advice Centre, a friend or other supporter. You may be represented by that NTSU representative or friend upon agreement between you and us.

3.5 The role of any supporter is to provide support and advise you. You are expected to communicate and engage with the process yourself; there is no automatic right for the supporter to communicate on your behalf. We reserve the right not to engage with your supporter if, in the view of the Academic Registrar, they do not behave in an acceptable manner or respect the nature of the role.

3.6 NTU provides a number of support services. You are encouraged to engage with these services and take up any appropriate support available to you. You can:

• Find out what support is available from Student Services
• Speak with a support adviser
• Get support from the NTSU advice centre.

4.1 We encourage you to provide enough details to support your complaint. Scanned copies of original documents will be accepted; however, original hard copies can be requested at any time.

4.2 You may be asked to explain aspects of your complaint or to provide further information or evidence at any time to enable a full review. For example, relevant emails, as well as meeting notes can help us investigate your complaint more effectively.

4.3 It is expected that the supporting evidence is provided at time of submission. Where this is not possible, you must tell us the type of evidence you intend to submit and the reason why it cannot be submitted at the time. Additional evidence should be submitted within five working days of the submission.

4.4 Acceptance of submissions without evidence, or delayed evidence is at the discretion of the Academic Registrar (or nominee). You will be notified of the decision to accept the submission or otherwise. A lack of supporting evidence at the point of submission may lead to delays within the process or the submission being considered ineligible.

5.1 If you have an issue that needs resolving you can address this directly with the School or Department at the University in an informal manner via email or in person without the need to go through a Complaint Process. Please do allow a reasonable amount of time for those departments to look into and resolve the issue. Five working days for a response is reasonable in most cases.

5.2 For issues where you do want to raise a complaint, for example if you have not received a satisfactory response, you should follow the processes below.

5.3 You can make a complaint about an issue or event which happens while you are enrolled as a student at the University. You do not need to be still enrolled when you make your complaint provided the issue or event about which you wish to complain happened while you were an enrolled student.

5.4 We aim to deal with all complaints within the timeframes set out below:

Level 1: Early resolution at local level

• Student: Raise your complaint within 60 working days of the issue.
• Acknowledgement: Within 7 working days of receipt of the complaint.
• Outcome: Within 25 working days of receipt of the complaint.

Level 2: Formal stage

• Student: Raise your complaint within 10 working days of the date of the local resolution outcome.
• Acknowledgement: Within 7 working days of receipt of the complaint.
• Outcome: Within 35 working days of receipt of the complaint.

Complaint review

• Student: Request a review within 10 working days of the Formal stage outcome.
• Acknowledgement: Within 7 working days of receipt of the request for a review.
• Outcome: Within 20 working days of receipt of the request for review.

Office of Independent Adjudicator (OIA)

• Student: Request a review within 12 months of the date of the Completion of Procedures Letter.
• Acknowledgement: Not applicable
• Outcome: OIA timescales

5.5 Where it is not possible to manage a complaint within these timeframes, an alternative timescale will be provided.

5.6 Complaints submitted outside of the time limits are difficult to investigate, given the passage of time. Complaints submitted outside of those time limits will not be considered unless you can show good cause, i.e., that you have been prevented from submitting your complaint as a result of personal circumstances, and provide relevant evidence in support.  An example of such circumstances may be a serious illness, bereavement, or childbirth. A busy lifestyle will not be considered an exceptional circumstance.

5.7 You must state reasons for the delay when submitting the complaint and provide supporting evidence to extend the normal timeframes. For example, a doctor’s letter or birth certificates. The University reserves the right to accept or reject a complaint submitted out of time following consideration of any supporting evidence provided. In addition, the University is not obligated to investigate a complaint where some or all of the relevant records are no longer readily accessible to the University, given the lapse of time since the matter complained of took place.

5.8 We will send you a Completion of Procedures letter if we do not accept your complaint for being out of time. That letter will explain why your complaint has been submitted late by reference to the time limits prescribed in this procedure.

6.1 You should raise your concerns quickly and directly with your school or the relevant service area. If you are not sure where to raise your complaint or if you feel that you are unable to raise your complaint with your School or the service area concerned, please contact the Academic Registry for advice.

6.2 You must raise your complaint no later than 60 working days from the incident or cause for concern using the relevant form.

6.3 You should describe your concerns clearly and provide information and evidence where possible to support your claims.

6.4 Your complaint will be acknowledged within 7 working days. You will receive an outcome within 25 working days.

7.1 If you invoke the formal stage, you must submit a Complaint Form within 10 working days of the date of the local resolution outcome.

7.2 You should explain clearly on the Complaint Form why you believe that your complaint remains unresolved as this will help us to understand your complaint. We may ask you for further clarification or information, where necessary.

7.3 You should also describe the outcome you are seeking as a result of your complaint as this can be extremely helpful to us. However, you must recognise that our response may differ significantly from your desired outcome.

7.4 You should provide enough information to support your claims, and documentary evidence, where possible.

7.5 Your Formal stage complaint will be investigated by a Complaint Investigator in Academic Registry, which is a central University department independent of all Schools and service areas. The Complaint Investigator will:

• Decide whether your complaint is eligible and has been submitted within the time limit; and
• Consider whether the issues you have raised in your complaint should be investigated under this procedure or whether they would be more effectively addressed through another procedure.

Use of Artificial Intelligence in the Complaints Process

7.6 The Complaint Investigator may make use of artificial intelligence (“AI”) tools, including Microsoft 365 Copilot (“Copilot”), from time to time to support with the complaint investigation.

7.7  The University uses a range of tools to support its processes, including AI-enabled tools. However, all complaints investigations are conducted with appropriate care, diligence, and human oversight, and no decisions are made solely by automated means. Complaint Investigators will maintain an appropriate audit trail where AI tools are used, including retaining relevant prompts and outputs where they form part of the investigation process. Such records are stored in accordance with the University’s records management and retention policies.

7.8  The University recognises that AI tools may produce outputs that are incomplete, inaccurate or reflect unintended bias. Complaint investigators will take appropriate steps to identify and mitigate such risks. Complaint investigators will ensure that any use of AI tools complies with the University’s data protection and confidentiality obligations, including ensuring that only appropriate information is inputted into approved systems.

7.9 AI tools are intended to assist Complaint Investigators with administrative and analytical tasks only. They are not used as a substitute for professional judgement or decision-making. Complaint Investigators will independently review and verify all information, findings and conclusions, regardless of any AI-assisted outputs. Any outputs generated by AI tools will be critically assessed, against the underlying evidence, and, where necessary, supplemented or corrected by the Complaints Investigator.

7.10 Any drafts or materials generated with the assistance of AI tools will be clearly identified as draft or working documents until reviewed and finalised by the Complaint Investigator. AI-generated drafts do not constitute findings or conclusions unless and until they have been reviewed and formally adopted by the Complaint Investigator.

7.11 Your complaint will be acknowledged within 7 working days of receipt.

7.12 If your complaint is eligible, the Complaint Investigator will review it against the evidence you have provided, consulting other colleagues where appropriate. The Complaint Investigator may ask to meet with you to discuss your complaint. If you are unwilling to attend a meeting without a good reason, this and your reasons for not attending will be taken into account in the outcome of your complaint.

7.13 You may request to meet, either in person, by telephone or via online meeting, with the Complaint Investigator if you wish to discuss the details of your complaint in more detail. Such a request will not be unreasonably denied by the University.

7.14 You may be asked to explain the information or evidence you submitted with your Complaint Form or you may be asked for further information or evidence. You are expected to cooperate with reasonable requests, within the time limit set for a response.

7.15 Having fully reviewed the complaint, the Complaint Investigator will produce a decision letter, which will tell you about the process followed, the information gathered, the outcome and any recommendations made.

7.16 You will receive an outcome within 35 working days from receipt of your Complaint Form. If the review into your complaint will take longer, we will notify you of the reasons and provide you with an expected date of response. The outcome will provide enough detail for you to understand our response.

7.17 If your complaint is accepted in full, or in part, a proposed resolution will be offered to you.

7.18 If your complaint is not accepted, you will be provided with an explanation for the decision.

7.19 Other staff at the University may be informed of the complaint outcome where needed with due regard to confidentiality, as appropriate.

7.20 In very few, particularly complex cases, the Complaint Investigator may refer a Formal stage complaint to a Complaint Panel. The Complaint Investigator is responsible for deciding whether a complaint should be referred to a Complaint Panel.

7.21 Should a Complaint Panel be required, you will be informed of this decision in writing. See Appendix 3 for the Role of the Complaints Panel.

Support at the Complaints Panel

7.22 The purpose of a Complaint Panel is to allow you to explain your complaint and how you think it should be resolved, and to assist us in reaching a decision based on the available evidence and the representations you have made. Legal representation is not allowed at meetings taking place at any stage under this procedure.

7.23 You may bring a supporter to the panel meeting who may be either a Students’ Union representative, a fellow student or a parent/guardian. You must tell the Complaint Investigator who your chosen companion is, no later than 3 working days before the Panel meeting. (For the role of supporter, see 3.5).

Closing the formal stage

7.24 The outcome of the complaint will be sent to you in a letter via email, outlining the reasons for each decision and advising of the right to a Complaint Review.

7.25 If at this stage you are satisfied with the outcome and consider the complaint to be resolved, no further action is needed and the complaint is closed. You will not be entitled to request a Completion of Procedures letter on this basis.

8.1 The purpose of a Complaint Review is to consider whether the ground(s) relied on by you have merit. The Review will not consider new or previous issues of your complaint afresh, nor will it involve further investigation. It will consist of a review of the evidence submitted in relation to the permissible grounds.

8.2 Requests for a Complaint Review will only be granted on the following grounds:  

• There was a procedural irregularity by the University in the consideration of the complaint which has materially affected the outcome; or
• You have new evidence which could not have previously been made available, for valid reasons; or
• The outcome was not reasonable in the circumstances, in that the decision maker, taking into account the facts and circumstances of the case, could not have reasonably reached that decision; or
• Your complaint is about a partner institution in relation to quality of learning opportunities provided and you have exhausted the complaint procedures at the partner institution.

8.3 You should set out the grounds for the complaint review and your concerns clearly and succinctly using the Complaint Review form and provide evidence in support (where possible). You must explain how your request falls within one or more of the grounds set out above.

8.4 You must submit your Complaint Review request within 10 working days of the date shown on the formal stage outcome letter.

8.5 A member of Academic Registry with no prior involvement in the matter will review and decide whether your request for a Complaint Review is eligible to be considered and notify you within 7 working days of receiving the request.

8.6 If it is determined that the grounds are not met, you will be informed of the decision and we will send you a Completion of Procedures letter confirming the closure of your matter and university processes within 20 working days of the decision not to progress your matter to Complaint Review.

8.7 If we decide that your request meets one or more of the grounds for Complaint Review, we will allocate a Complaint Reviewer, not previously involved in levels one or two of the complaint process, to undertake the review. The Reviewer will consider all information collated for the complaint, together with any new evidence presented, but may contact you and anyone previously involved in the complaint as well as any new witnesses.

8.8 On completion of the review, the Reviewer will either agree the outcome made at the formal stage, or make a different finding which overturns the original outcome.  The decision taken at the Review stage is final.  You will receive an email of the outcome of the Complaint Review, including a Completion of Procedures Letter, normally within 20 working days from your Complaint Review request being accepted. This is the end of the University’s internal procedures.

8.9 If the deadlines cannot be met, we will contact you to explain the delay and set a new deadline for our response.

9.1 If we believe that your complaint is unreasonable, we reserve the right to terminate our review of your complaint. A complaint will be considered unreasonable if it is:

• Obsessive or repetitive;
• Insistent on pursuing non-meritorious complaints and/or unrealistic, unreasonable outcomes;
• Insistent on pursuing what may be meritorious complaints in an unreasonable manner;
• Designed to cause disruption or annoyance;
• Excessively long in length. A submission should be no more than 1000 words; and/or
• Demanding for redress which lacks any serious purpose or value.

9.2 Where a complaint is considered to be unreasonable, or where the conduct of you or a third party is considered to be unacceptable, the Executive Dean of the School or Head of Department (or nominated Deputy) will decide whether to terminate contact with the complainant. In exceptional circumstances, this may mean that consideration of the complaint is also terminated, in which case you will be issued with a Completion of Procedures letter.

9.3 Complaints relating to speech will be promptly rejected where these are vexatious, frivolous or obviously unmeritorious. It is accepted, however, that it may not always be possible to determine that a complaint is vexatious at the outset of an investigation. In order to avoid unnecessary intrusive investigations, a preliminary assessment/triage of the complaint will be undertaken to assess whether to commence an investigation. The starting point of any such investigation will be that lawful speech will not be punished solely because of their lawful expression of a viewpoint.

10.1 You must complete the University’s internal procedures before you can request an OIA review.

10.2 Your complaint must be submitted to the OIA within 12 months of the date of your Completion of Procedures Letter from the University and must be submitted using the OIA’s form. You must include your Completion of Procedures Letter with your submission.

10.3 Further information can be found on the OIA’s website at oiahe.org.uk.