STILLWELL

Complaints Procedure

Personal Care Membership | Members, prospective Members and representatives

Service provider	Stillwell Wellness Ltd, trading as Stillwell®
Company number	16965118
Registered office	Hillview, Tan Y Bryn, Hen Lon, Dinbych, United Kingdom, LL16 5BE
Complaints email	info@stillwellclub.com
Complaints lead	TBC
Independent review contact	TBC
Effective / review date	29 July 2026 / 29 July 2027
OUR COMMITMENT Stillwell welcomes concerns and complaints as an opportunity to put things right and improve. We will listen, respond fairly, protect confidentiality, make reasonable adjustments and ensure that nobody is disadvantaged for raising a genuine concern.

 

1. Purpose and scope

1.1 This procedure explains how to complain about Stillwell’s Personal Care Membership, customer service, communications, billing, accessibility, staff or contractor conduct, privacy, safeguarding or another aspect of the service.

1.2 It applies to Members, prospective Members, former Members, authorised representatives and other people directly affected by Stillwell’s service.

1.3 A request for information, routine service query, cancellation request or initial expression of dissatisfaction may be handled without becoming a formal complaint. The person may ask for the formal process at any time.

1.4 This procedure does not replace emergency, safeguarding, police, court, regulatory or statutory routes. Stillwell may run another process alongside the complaint where necessary.

2. Principles

Stillwell will:

·     make the process clear, free to use and reasonably accessible;

·     listen respectfully and identify the outcome the complainant is seeking;

·     deal with the complaint promptly, proportionately and without avoidable defensiveness;

·     use an investigator or reviewer who is sufficiently impartial and has not made the decision under challenge wherever practicable;

·     keep the complainant informed and explain any delay;

·     protect confidential information and share it only where necessary;

·     not suspend, reduce or worsen service because someone has complained, except where a proportionate safety or conduct measure is necessary; and

·     record outcomes, remedies and learning.

3. Who may complain and support available

3.1 A person may complain for themselves or through a representative. Stillwell may ask for authority to discuss confidential information with the representative, unless another lawful authority applies.

3.2 Complaints may be made in writing, by email, or verbally. Stillwell will record a verbal complaint and check its understanding with the complainant.

3.3 Stillwell will make reasonable adjustments where needed, including communication in a preferred format or channel, additional time, support from a representative, or another practicable adjustment.

3.4 Anonymous complaints will be considered where enough reliable information is available. The ability to investigate or provide an individual response may be limited.

4. How to make a complaint

4.1 Email info@stillwellclub.com with the subject line “Complaint”, or write to the registered office shown above. A complaint may also be raised with a Stillwell practitioner, who must pass it promptly to the Complaints Lead.

4.2 Please provide, where possible: your name and contact details; Membership ID; what happened and when; who was involved; any relevant documents; the impact; steps already taken; and the outcome you would like.

4.3 Complaints should normally be made within 12 months of the event or of becoming aware of it. Stillwell may accept a later complaint where there is a good reason and it remains possible to investigate fairly.

5. Complaint stages and timescales

Stage	How it starts	Normal timescale
Early resolution	Raise the concern with Stillwell by email or during contact with the service.	Acknowledge promptly and aim to resolve within 5 working days.
Formal investigation	Request a formal complaint, or Stillwell may move a serious or unresolved concern directly to this stage.	Acknowledge within 3 working days. Aim for a written outcome within 20 working days.
Review	Ask for a review within 15 working days of the formal outcome, explaining the grounds.	Acknowledge within 3 working days. Aim for a final response within 15 working days.

Working days exclude weekends and public holidays in England and Wales. Times are targets rather than a restriction on legal rights. If a complaint is complex, depends on another investigation, or cannot safely be completed on time, Stillwell will explain the reason, provide an update and give a revised target date. Formal investigations should not normally exceed 40 working days without exceptional reasons.

6. Stage 1: early resolution

6.1 Where suitable, the person receiving the concern will listen, clarify the issue, apologise for any clear service failure, correct straightforward errors and agree a practical response.

6.2 A brief written confirmation will be provided where appropriate. The complainant may request formal investigation if the concern is serious, remains unresolved or they do not consider early resolution suitable.

6.3 Stillwell will move the matter directly to formal investigation where it involves alleged serious misconduct, discrimination, repeated failure, significant financial loss, safeguarding, privacy, serious harm or a substantial conflict of interest.

7. Stage 2: formal investigation

7.1 The Complaints Lead will acknowledge the complaint, provide a reference, summarise the issues and desired outcome, identify the investigator, explain the process and confirm any immediate risk controls.

7.2 The investigator may review records and correspondence, speak to relevant people and request further information. Only information reasonably necessary for the investigation will be used.

7.3 The complainant and any person criticised will be treated fairly. Each should have a reasonable opportunity to provide relevant information, subject to safeguarding, confidentiality and legal constraints.

7.4 The written outcome will set out the issues considered, evidence or information relied upon, findings on each material point, reasons, remedy or action, learning and how to request a review.

8. Stage 3: review

8.1 A review is not normally a complete reinvestigation. It considers whether the procedure was fair; material evidence was overlooked; findings were reasonably supported; the response was proportionate; or significant new information has emerged.

8.2 The request should identify the review grounds and desired outcome. Stillwell may accept a late request where there is a good reason.

8.3 The review should be carried out by a person who was not responsible for the original outcome. Where Stillwell’s size makes internal independence impossible—particularly where the complaint concerns the sole director—Stillwell should appoint an appropriate external reviewer.

8.4 The final response will confirm whether the original decision is upheld, varied or replaced; explain the reasons and any further action; and identify relevant external options.

9. Possible outcomes and remedies

A proportionate outcome may include:

·     an explanation, clarification or correction;

·     an apology where Stillwell has fallen short;

·     completion or repetition of an agreed service action;

·     a change of practitioner, communication method or reasonable adjustment where practicable;

·     rebooking, account credit, partial refund or refund where appropriate and consistent with legal rights;

·     correction or restriction of inaccurate or improperly handled personal information;

·     staff guidance, training, supervision, disciplinary or contractual action where appropriate;

·     a change to a process, document, system or risk control;

·     safeguarding, insurer, legal, regulatory or law-enforcement referral where required; or

·     no further action, with reasons, where the complaint is not upheld.

Any remedy will depend on the circumstances and applicable legal rights. Nothing in this procedure limits a consumer’s rights under the Consumer Rights Act 2015 or other applicable law.

10. Safeguarding, safety and serious misconduct

10.1 If a complaint indicates immediate danger, serious self-harm or suicide risk, abuse, neglect or another safeguarding concern, Stillwell will follow its Safeguarding and Escalation Procedure without waiting for the complaints process.

10.2 Stillwell may share relevant information with emergency services, social services, police, insurers, legal advisers or another appropriate body where lawful, necessary and proportionate.

10.3 A complaint about a practitioner may require temporary risk controls. These are neutral protective steps and do not predetermine the complaint or any separate investigation.

11. Data-protection complaints

11.1 A complaint about personal information will also be handled under the Privacy Notice and applicable data-protection law. Stillwell will provide a clear route to complain, acknowledge a data-protection complaint within 30 days at the latest, investigate without undue delay, keep the complainant informed and communicate the outcome.

11.2 Where the complaint also contains an information-rights request, such as an access or erasure request, Stillwell will identify and manage the statutory request separately so the correct legal timescale is applied.

11.3 A person may complain to the Information Commissioner’s Office if dissatisfied with Stillwell’s response. The ICO recommends raising concerns with the organisation first and normally contacting the ICO within three months of the organisation’s final response.

12. Confidentiality, records and retention

12.1 Complaints will be handled confidentially on a need-to-know basis. Complete secrecy cannot be promised where information must be shared to investigate fairly, safeguard someone, obtain advice or comply with law.

12.2 Stillwell will keep a complaint file containing the complaint, correspondence, evidence, decisions, actions and outcome. Complaint records will normally be retained for six years after closure, or longer where necessary for safeguarding, legal claims, insurance, regulation or an ongoing risk.

12.3 Anonymous and aggregated complaint information may be used for governance, training and service improvement.

13. Unreasonable, abusive or persistent behaviour

13.1 Stillwell will distinguish between a persistent complaint and unreasonable behaviour. A complainant will not be restricted merely because they are distressed, disagree with an outcome or make repeated reasonable contact.

13.2 Stillwell may set proportionate communication boundaries where behaviour is threatening, abusive, discriminatory, knowingly false, excessively repetitive, or seriously disrupts the service. Any restriction will be explained in writing, kept under review and will not prevent genuine new safeguarding or service concerns being considered.

 

14. External options

14.1 For consumer advice, a complainant may contact the Citizens Advice consumer service through www.citizensadvice.org.uk/consumer.

14.2 For personal-information concerns, a complainant may contact the Information Commissioner’s Office through www.ico.org.uk.

14.3 Where a consumer dispute remains unresolved, Stillwell’s final response will state whether an approved alternative dispute resolution provider is available and whether Stillwell is required or willing to use it. Stillwell must not claim membership of an ADR or ombudsman scheme unless that arrangement has been confirmed.

14.4 The complaints process does not remove anyone’s right to seek independent legal advice, report a matter to an appropriate authority, or pursue a court remedy.

15. Governance and learning

15.1 The Complaints Lead will maintain a secure register of complaint category, stage, timescales, outcome, remedy, equality or accessibility issues, safeguarding links and learning.

15.2 Complaint themes and overdue actions will be reviewed periodically. Corporate partners may receive only appropriately anonymised, aggregated information—not identifiable Member complaint content.

15.3 This procedure will be reviewed annually and following a serious complaint, material legal change, new service, new ADR arrangement or identified control failure.