SQA Expected Behaviours Policy

Introduction

Every day, SQA staff engage with people outside of the organisation. These may be education practitioners, parents, candidates, appointees or other stakeholders. In the vast majority of cases, the people we interact with are courteous and positive — even if there is a measure of disagreement between us and them. However, sometimes this is not the case and other peoples’ behaviour falls below the standard expected. SQA classes instances like these as ‘unacceptable actions’.

This policy defines what is meant by an unacceptable action, and what staff members and managers are empowered to do as a response. The aim is to make it clear to everyone what behaviour is unacceptable and what will happen as a result.

Responsibilities

SQA cannot mandate how people outside the organisation behave. What we can do is define the types of behaviour we will and will not accept. It follows, of course, that to do this credibly, all our interactions, as members of SQA staff, with other people should avoid any behaviour or communication that would be considered an unacceptable action.

This means that all SQA staff members must meet these standards of behaviour, and must know what to do should they be faced with unreasonable behaviour in their role with SQA.

Line managers will be responsible for determining and dealing with actions when unacceptable behaviour is escalated to them, and this policy sets out the actions available to them and the steps they need to take.

Defining unacceptable actions

People may act out of character in times of trouble or distress. There may have been upsetting or distressing circumstances before an individual contacts us.

We do not view behaviour as unacceptable just because an individual is forceful or determined.

However, we do consider actions that result in unreasonable demands on our office, or unreasonable behaviour towards SQA staff, to be unacceptable. It is these actions that we aim to manage under this policy.

SQA has defined unacceptable actions under four broad headings:

Aggressive or abusive behaviour and language

We expect SQA staff members to be treated courteously and with respect. Violence or abuse towards us is unacceptable. We understand the difference between aggression and anger. However, it is not acceptable when anger escalates into aggression directed towards SQA staff members.

Violence is not restricted to acts of aggression that may result in physical harm. It also includes behaviour or language (whether oral or written) that may cause us to feel offended, afraid, threatened or abused. Examples of behaviours grouped under this heading include:

Language that is designed to insult or degrade, is racist, sexist or homophobic, or which makes allegations that individuals have committed criminal, corrupt or perverse conduct without any evidence is unacceptable.

We will judge each situation individually and decide whether the behaviour demonstrated is unacceptable.

SQA also considers that inflammatory statements containing unsubstantiated allegations can be abusive behaviour. However, SQA will ensure that whenever we are approached with concerns surrounding staff misconduct or centre malpractice, the concerns will be considered appropriately through our complaints, malpractice and employment procedures.

Examples of how we manage aggressive or abusive behaviour and language

The threat or use of physical violence, verbal abuse or harassment towards SQA staff is likely to result in a termination of all direct contact with the individual concerned. We may report incidents to the police. This will always be the case if physical violence is used or threatened.

SQA staff members will end telephone calls if they consider the caller to be acting in way that is aggressive, abusive or offensive. SQA staff members are entitled to make this decision, to tell the caller that their behaviour is unacceptable and end the call if the behaviour persists.

We will not respond to correspondence (in any format) that contains statements that are abusive. Where we can, we will return the correspondence. We will explain why we have done this, and say that we consider the language used to be offensive, unnecessary and unhelpful, and will ask the sender to stop using such language. We will state that we will not respond to their correspondence if the action or behaviour continues.

In extreme situations, we will tell the individual in writing that their name is on a ‘no personal contact’ list. This means that all contact about the matter they have raised with us will be through a representative.

Unreasonable demands

People may make what SQA considers unreasonable demands through the amount of information they seek, the nature and scale of service they expect, or the number of approaches they make. What amounts to unreasonable demands will always depend on the circumstances surrounding the behaviour and the seriousness of the issues raised.

Examples of actions grouped under this heading include:

SQA considers these demands as unacceptable if they start to impact substantially on the work of the office, such as taking up an excessive amount of time.

Unreasonable levels of contact

SQA recognises that some people will not, or cannot, accept that SQA is unable to assist them further or provide a level of service other than that provided already. They may continue to disagree with the action or decision taken in relation to their contact with us or contact SQA repeatedly about the same issue.

Examples of actions grouped under this heading include:

The way in which people approach SQA may be entirely reasonable, but it is their persistent behaviour in continuing to do so that is not. We consider that the level of contact is unacceptable when the amount of time spent talking to the person on the telephone, or responding to, reviewing and filing e-mails or written correspondence impacts on our ability to deal with that enquiry, or with other people’s enquiries.

Unreasonable refusal to co-operate

Sometimes we will need to ask the individual who has contacted us to co‑operate in providing information so that can resolve their query. This can include agreeing with us what their query is and what we will look at; providing us with further information, evidence or comments on request; or helping us by summarising their concerns or completing a form for us.

Sometimes, an individual repeatedly refuses to co-operate, and this makes it difficult for us to proceed. We will always seek to assist someone if they have a specific, genuine difficulty complying with a request. However, we consider that in most cases it would be unreasonable to contact us and then not respond to reasonable requests.

Right of review

An individual has the right to request a review of a decision to restrict contact, including where SQA removes contact. The review will only consider representations that relate to the restriction, and not to the initial reason they contacted us. Inform complaints@sqa.org.uk if an individual makes a request for a review.

A senior member of staff who was not involved in the original decision will be asked to review the decision. They will review the decision based on the evidence available to them, and will be asked to decide whether to confirm, end or vary the restriction. The senior member of staff will write to the individual to inform them of the outcome of the review. This can be supplemented with another form of communication if written communication is not the most appropriate form for the individual.

Expected behaviour and complaints

The same approach applies where an individual has made a complaint but is unhappy with the outcome. All complaints are managed through the complaints handling procedure. If a complainant remains dissatisfied following the conclusion of the complaints handling procedure, they can take their complaint to the Scottish Public Service Ombudsman (SPSO).

Our Expected Behaviours Policy allows us in limited circumstances to restrict access to SQA's complaints handling process entirely. This would be as a last resort, and should be as limited as possible (for a limited time, or about a limited set of subjects). It requires approval from the complaints manager to ensure that (a) this is a necessary and proportionate response; and (b) SQA is being transparent and clearly recording its reasons for restricting this customer's access. Where access to the complaint process is restricted, we must signpost the customer to the SPSO.

A complainant’s actions will be considered unacceptable if the complaints procedure has been exhausted but the complainant continues to dispute SQA’s decision regarding their complaint. The individual should be informed that no further phone calls or correspondence will be accepted concerning the complaint unless the complainant provides significant new information relating to the complaint.

Data protection

All records kept by SQA on incidents relating to application of the Expected Behaviours Policy form part of an individual’s personal information and can be requested by them via a Subject Access Request. This information will be provided by SQA in response to a Subject Access Request.