Operated by: Nudge Education Ltd · Version: Dec 2025 · Owner: Director of Operations
COMPLAINTS POLICY & PROCEDURE DEC 2025 Review date: DEC 2026
SCOPE
Nudge Education delivers bespoke interventions to support young people academically, socially and emotionally, helping them progress toward their next steps; whether that is reintegration into school, transition to a new provision, or entering the world of work. We strive to meet the highest standards in all aspects of our work and to provide an exceptional level of service through our trained professionals and resources.
However, we recognise that concerns may occasionally arise. This policy sets out the process to be followed when a young person, parent/carer, commissioning body or anyone else wishes to raise a complaint about any aspect of our services.
This Complaints Policy applies to all external stakeholders. Employees of Nudge Education should refer to the organisation’s Grievance Policy for matters relating to internal employment concerns.
This policy should also be read in conjunction with our Whistleblowing Policy, which outlines procedures for reporting serious concerns that fall outside the scope of this document.
STATEMENT OF INTENT It is vitally important to us that there are open lines of feedback for anyone to have their voice heard should they experience any problems whilst partnering with Nudge Education.
We place great value in learning from challenges and obstacles that we come across as this will allow us to improve our practices and make sure that we have a culture of openness and fairness in everything that we do.
We aim to address complaints and feedback as swiftly as possible to ensure the person making the complaint is reassured we are striving to improve their situation.
We strongly believe in the power of human connection and believe that open conversation can resolve many uncertainties or queries. This policy relates to a party wishing to make a formal complaint if an informal resolution has not been reached.
COMPLAINTS PROCEDURE A flowchart of this process is in Appendix A
A complaint should be made within a reasonable timeframe as to allow us to gather valid information. To this extent, we may not recognise a complaint made after three months of an incident or grievance occurring.
If the complaint relates directly to a commissioning body rather than Nudge Education, we will advise you to contact them directly.
We have two methods of making a complaint at the time this policy has been written:
Email: Contact talktonudge@nudgeeducation.co.uk
Writing: Send a letter to the Nudge Education office at:
FAO: Complaints at Nudge Education 2 Sirius House Amethyst Road Newcastle Upon Tyne NE4 7YL
We will not respond to any complaints in a public forum such as social media platforms.
We will respond in writing or by email and may call or arrange a meeting to gather further clarifications if required.
We will always make a written log of formal complaints for our own quality assurance and compliance purposes. These will be stored on a secure system with limited access to the documents.
We will initially respond within ten working days of a complaint being received as this will allow us time to investigate and collect relevant information. If the investigation cannot be concluded within this timeframe, a holding response will be sent out giving an update and estimated date of final response.
As part of the investigation, we will need to speak with the complainant directly. If the complainant is a young person, we would always ask that they be accompanied by an independent advocate or family member/carer where appropriate.
If an advocate cannot be sought, we would look to delay the investigation until one is found. Local independent advocacy services can be found online or by speaking with your local authority social services commissioning team.
The person(s) who undertakes the investigation will be completely independent of the matters related to the complaint.
On completion of the investigation, the lead investigator will communicate the outcome of the complaint to the complainant as either:
- Upheld
- Partially Upheld
- Not Upheld
This outcome will be communicated in writing.
Where the outcome will lead to disciplinary or similar actions, there may be a restricted response due to confidentiality issues.
STAGES OF THE COMPLAINT PROCESS
Stage 1 of the complaint process is triggered on the day that a Regional Lead receives the complaint. The Regional Lead then begins the initial investigation and will respond to the complainant within 10 working days. The Regional Lead then confirms with rationale whether the complaint is Upheld, Partially Upheld or Not Upheld.
If the complainant is not satisfied with the confirmed outcome at stage 1, they have 10 working days to escalate a challenge. If we receive written and/or email confirmation challenging the complaint outcome, this is then escalated to the Operations Manager/Service Manager as appropriate to investigate and respond. If 10 working delays elapse without response, the Regional Lead will close the complaint.
Stage 2 of the complaint process is triggered on the day (via writing or an email), the relevant Regional Lead receives the challenge to the initial Stage 1 decision. The Operations Manager/Service Manager will then have 10 working days to investigate this escalated complaint. The Operations Manager/Service Manager then confirms with rationale whether the complaint is Upheld, Partially Upheld or Not Upheld.
Stage 3 of the complaint process is triggered on the day (via writing or an email) the relevant Operations Manager/Service Manager receives the challenge to the initial Stage 2 decision. The Operations Director/Director of Partnerships will then have 10 working days to investigate this escalated complaint. The Director then confirms with rationale whether the complaint is Upheld, Partially Upheld or Not
Upheld.
This ends the internal complaints process.
What to do if you remain dissatisfied (External Escalation) Stage 3 marks the end of Nudge Education’s internal complaints process. If you feel your complaint has not been resolved to your satisfaction after this final review, you have the right to escalate your concerns externally. Depending on the nature of your complaint, you may contact the following external or regulatory bodies:
- The Commissioning Body: Because Nudge Education delivers commissioned services, you may escalate your concerns to the specific body that funded and requested the intervention (e.g., the Local Authority, Virtual School, or referring mainstream school).
- The Local Authority Designated Officer (LADO): For unresolved complaints regarding safeguarding concerns, child protection, or the professional conduct of a staff member towards a child or young person.
- The Information Commissioner’s Office (ICO): For unresolved complaints regarding data protection, privacy, or the handling of your personal information
ACCESSIBILITY OF POLICY
This policy is openly available via our website to young people, parents (including Corporate Parents for Looked After Children), carers, commissioners and associates of Nudge Education as well as any representatives from Awarding Bodies (e.g. ASDAN, NCFE, City & Guilds) and Regulatory Bodies (such as OFSTED or ISI).
Appendix A - Flowchart of Complaints and Appeals Process
STAGE 1
STAGE 2
STAGE 3
STAGE 4
This policy has been signed off by the Nudge Education Directorate. Charlotte Noutch Director of Partnerships & Services 5 Dec 2025
NEO Online Addendum
This addendum applies the canonical Nudge Education policy above to the online provision context of Nudge Education Online (NEO). It is sourced from NEO - Complaints Procedure v04.26.docx.
NEO BY NUDGE EDUCATION
Complaints Procedure Nudge Education Online
| Policy Owner | Director, Nudge Education Online & Head of School |
|---|---|
| Approved | April 2026 |
| Review Date | April 2027 |
| Version | 04.26 |
| Operating Company | Nudge Education Ltd (Company Number 10192753) |
| Proprietor | Diego Melo |
| Accreditation Route | Online Education Accreditation Scheme (OEAS) — accreditation in progress |
This policy applies to all learners, staff, practitioners, contractors, volunteers and visitors of Nudge Education Online (NEO). NEO is a fully online alternative provision for learners aged 11–18, operated by Nudge Education Ltd. NEO is not a DfE-registered independent school and is not subject to Independent Schools Inspectorate (ISI) inspection. NEO is pursuing OEAS accreditation only.
1. Policy Statement and Purpose
Nudge Education Online (NEO) is committed to listening to learners, parents and carers, and commissioning partners. NEO welcomes feedback and treats complaints as an opportunity to learn, improve, and strengthen trust. This procedure provides a clear, fair, and accessible route for raising and resolving concerns. It is designed to meet OEAS accreditation expectations for complaints handling and to satisfy commissioner due diligence. NEO aims to: Resolve concerns quickly, informally, and at the earliest possible stage. Handle formal complaints thoroughly, fairly, and transparently. Ensure that complainants are not penalised for raising legitimate concerns. Use the outcomes of complaints to improve NEO’s provision and practice. NEO is not a DfE-registered independent school and is not subject to ISI inspection. Accordingly, references below to ISI as an external escalation route do not apply to NEO; the relevant external routes are listed in Section 7.
2. Scope
This procedure applies to complaints from parents, carers, learners, and external partners including local authorities and referring schools. It covers complaints about NEO’s provision, policies, staff conduct, or the application of NEO procedures. It does not apply to staff employment matters, which are covered under the NEO Grievance and Disciplinary Policy (in development). Safeguarding concerns must be referred directly to the Designated Safeguarding Lead (DSL) and are handled under the NEO Child Protection and Safeguarding Policy, not under this procedure. Complaints about the Proprietor should be raised in writing to the DSL, who will consult independently and determine how the complaint is investigated, ensuring no conflict of interest. Complaints about the Director / Head of School should be raised in writing to the Proprietor.
3. Summary of Stages
| Stage | What Happens | Timeline |
|---|---|---|
| Informal Resolution | Concern raised with the relevant member of staff, the learner’s named practitioner, or the DSL. NEO aims to resolve the issue promptly through dialogue. | As quickly as possible |
| Stage 1: Formal Complaint | Written complaint submitted to the Director / Head of School. Acknowledged within 5 working days. Investigation and written response provided. | Response within 20 working days |
| Stage 2: Panel Hearing | Complainant requests a hearing before a panel of at least three people, including one member independent of NEO’s management and governance. | Hearing within 20 working days of request; decision within 10 working days of the hearing |
| Further Escalation | If still unresolved, the complainant may escalate to an appropriate external body (see Section 7). | No fixed timeline |
4. Informal Resolution
NEO encourages parents, carers, and learners to raise concerns as early as possible so that they can be resolved quickly and informally. Many concerns can be addressed through a conversation with the relevant member of staff or the learner’s named practitioner. Concerns may be raised: By email or telephone to the relevant member of staff, the named practitioner, or the DSL. During a scheduled review meeting or parent consultation. Via NEO’s general contact email (neo@nudgeeducation.co.uk). The member of staff will aim to acknowledge the concern within two working days and to resolve it as quickly as possible, keeping the parent or carer informed throughout. If the concern cannot be resolved informally, or if the complainant is not satisfied with the outcome, they may proceed to Stage 1.
5. Stage 1: Formal Written Complaint
If the concern has not been resolved through informal discussion, the complainant may submit a formal complaint in writing to the Director / Head of School (or a nominated senior member of staff). The complaint should include: The complainant’s name and contact details. A clear description of the concern or complaint. What has already been done to try to resolve it. What outcome the complainant is seeking. Complaints may be submitted by email or letter. NEO will provide assistance with putting a complaint in writing if requested.
5.1 Acknowledgement
The Director / Head of School (or nominee) will acknowledge receipt of the complaint in writing within five working days. The acknowledgement will confirm who is investigating the complaint and the expected timeline for a response.
5.2 Investigation
The investigating officer will: Review all relevant information and records. Speak with the complainant to clarify the concern if necessary. Speak with any staff, learners, or other parties relevant to the complaint. Consider the complaint in the context of NEO’s policies and procedures. The investigation is conducted impartially and without prejudice.
5.3 Response
A written response is provided within 20 working days of receipt of the formal complaint. The response will include: A summary of the complaint as understood by NEO. The findings of the investigation. The conclusion and the reasons for it. Any actions NEO will take as a result. Information about how to escalate the complaint to Stage 2 if the complainant is not satisfied.
6. Stage 2: Panel Hearing
If the complainant is not satisfied with the outcome of Stage 1, they may request a panel hearing by writing to the Director / Head of School within 10 working days of receiving the Stage 1 response.
6.1 Panel Composition
The panel consists of at least three people who have not been directly involved in the matters detailed in the complaint. At least one member of the panel is independent of NEO’s management and governance. NEO takes reasonable steps to ensure that the independent member has no connection to NEO that might compromise their impartiality.
6.2 Hearing Arrangements
The panel hearing is convened within 20 working days of the request. As NEO is a fully online provision, hearings are normally conducted via Google Meet unless the complainant requests an alternative arrangement. Reasonable adjustments are made where needed. The complainant is informed in advance of: The date, time, and format of the hearing. The names and roles of the panel members. Their right to be accompanied by a friend, family member, or advocate (but not a legal representative acting in that capacity). The procedure to be followed during the hearing.
6.3 The Hearing
At the hearing: The complainant is invited to explain their complaint and the outcome they are seeking. NEO presents its response and the findings of the Stage 1 investigation. The panel may ask questions of both parties. Both parties have the opportunity to make a closing statement.
6.4 Panel Decision
The panel reaches a decision and communicates it in writing to the complainant within 10 working days of the hearing. The written decision includes: A summary of the complaint and the issues considered. The panel’s findings of fact. The panel’s conclusion, with reasons. Any recommendations or actions NEO should take. The panel’s decision is the final stage of NEO’s internal complaints procedure.
7. Further Escalation
If the complainant remains dissatisfied after the panel hearing, they may escalate their complaint to the appropriate external body. Depending on the nature of the complaint, this may include: OEAS (Online Education Accreditation Scheme) — for complaints about NEO’s compliance with OEAS accreditation criteria, once NEO is an accredited member. The Department for Education (DfE) — for complaints relating to statutory duties applicable to alternative provision. The relevant local authority — for complaints relating to a commissioned placement or EHCP provision. The Information Commissioner’s Office (ICO) — for complaints about data protection, privacy, or children’s data rights under the ICO Children’s Code. The First-tier Tribunal (SEND) — for appeals relating to EHCP decisions. Ofcom — for complaints relating to online safety obligations under the Online Safety Act 2023. The Disclosure and Barring Service (DBS) — for concerns about the suitability of adults working with children. NEO will provide, on request, contact details for the appropriate external body.
8. Timeframes
NEO is committed to responding to complaints within the published timeframes. Where a complaint is particularly complex and a longer investigation period is needed, NEO notifies the complainant in writing, explains the reason for the delay, and provides an updated timeline.
9. Serial or Unreasonable Complaints
NEO is committed to dealing with all complaints fairly and respectfully. However, where a complaint has been fully investigated and the complaints procedure has been exhausted, NEO is not obliged to reinvestigate the same complaint. Where a complainant’s behaviour becomes unreasonable, abusive, or places undue demands on staff, the Proprietor or the Director / Head of School may invoke NEO’s procedure for managing unreasonable complaints. This may include: Limiting the complainant to a single named point of contact. Restricting the method of communication (for example, written only). Declining to engage with further correspondence on the same matter. Any decision to restrict contact is communicated in writing with a clear explanation of the reasons and a route for review.
10. Confidentiality
All complaints are handled with discretion. Information about a complaint is shared only with those who need to know in order to investigate and resolve it. NEO complies with UK GDPR, the Data Protection Act 2018, and the ICO Children’s Code in all handling of complaint-related data. Complainants should be aware that where a complaint involves allegations about a specific member of staff, NEO has a duty of care to that individual as well as to the complainant. Information about the investigation and its outcome may be shared with the staff member concerned.
11. Record Keeping
All formal complaints (Stage 1 and above) are logged in the NEO complaints register. The register records the date, subject, stage reached, outcome, and any actions taken. Records are retained for a minimum of three years in line with NEO’s retention schedule. The Proprietor reviews anonymised complaint data annually to identify patterns and inform NEO improvement planning. The number of complaints registered under the formal procedure during the preceding academic year is made available to OEAS on request.
12. Complaints from Learners
NEO takes learner voice seriously. Learners are encouraged to raise concerns and are supported to do so. Concerns from learners may be raised: Directly with a trusted member of staff, their named practitioner, or the DSL. Via NEO’s anonymous reporting routes. Through a parent, carer, or advocate on their behalf. Where a learner wishes to make a formal complaint, NEO provides age-appropriate support and ensures that the process is accessible and not intimidating. The learner may be accompanied by a parent, carer, or other trusted adult at any stage.
13. Complaints About Safeguarding
Complaints that include a safeguarding allegation are referred immediately to the DSL and handled in accordance with the NEO Child Protection and Safeguarding Policy. The complaints procedure is paused where necessary to allow safeguarding processes to take priority. The complainant is kept informed to the extent possible without compromising the safety of any child.
14. Monitoring and Review
The DSL conducts a termly review of the complaints log to identify patterns and ensure that responses have been proportionate and timely. The Proprietor reviews complaints data annually as part of OEAS-aligned governance oversight. This procedure is reviewed annually, or sooner if statutory guidance or OEAS criteria change. The procedure is made available to parents on request, provided at admission, and published on the NEO website.
Related Policies
This policy should be read alongside: NEO Child Protection and Safeguarding Policy NEO Behaviour and Regulation Policy NEO Data Protection, Confidentiality and Privacy Policy NEO Equal Opportunities, Equality and Diversity Policy NEO SEND Policy NEO Admissions Policy NEO Online Safety and Acceptable Use Policy NEO Terms and Conditions
Document Control
| Version | 04.26 |
|---|---|
| Approved | April 2026 |
| Next Review | April 2027 |
| Owner | Director, Nudge Education Online & Head of School |
| Approver | Proprietor (Diego Melo) |
| Operating Company | Nudge Education Ltd (Company Number 10192753) |
Document control
| Field | Value |
|---|---|
| Version | Dec 2025 |
| Owner | Director of Operations |
| Status | live |
| Source file | 1. All Company/Complaints Policy - Dec 25.docx (2).pdf |