1
Transport for London Complaints Handling Procedure
Complaints Handling Procedure:
Our commitment to putting things right
At Transport for London we are committed to providing a high-quality service to everyone
we come into contact with. We appreciate that sometimes we may not meet your
expectations, either through the planning or delivery of our activities. If so, we welcome your
feedback and want you to tell us when things go wrong.
For us, a complaint is any expression of dissatisfaction with our service or policy. We will
listen to all complaints, treat them seriously, resolve them as quickly as possible and learn
from them so that we can continue improving our service.
This procedure has been updated in accordance with guidelines published by the industry
regulator, the Office of Rail and Road (ORR), in 2015, as a condition of the operating licences
for London Underground, London Overground and TfL Rail services.
Contents
Core Standard 1:Feedback mechanisms and response ................................................ 2
Promoting awareness ......................................................................................................... 2
Making it easy to contact us ............................................................................................... 2
Respecting the customer ................................................................................................... 3
Respecting customer privacy .............................................................................................. 4
Response times ................................................................................................................. 4
Providing a resolution ........................................................................................................ 5
Escalations and Appeals .................................................................................................... 6
Core Standard 2: Structures, people and processes ................................................... 9
Organisational structure and people................................................................................... 9
Training and development .................................................................................................. 9
Processes and protocols .................................................................................................. 10
Complaint service standards ............................................................................................ 11
Core Standard 3: Organisational culture ................................................................. 11
High-level visibility and governance .................................................................................. 11
Learning and improving .................................................................................................... 12
Links ................................................................................................................................ 12
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Transport for London Complaints Handling Procedure
Core Standard 1:
Feedback mechanisms and response
Promoting awareness
Understanding how we are performing is a key element in our process
of continuous improvement. We will make it easy for customers to
provide feedback on our services and encourage them to do so.
Details on how to contact our Customer Services team are displayed
on:
In person
Frontline staff are the first point of contact for immediate feedback
on service performance. Staff members undertake customer service
training and are provided with the tools and information to allow
them to resolve issues on the spot whenever it is possible to do so.
Where a complaint requires investigation or a formal response, staff
will encourage customers to contact the Customer Services team and
provide them with the most appropriate channel for their needs.
• major customer publications;
• our website;
• posters displayed in passenger vehicles; and
• posters displayed at stations
Making it easy to contact us
There are several channels available for customers to contact us.
We have given consideration to each of these options to ensure that
concerns raised can be captured and handled in an effective and
efficient manner.
Phone
Online
TextPhone
Post
Online
Our website includes clear and guided forms that allow customers to
raise a complaint or enquiry, as well as a range of FAQs. Information
on how to raise a complaint is available within two clicks from any
part of our web site. We follow the guidelines for UK government
websites by supporting W3C's Web Content Accessibility Guidelines
2.0 Level AA, and make the website adaptive for use on a range of
devices and browsers.
We include a list of all available contact channels, including phone,
TextPhone and postal options, for customers who wish to contact us
by a different method. To improve the overall experience, we include
the option number that needs to be selected when calling, allowing
for a faster connection to our Customer Services team.
The web page also contains links to our Customer Promise, which
details the service levels we adhere to, the process of how to
complain and to whom, the information required when making a
complaint, as well as the routes for escalation and appeal, including
London TravelWatch and the Local Government Ombudsman.
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Transport for London Complaints Handling Procedure
Phone
We offer a local rate and easy to remember phone number that is
included in a majority of call packages for landline and mobile
providers. The Customer Services team is available 24 hours a day.
If for any reason the phone lines are not open, a recorded message is
played giving details of opening hours and alternate contact options,
such as the website. A TextPhone service is available on a Freephone
number for customers with a hearing disability.
Post
A standard postal address is available for customers who prefer to
write to us with their complaint, or for instances where they may
need to send in supporting materials.
Social media
Our Facebook and Twitter accounts are increasingly used by
customers to express real-time and informal feedback on our
services. We actively monitor comments and aim to resolve and
directly respond to issues when appropriate and practical.
Facebook: Transport for London
Twitter: @tfl
Where customer feedback through social media is determined to be
an issue that needs a more formal response, customers will be
directed to our Customer Services team in order to make their
complaint.
We proactively publish links on social media advising customers of
the complaints process. Where there is an occurrence that is likely to
create service delays, we also publish links for our refunds process.
Respecting the customer
We strive to provide a transport service that caters for all users,
regardless of their circumstance. Our customer service proposition
follows the same ethos and we will ensure that all customers have an
equal opportunity to put forward their concerns.
Whenever possible, we will respond to a customer using their
preferred contact method. The use of large print, audio and other
forms of accessible communication methods will be made available
where practical. The use of PDF files allows us to provide text search,
screen enlargement and ‘read to me’ services for customers.
We maintain a register of different languages spoken by Customer
Service staff and, where possible, will use this to assist in responding
to customers for whom English is not their first language.
We appreciate that not all customers are able to act on their own
behalf. In line with our data protection policy, we allow carers or
guardians to act or advocate for customers with their permission.
Accessibility
Customer Services staff are trained and enabled to assist those with a
diverse range of needs. To support and encourage this, we have a
network of Accessibility Champions who take a proactive stance in
promoting good practice amongst their peers and collaborate with
other departments to ensure the customer voice is heard.
We provide a separate email address (tflaccessibility@tfl.gov.uk) that
allows us to quickly identify and respond to enquiries and complaints
from disabled customers.
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Transport for London Complaints Handling Procedure
Respecting customer privacy
Data protection
All information we collect and store during the process of handling a
complaint is done in adherence with the Data Protection Act 2018.
Our Privacy and Data Protection Policy covers our commitment and
adherence to:
• The Information Commissioner's guidance documents and
Codes of Practice;
• the Payment Card Industry Data Security Standard (PCI DSS);
• TfL's Information and Records Management Policy;
• TfL's Information Security Policy; and
• TfL's Code of Conduct
In respecting a customer’s right to privacy, we will:
• ensure that personal data is processed fairly and lawfully;
• collect only relevant and adequate personal data to allow us
to investigate a complaint;
• take measures to ensure the integrity and security of the data
we process;
• inform them of any requirement to share their data and seek
their permission to do so;
• ensure that all Customer Services staff undertake annual
refresher training on data protection and privacy.
Response times
We value customer feedback and appreciate the efforts made by
customers who have taken the time to contact us. We will respond
to complaints in a timely manner.
All complaints will be acknowledged within 48 hours and a full
response will be provided within 10 working days. In the event that
more time is required, the customer will be informed of:
• what is happening with their complaint;
• how long it will likely take for the response; and
• the name and contact details of the person dealing with the
complaint.
Customers will be given an outline of the complaints procedure when
they first contact us, including the standard for response times. This
may be in person when contacting us by phone, or by an automated
acknowledgement for online and email enquiries to publicised
addresses.
Customers will be provided with a reference number for each case.
Exceptional demand
We forecast and monitor demand for our Customer Services team on
an intra-day basis. In exceptional circumstances, we may not be able
to achieve ORR’s required level of responding to 95% of complaints
within 20 working days.
Should this occur over a period of more than one month, we will
implement a process of reasonable endeavours to maintain service
standards, as well as:
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Transport for London Complaints Handling Procedure
• notifying the ORR and London TravelWatch within two weeks
of such action as to the nature of the event, our mitigating
actions and expected timeframes for returning to normal
service standards; and
• notifying customers through our web page as to the nature of
the event and our amended response standards.
Providing a resolution
We aim to provide a full and fair investigation of all complaints.
In order to do so, we will:
• identify the key issues that have been raised by the customer
and address each one in turn;
• look at the context and intent of the complaint to confirm
whether there are any unstated issues that need to be
addressed;
• gather, check and review evidence to allow us to establish and
corroborate the facts of the complaint;
• investigate the reasons why the issue has occurred;
• identify any recurring or root causes; and
• consider the most appropriate form of resolution and
response.
We will respond to customers using their preferred channel where
possible and will provide a full written response in plain English.
All Customer Services staff are trained and have guidelines in the use
of tone and voice when crafting a response. To maintain and improve
the standard of our responses, regular quality assessments are
undertaken by team managers, as well as by an independent quality
team.
Getting it right first time
Our Customer Services team are focused on the importance of
responding individually and empathetically to each customer’s
circumstances. We have empowered our staff to use their initiative
and explore all avenues, including the use of gestures of goodwill,
in order to provide a quick and acceptable response to customer
complaints.
Further investigation
In certain cases, we may need to investigate issues that require more
than one response from us. Where we have provided a second full
and substantive response to a customer, we will include the details
for London TravelWatch, even where we are still actively working
towards a resolution of the complaint.
Complaints involving multiple licence holders
Where a complaint involves services not directly under our licence,
we will liaise with relevant Operators to obtain the information we
need in order to resolve the issue. In situations where the interest of
the customer would be better served by having the complaint
resolved directly by the third party, we will inform them of our
decision and seek permission to share the relevant details of their
complaint in line with our Privacy and Data Protection Policy.
Staff privacy
Where a complaint relates to an individual member of staff, the
details of any action taken against them remains confidential within
the bounds of the Data Protection Act 2018 and will not ordinarily be
disclosed.
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Transport for London Complaints Handling Procedure
Compensation
Where the complaint involves a refund for service delay, we will
provide compensation in line with the Transport for London or
National Rail Conditions of Carriage, whichever is greater. Claims for
payment due to delayed or cancelled services are not considered as a
complaint and will be recorded and monitored separately to this
procedure.
Unreasonable and unreasonably persistent complaints
We will actively seek to find a full and fair resolution to all complaints
received. However, where a customer’s complaint is unreasonable, or
they are unreasonably persistent in pursuing either an open or
resolved complaint, we reserve the right to restrict or cease their
communication with us.
Such action will be taken as a last resort and is covered in full by our
Unreasonable and Unreasonably Persistent Complaints policy.
Any actions taken under this policy will include:
• full communication with the customer as to why the action is
being proposed or implemented;
• authorisation and review by a business-level manager;
• documentation of the situation and actions taken; and
• notification to the customer of paths to appeal, including
London TravelWatch and the Local Government
Ombudsman.
Except in extreme cases of deliberate and vexatious communication,
each new and unrelated complaint from a customer who is being
managed under this policy will be treated on its merits.
Escalations and Appeals
Whilst the majority of customer complaints can be resolved by
Customer Services staff, there are instances where the process may
need to be reviewed by a team manager or independent adviser to
ensure the thoroughness and suitability of our investigation.
Escalations
Escalation of a complaint may occur where:
• it is requested by the customer;
• the customer is aggrieved with the process or response;
• it involves a serious or exceptional incident involving injury, or
a vulnerable member of the public;
• it involves a serious reputational risk to the organisation;
• it has underlying health and safety implications;
• it is politically sensitive or newsworthy;
• it is from a customer being managed under the Unreasonable
and Unreasonably Persistent Complaints policy; or
• it relates to an exceptional matter involving the Mayor,
Transport Commissioner, or company Director.
Where a complaint has been escalated, we will:
• pass the complaint to a Customer Services team manager
who will review the complaint in its entirety and respond
within 10 working days. Should further time be required, the
manager will contact the customer advising them of the
reason and likely timeframe for response.
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Transport for London Complaints Handling Procedure
Complaints may be directly escalated to any stage of the process
dependent on the context. The escalation of a complaint is part of
our internal process and does not impact the customer’s rights to
engage with London TravelWatch, the Rail Ombudsman, or the
Local Government Ombudsman in pursuit of resolution.
Appeals
Customers who are not satisfied with our resolution or response to
their complaint may refer the issue to London TravelWatch, the
Rail Ombudsman, or the Local Government Ombudsman.
We provide the contact details for these organisations within the
second substantive response to a complaint, as well as on our web
site.
Alternative Dispute Resolution
In line with our obligations under the Alternative Dispute Resolution
for Consumer Disputes (Competent Authorities and Information)
Regulation 2015, where we are unable to resolve a complaint, we will
provide customers with the details for the relevant ADR body, the
Consumer Ombudsman (www.consumer-ombudsman.org). We will
also advise that we are not obliged to use the ADR process and direct
them instead to London TravelWatch or Rail Ombudsman.
Freedom of information
Requests for data we hold can be made via email: [email protected]
Full details are available on our Transparency page:
www.tfl.gov.uk/corporate/transparency
London TravelWatch is the official watchdog organisation representing
the interests of public transport users in and around the capital. It is
independent of the transport providers. It can assist with complaints
about public transport in London when the complainant remains
dissatisfied with the service provider’s response.
Phone
020 3176 2999 (09:00 – 17:00, Monday to Friday)
Online
www.londontravelwatch.org.uk/complaints/online
Email
[email protected]
The Local Government Ombudsman (“LGO”) provides a free,
independent and impartial service for investigating complaints about
the actions of many public authorities. The LGO can assist with
complaints about streets and traffic matters, when the complainant
remains dissatisfied with Transport for London's response.
Phone
0300 061 0614 (08:30 – 17:00, Monday – Friday)
Online
www.lgo.org.uk/making-a-complain
Post
The Local Government Ombudsman
PO Box 4771
Coventry, CV4 0EH
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Transport for London Complaints Handling Procedure
The Rail Ombudsman is an independent, not-for-profit organisation.
They offer a free, expert service to help sort out unresolved customer
complaints about service providers within the rail industry. They can
assist with complaints about London Overground and TfL Rail services
and *some London Underground stations with National Rail services
for incidents starting from 1 April 2022 when the complainant remains
dissatisfied with Transport for London’s response.
Phone
0330 094 0362 (09:00 – 17:00, Monday – Friday)
Online
www.railombudsman.org
Email
[email protected]
Post
FREEPOST –
RAIL OMBUDSMAN
*London Underground stations with National Rail
services covered by the Rail Ombudsman
• Amersham
• Blackhorse Road
• Chalfont & Latimer
• Chorleywood
• Farringdon
• Greenford
• Gunnersbury
• Harlesden
• Harrow & Wealdstone
• Harrow on the Hill
• Highbury & Islington
• Kensal Green
• Kenton
• Kentish Town
• Kew Gardens
• Moorgate
• North Wembley
• Old Street
• Queen’s Park
• Rickmansworth
• Seven Sisters
• South Kenton
• South Ruislip
• Stonebridge Park
• Stratford
• Walthamstow Central
• Wembley Central
• West Brompton
• West Ham
• West Ruislip
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Transport for London Complaints Handling Procedure
Core Standard 2:
Structures, people and processes
Organisational structure and people
As an organisation, we place customers at the heart of everything we
do. Our commitment is evidenced through the deployment of a
professional, well-trained and supported network of staff,
empowered and enabled to deliver excellence as a standard.
Frontline operational staff
Frontline staff have regular and on-going interaction with managers,
both in terms of personal performance and development, as well as
operational reviews and quality assurance. All staff are trained and
have access to the information and processes to enable them to
assist customer enquiries at point of origin, as well as the details of
alternate support options including the formalisation of complaints.
Customer Services team
Complaints and investigations are handled by our in-house team.
We maintain a high standard of service through a combination of
recruitment, induction, training, engagement, motivation and quality
assurance activities.
There is daily interaction with team managers and business-level
performance managers, ensuring that feedback and awareness of
customer issues is captured and reviewed without delay. Senior
managers, including the Head of Contact Centre Operations,
Customer Experience Director and Managing Director hold regular
open forums with the team.
Training and development
Supporting the Customer Services staff are four teams focusing on:
• learning and development;
• knowledge and engagement;
• quality; and
• resourcing and scheduling
These teams provide a centralised and calibrated approach that
ensures a consistency in standards and the ability to identify and act
upon elements of performance improvement. Key activities delivered
by these teams include:
• bespoke training programs for induction, development and
operational awareness;
• central knowledgebase for procedures, news and information
that ensures a consistency in approach and a timely
distribution of updates regarding situations that may impact
operational performance and customer satisfaction;
• publication of quality standards, frameworks and best practice
guides; and
• effective distribution of staff resource to ensure response
times are met whilst allowing for support, training and
development activities.
All complaint-handling staff are trained and monitored on their
customer service, complaint investigation and resolution skills.
Regular performance reviews allow for the identification of coaching
and training opportunities to improve skills and knowledge.
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Transport for London Complaints Handling Procedure
Processes and protocols
Record keeping
Complaints are collated centrally on our Customer Relationship
Management (CRM) system. Data is retained in line with our corporate
information and records disposal schedule, which conforms to the
requirements of the Data Protection Act 2018.
We retain complaint data in electronic format. Records logged on the
CRM are held for a minimum period of three years. This includes full
details of the customer, nature of the complaint, and a record of all
contacts received and responses sent.
Aggregated data that contains no personally identifiable information
may be held for a minimum of five years in order to identify trends in
complaint volumes and categories.
Complaint data will be maintained in a format that allows for analysis
of service improvement opportunities and fulfilment of regulatory
reporting requirements.
Quality control
We implement a range of measures to ensure the quality of our
communication with customers is of a high standard, including:
• the use of style guides and adviser self-assessment checks;
• scheduled call recording, monitoring and quality audits;
• scheduled correspondence reviews for structure, tone and
suitability of proposed resolution;
• intra-day monitoring and coaching; and
• external audit programs.
We undertake over 500 phone, correspondence and 'mystery
shopper' quality checks each four week period. These are conducted
both within the Customer Services team and by the independent
Quality team to ensure objectivity.
Identification of systemic weaknesses
We monitor and analyse the volume and type of complaints on a
periodic basis to identify any underlying issues that have emerged.
Where these pertain to the complaints handling procedure, we will
look to implement changes in line with ORR guidelines.
We provide feedback to internal stakeholder groups allowing them to
incorporate intelligence gained from customer complaints as part of
their service improvement processes.
We distinguish complaints as being a notice of customer
dissatisfaction that specifically asks for or requires a direct response
from us. Feedback from customers that does not require such action
is still collated and used alongside complaints data to review and
improve performance.
Where a complaint pertains to an individual member of staff, we will
consider the context and contributing factors to examine if there are
broader issues that need to be addressed to improve performance.
Complaints pertaining to health and safety issues will be reviewed in
line with our Health, Safety and Environment policies. Where an
allegation of injury is received from a customer, consideration will be
given for the reporting of the incident under the Reporting of Injuries,
Diseases and Dangerous Occurrences Regulations 2013.
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Transport for London Complaints Handling Procedure
Complaint service standards
We adhere to a set of standards that customers can be assured of
when they make a complaint:
• the complaint handling process is embedded in our culture
and subject to high level governance;
• the complaints process is accessible and easy to use;
• complaints will be fully and fairly investigated by trained staff;
• we will aim to respond in full to complaints within 10 working
days wherever possible;
• we will keep customers informed of the progress and
outcome of their complaint;
• we will respond to all points raised and seek to resolve the
issue to the customer’s satisfaction;
• we will inform customers of their right of appeal with London
TravelWatch or the Local Government Ombudsman
• we will monitor trends to identify and address any systemic
issues; and
• we will learn from the issues raised in complaints and use
these to drive performance improvement.
These standards are reflected in our Customer Promise document,
which is available on our website.
Core Standard 3:
Organisational culture
High-level visibility and governance
We are a customer-focused organisation that utilises feedback to
help drive improvements in our performance. This commitment
springs from two of our core strategic pillars:
• Customers - the heart of our business: putting customers and
users at the centre of everything we do;
• Our People - dedicated to customer service: valuing our
people, being accountable, actively seeking solutions and
working with others directly, fairly and consistently.
In particular, the values of being accountable, active, fair and
consistent are direct drivers in our commitment to providing a robust
complaint handling procedure.
Customer satisfaction and complaints data are published as key
business metrics in our Quarterly finance, investments and
operational performance report. These are reviewed at board level
and available on our website.
In addition, the senior leadership team have a full overview of the
complaints process, volumes, trends and underlying causes of
complaints across the organisation.
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Transport for London Complaints Handling Procedure
Learning and improving
To ensure we remain competent and focused on handling and
resolving customer complaints, we conduct a range of activities
including:
• engaging with industry peers to collaborate on elements of
best practice, including participation in the annual Top 50
Contact Centre benchmarking programme;
• participating in mystery shopper programmes; and
• major internal campaigns to enhance writing and first-time
resolution skills with complaint handling staff.
As an organisation, we strive to deliver a safe, reliable, efficient and
inclusive transport network. Learning from complaints is a key factor
in achieving this and we are committed to doing so.
For more information on what we do and our commitment to
customers, visit: www.tfl.gov.uk/corporate/about-tfl/
Links
Help and contacts (including Customer Promise):
www.tfl.gov.uk/help-and-contact
Freedom of Information requests:
www.tfl.gov.uk/corporate/transparency
National Rail Conditions of Carriage:
www.nationalrail.co.uk/times_fares/46427.aspx
Privacy and data protection policy:
www.tfl.gov.uk/corporate/privacy-and-cookies
Quarterly finance, investment and operational performance reports:
www.tfl.gov.uk/corporate/publications-and-reports/quarterly-progress-
reports
Social media policy and house rules:
www.tfl.gov.uk/corporate/terms-and-conditions/social-media
Transport for London Conditions of Carriage:
www.tfl.gov.uk/corporate/terms-and-conditions/ticketing-and-travel-
conditions-of-carriage
Unreasonable complaints policy:
www.tfl.gov.uk/corporate/publications-and-reports/complaints-policy
Document control
This document will be reviewed annually in March and authorised by the CCO
Customer Support Manager. Current version: FY 2022 Updated: March 2022