Appropriate Body Complaints, Concerns and Appeals Policy

 

1. Purpose

Embrace Appropriate Body is committed to delivering a high-quality, fair, transparent and impartial service in relation to the statutory induction of Early Career Teachers (ECTs). This policy sets out the arrangements for raising, investigating and resolving concerns, complaints and appeals relating to statutory induction and the services provided by the Appropriate Body.

The policy aims to:

  • Resolve concerns at the earliest opportunity.
  • Ensure all parties are treated fairly, respectfully and consistently.
  • Safeguard the statutory entitlements of Early Career Teachers.
  • Maintain confidence in the Appropriate Body service.
  • Support continuous improvement through effective complaint handling.

All matters will be managed sensitively, confidentially and in accordance with relevant data protection legislation.

2. Scope

This policy applies to:

  • Early Career Teachers (ECTs)
  • Mentors
  • Induction Tutors
  • Headteachers and Principals
  • Governing Bodies
  • Employing Schools
  • Appropriate representatives acting on behalf of an ECT or school where appropriate

The policy covers:

Complaints Regarding a School's Handling of Induction. Including concerns relating to:

  • Mentoring arrangements
  • Induction tutor support
  • Release time entitlements
  • Delivery of the Early Career Teacher Entitlement
  • Progress reviews and formal assessments
  • Additional support arrangements
  • Compliance with statutory induction guidance

  • Complaints Regarding Embrace Appropriate Body. Including concerns relating to:

  • Quality assurance activities
  • Advice and guidance provided
  • Statutory induction decisions
  • Investigations undertaken
  • Administrative processes
  • Communication and service standards
  • Conduct of Appropriate Body representatives

  • This policy does not replace:

  • School complaints procedures
  • Grievance procedures
  • Capability procedures
  • Disciplinary procedures
  • Whistleblowing procedures

  • Employment matters should normally be addressed through the relevant employer's procedures.

    3. Who May Raise a Concern or Complaint

    Concerns and complaints may be raised by:

  • Early Career Teachers (ECTs)
  • Mentors
  • Induction Tutors
  • Headteachers and Principals
  • Governing Bodies
  • Employing Schools
  • Authorised representatives acting on behalf of an ECT or school

  • The Appropriate Body will consider concerns and complaints from any party directly involved in, or affected by, the statutory induction process.

4. Definitions

Concern. A concern is an issue relating to induction support, provision, progress or compliance that can usually be resolved through discussion and early intervention.

Formal complaint. A complaint becomes a formal expression of dissatisfaction, which remains unresolved following informal attempts at resolution, regarding:

  • A school's handling of statutory induction; or
  • The service provided by Embrace Appropriate Body

Complaint Review Panel.  Held following a request for Embrace Appropriate Body to review whether a formal complaint was investigated fairly, reasonably and in accordance with this policy.

Statutory Induction Appeal. A statutory challenge by an ECT against an Appropriate Body decision that the ECT has failed to complete induction satisfactorily or that their induction period should be extended. Statutory induction appeals are determined by the Teaching Regulation Agency and do not form part of the Embrace complaints procedure.

5. Guiding Principles

The Appropriate Body will:

  • Always act impartially.
  • Investigate concerns objectively.
  • Treat all parties fairly.
  • Maintain appropriate confidentiality.
  • Keep complainants informed of outcomes and available next steps.
  • Explain the evidence considered in reaching decisions.
  • Explain where evidence has not been relied upon and the reasons for doing so.
  • Seek to resolve matters at the earliest opportunity.

Where an investigation requires a school visit, reasonable efforts will be made to ensure the complainant is aware of the visit and can provide evidence or speak directly with the investigator.

Reasonable adjustments. Embrace Appropriate Body will make reasonable adjustments to the complaints process where required. This may include accepting a complaint in an alternative format, providing documents in an accessible format, allowing support from a representative or adjusting meeting arrangements. Requests will be considered in accordance with the Equality Act 2010.

Safeguarding and Whistleblowing. Where information received under this policy raises a safeguarding concern, an allegation concerning an adult working with children, a risk of harm or a whistleblowing matter, Embrace Appropriate Body may refer the information promptly to the relevant school, designated safeguarding lead, local authority designated officer, employer, regulator or statutory agency. The complaints process may be paused or adjusted where necessary to avoid prejudicing another investigation.

6. Informal Resolution of Concerns

Concerns should be raised as soon as possible.

ECT Concerns. ECTs should normally raise concerns initially with:

  1. Their Mentor
  2. Their Induction Tutor
  3. Their Headteacher or Principal

School Concerns. Schools should discuss concerns regarding induction or ECT progress directly with:

  • The ECT
  • The Mentor
  • The Induction Tutor
  • Embrace Appropriate Body where appropriate

Appropriate Body Support. Where concerns cannot be resolved locally, Embrace Appropriate Body may support resolution through:

  • Advice and guidance
  • Mediation or facilitated discussions
  • Quality assurance activities
  • Intervention support

The Appropriate Body will normally respond to informal concerns within 10 working days.

7. Early Intervention and Support for ECTs

Where concerns arise regarding an ECT's progress towards meeting the Teachers' Standards, Embrace Appropriate Body will follow its published escalation procedures.

Where concerns are raised during Terms 1 to 3:

  • The school should implement an Additional Support Plan, see Appendix A.
  • The support plan should identify strengths, targets and success criteria.
  • Support should normally continue for a minimum of six weeks.
  • Progress should be reviewed regularly.

 

If concerns remain at the next assessment point, an Appropriate Body Lead may undertake a quality assurance visit and may conduct a joint observation with the Induction Tutor.

Where concerns arise from Term 4 onwards:

  • An Appropriate Body Lead will normally undertake a quality assurance visit promptly.
  • An Embrace Additional Support Plan will be implemented.
  • Support should normally continue for a minimum of six weeks.
  • Progress should be reviewed regularly.

No judgement that an ECT is failing to make satisfactory progress should be reached without evidence that appropriate support and intervention have been provided.

8. Formal Complaints Procedure

Stage 1: Informal Resolution

Before submitting a formal complaint, complainants should normally seek informal resolution wherever appropriate.

This may include:

  • Discussion with the school
  • Discussion with the Appropriate Body Lead
  • Clarification of statutory guidance
  • Mediation or facilitated discussion

If the matter remains unresolved, a formal complaint may be submitted.

Stage 2: Formal Complaint Investigation

Submitting a complaint. Complaints should normally be:

  • Raised within three months of the matter occurring; and
  • Submitted in writing.  Assistance can be offered where a complainant has difficulty submitting a written complaint.

The complaint should include:

  • Details of the complaint
  • Actions already taken to resolve the matter
  • Relevant supporting evidence
  • The outcome sought

 

Acknowledgement. The Appropriate Body will acknowledge receipt within 5 working days. When the office is closed, this will be within 5 working days of the office re-opening.

Investigation. An investigator will be appointed who has had no prior involvement in the matter wherever possible.

The investigator may:

  • Review documentation
  • Seek written evidence
  • Interview relevant individuals
  • Undertake school visits where necessary
  • Obtain additional information

Outcome. A written outcome will normally be issued within 20 working days.

The written response will include:

  • Findings
  • Evidence considered
  • Conclusions reached
  • Reasons for decisions
  • Any actions arising
  • Details of further escalation rights

Stage 3: Complaint Review Panel

If the complainant remains dissatisfied following the Stage 2 outcome, they may request a Complaint Review Panel.

Requests for a review must be submitted in writing within 5 working days of receipt of the Stage 2 response. Assistance can be offered where a complainant has difficulty submitting a written request.

Acknowledgement. The Appropriate Body will acknowledge receipt within 5 working days. When the office is closed, this will be within 5 working days of the office re-opening.

Panel Arrangements. A Complaint Review Panel will normally be convened within 20 working days. When the office is closed, holiday periods are not included when calculating 20 days.

The Complaint Review Panel will normally comprise three people who have had no material prior involvement in the complaint or the decisions under review. Panel members must be able to consider the matter fairly and impartially and must declare any actual or potential conflict of interest.

 

Wherever reasonably practicable, at least one panel member will be independent of the Embrace Appropriate Body service and of the operational management of the matter complained about.

The person who investigated the complaint at Stage 2 may attend to explain their investigation but will not be a member of the panel or participate in the panel’s decision.

The Panel will consider:

  • Whether the complaint was investigated fairly and objectively
  • Whether relevant policies, procedures and statutory guidance were followed
  • Whether the findings and conclusions were reasonable based on the available evidence
  • Whether any further actions are required

Panel Outcomes. The Panel may:

  • Uphold the complaint in full
  • Uphold the complaint in part
  • Dismiss the complaint
  • Recommend further investigation
  • Recommend service improvements or corrective action

A written decision will be issued within 5 working days of the panel meeting.

The decision of the Complaint Review Panel represents the final stage of the Embrace Appropriate Body complaints process.

The Panel cannot determine a statutory induction appeal or substitute its own statutory induction decision for that of the Appropriate Body. Where the complaint identifies a procedural failing or relevant evidence that may not have been considered, the Panel may recommend that the Appropriate Body reconsider the matter in accordance with its statutory responsibilities. This does not affect the ECT’s right to appeal to the Teaching Regulation Agency within the applicable deadline.

Submitting a formal complaint or requesting a complaint review does not extend or suspend the statutory deadline for appealing an induction decision to the Teaching Regulation Agency.

Complaint Handling Extensions.  Where it is not reasonably possible to meet a timescale in this policy, the Appropriate Body will write to the complainant before, or as soon as reasonably practicable after, the deadline. The communication will explain the reason for the delay, the steps remaining and the revised target date. Extensions will be proportionate and will not be used to delay matters unnecessarily.

 

9. Complaints About a School's Handling of Induction

Where a concern or complaint relates primarily to a school’s handling of statutory induction, the complainant should normally seek to resolve the matter with the induction tutor or headteacher/principal in the first instance.

An ECT may also contact the named Embrace Appropriate Body contact directly where:

  • the matter has not been resolved locally;
  • the concern relates to the induction tutor, headteacher or principal;
  • the concern involves a possible failure to provide statutory induction entitlements;
  • delay could adversely affect the ECT’s induction, assessment or support; or
  • there is another reasonable basis for not pursuing the matter locally.

Embrace Appropriate Body will determine whether the matter falls within its statutory quality-assurance role, should be considered under this policy, should be dealt with through the school’s own procedure, or requires parallel action by the school and the Appropriate Body.

The Appropriate Body's involvement remains focused on statutory induction and not wider employment matters.

10. Matters Outside the Appropriate Body's Remit

The Appropriate Body's role is limited to matters relating to statutory induction, including support, monitoring, assessment and quality assurance arrangements.

The Appropriate Body will not normally investigate:

  • Employment contracts
  • Pay and conditions of service
  • Disciplinary procedures
  • Capability procedures
  • Staffing restructures
  • Workplace grievances
  • Allegations managed through safeguarding procedures
  • Wider employment disputes

Such matters remain the responsibility of the employing school and should be dealt with through the school's own procedures.

Where a complaint contains elements both within and outside the Appropriate Body's remit, Embrace Appropriate Body will investigate only those matters relevant to its statutory responsibilities.

11. Complaints About Embrace Appropriate Body

Complaints regarding Embrace Appropriate Body may include concerns relating to:

  • Advice provided
  • Quality assurance activities
  • Investigations undertaken
  • Communication
  • Service standards
  • Decisions made under statutory induction responsibilities

Such complaints should proceed directly through the stages outlined in this policy.

12. Appeals Relating to Statutory Induction Decisions

Statutory induction appeals are separate from, and do not form part of, the Appropriate Body complaints process.

An ECT has a statutory right of appeal, where Embrace Appropriate Body decides that the ECT:

  • has failed to satisfactorily complete induction; or
  • requires an extension to their induction period.

Appeals should be submitted to the Teaching Regulation Agency within in 20 working days of receiving notification of the Appropriate Body’s decision, in accordance with the published procedures of the Teaching Regulation Agency.

Appeals may be made where the ECT believes:

  • Statutory guidance was not applied correctly
  • The decision was inconsistent with the available evidence
  • Appropriate support, monitoring or assessment arrangements were not provided
  • Relevant information was not properly considered

When notifying an ECT of a decision to extend induction or that the ECT has failed induction, Embrace Appropriate Body will provide:

  • written reasons for the decision;
  • the name and address or current contact details of the Appeals Body;
  • the deadline for submitting an appeal; and
  • a link to the current statutory induction appeals procedure.

 

A complaint about the service provided, the handling of induction or the process followed may be considered under this policy. However, the complaints procedure cannot overturn a statutory induction decision. Any challenge to such a decision must be made through the statutory appeal process.

13. Escalation to the Department for Education

Where a complainant has exhausted all stages of the Embrace Appropriate Body complaints process and remains dissatisfied, they may raise the matter directly with the Department for Education.

The Department for Education's role is limited to considering whether the Appropriate Body has:

  • Failed to discharge a statutory duty; or
  • Unreasonably exercised its statutory functions.

The Department for Education cannot substitute its own decision for that of the Appropriate Body in relation to statutory induction decisions. It may, however, consider whether the Appropriate Body's systems and processes comply with statutory requirements and guidance.

14. Managing Unreasonable Complainant Behaviour and Repeated Complaints

The Appropriate Body recognises that complainants have the right to pursue concerns through the stages outlined within this policy.

However, there may be occasions where a complainant's behaviour becomes unreasonable, including where complaints are:

  • Repetitive and substantially unchanged
  • Pursued after all stages of the process have been completed
  • Abusive, offensive or threatening
  • Intended to harass or cause disruption
  • Clearly frivolous or vexatious

In such circumstances, the Appropriate Body may implement proportionate measures to manage communications and the complaints process. Any such decision will be communicated in writing together with the reasons for the decision.

 

15. Responsibilities, Escalation Routes and Contact Details

 

Matter

 

Lead Responsibility

 

Submitted To

 

Day-to-day induction concerns

Mentor / Induction Tutor

 

School-level induction concerns

Headteacher / Principal

 

ECT progress concerns

School with Appropriate Body oversight

 

Complaint about school's handling of induction

School complaints procedure with AB involvement where statutory induction compliance is relevant

Contact the AB team at tsh@embrace-eduction.co.uk , marked for the attention of the AB Lead, or raise a support request via this form.

Complaint about Embrace Appropriate Body

Director, Embrace Teaching School Hub

Contact the Hub Director at tsh@embrace-education.co.uk, marked for the attention of the Hub Director.

Complaint about the Director, Embrace Teaching School Hub

 

 

The Sea View Trust

Contact trustoffice@svt.org.uk , clearly stating to whom the complaint is regarding.

Statutory induction outcome appeal

Teaching Regulation Agency

Induction appeals procedure - GOV.UK

 

16. Record Keeping and Confidentiality

Statutory induction assessment reports and associated induction records will be retained for a minimum of six years, in accordance with current statutory induction guidance.

Complaint records will be retained in accordance with applicable data protection legislation, organisational retention schedules and statutory requirements.

The Appropriate Body will maintain secure records of:

  • Concerns raised
  • Complaints received
  • Investigations undertaken
  • Correspondence
  • Evidence reviewed
  • Decisions made
  • Actions arising from complaints

Access to complaint records will be restricted to those individuals who have a legitimate professional need to access the information.

Information relating to complaints will be handled confidentially except where disclosure is required by law, safeguarding obligations or regulatory requirements.

17. Monitoring and Review

This policy will be reviewed annually, or sooner where changes to legislation, statutory guidance or Appropriate Body requirements necessitate revision.

Policy Owner: Director, Embrace Teaching School Hub