How to make a complaint about your provider
If you have a concern about your treatment
Every practitioner and clinic on the Treatments You Can Trust Register is there to serve you well and honestly.
Sometimes you may have a concern about the way you were treated. We tell you here how we ensure you are heard and a fair result is achieved.
What we do at Treatments You Can Trust in relation to complaints
We register practitioners of injectable cosmetic substances who are already licensed by a regulator set up by Parliament – the General Medical Council (GMC); the General Dental Council (GDC); and the Nursing and Midwifery Council (NMC) – together known as the professional regulators. As an officially Accredited Register joined voluntarily by practitioners, we do not have our own powers to remove a practitioners professional license, but we do take account of the statutory disciplinary powers of the regulators set up by Parliament. We do have the powers to:
- Informally Advise practitioners if they involuntarily transgress our Standards - and then inspect the remedy they have used.
- Formally warn practitioners when they have deliberately or recklessly transgressed our Standards; and keep a record of the warning for a time; and check the remedy they have used is appropriate. We may tell other Accredited Registers of the warning.
- Report a transgression of our Standards to the statutory Regulator if we perceive that the practitioner has transgressed the terms of his professional license. The matter may then be investigated by the professional regulator under the "Fitness to Practice" procedures. The professional regulators have powers to prevent further harm to the public resulting from the practitioner’s conduct. TYCT will take account of the outcome of any investigations when deciding about registration.
- Remove a practitioner from the Treatments You Can Trust Register. We would do this if a practitioner was no longer approved by the professional regulator for injectable cosmetic interventions; or has grossly transgressed our Standards such that TYCT and those remaining on the Register will be brought into disrepute.
We set the Standards for practitioners to achieve if they are to be registered with us. This is our Standard for complaints. If your practitioner is on our Register, he or she will meet this Standard. Our Standard says:
Standard: Patients are assured that an appropriate complaints handling process is in place.
- 7.1. There is a written policy and procedure for investigating and handling complaints about any aspect of the service/ treatment/ facility. This includes how to raise a concern, timeframes for responding to the complainant and the details of how to contact the appropriate professional regulatory body if the complaint cannot be resolved locally.
Guidance: Systems are in place to ensure that complaints from patients are handled and investigated and that information about services arising from complaints is used to improve quality. Where a complaint cannot be resolved quickly and locally, practitioners on the TYCT Register have access to the Centre for Effective Dispute Resolution (CEDR)/TYCT scheme for external resolution, which also provides review and learning opportunities.
- 7.2. Staff receive training in handling complaints. Attendance at training is recorded.
Guidance: All staff are trained in the skills necessary to respond to complaints at the time it is made. Complaints training records are kept.
- 7.3. A register of all complaints is kept updated and regularly reviewed.
Guidance: This should include what actions have been taken to address the issues raised. Collated records are kept of all complaints, and the records include responses to the patient/person who complained, the results of the investigations and actions taken in response.
- 7.4. Patients are routinely provided with written information on how to make a complaint, suggestion or comment.
Guidance: Leaflets or posters should be displayed in waiting areas informing patients of the complaints process.
- 7.5. Complaints and their outcomes are regularly discussed at staff team meetings.
Guidance: The organisation should show how it learns and uses the outcome of complaints to continually improve the quality of services treatment and care.
Some clinics whose practitioners are registered with TYCT will follow the Code of Conduct of the Independent Sector Complaints Adjudication Service (ISCAS). This Code meets our Standards. It will be explained to you if you decide to complain, but briefly, it offers 3 stages, from first clinic, then to Head office, and finally independent adjudication by an appropriately qualified person.
The EU (Alternative Disputes Resolution for consumer disputes) Regulations 2017 (ADR) took effect 1 April 2017 and now form part of our Standard.
Every public-facing business is required to show a written complaints policy that provides for a fair and impartial resolution procedure that can be brought into play if the provider and the consumer cannot reach agreement.
Your Mediation Route
TYCT now requires that practitioners registered with us should offer mediation by the impartial Centre for Effective Dispute Resolution (CEDR) if they cannot obtain mutual agreement with you.
We require mediation to be offered because in our experience this is the quickest way of settling a dispute about an elective procedure undertaken for payment – a consumer choice. It costs you nothing, and is therefore cheaper than resorting to law.
If mediation is not a suitable choice, then go to "What if your complaint (about anyone on the TYCT Register) is not suitable for adjudication (if offered) or mediation?" below.
What is mediation?
Mediation is an informal process for settling disputes through direct negotiations. A trained mediator contacts the parties directly, usually by telephone, to attempt to facilitate mutually acceptable resolution to the complaint. Any settlement reached through mediation will become binding as a contractual agreement.
There are three stages at which you may obtain a mediated outcome to your complaint.
- First you should, without delay, tell the clinic or practitioner of your cause for concern and be willing to seek a mutually satisfactory outcome. If the complaints protocol is not explained to you as soon as you start to make a complaint, then you should instead complain immediately direct to TYCT. See What if your complaint (about anyone on the TYCT Register) is not suitable for adjudication (if offered) or mediation? below
- Secondly, if you and your clinic or practitioner cannot agree, then your practitioner undertook when admitted to the TYCT Register to put your concern to its Head office. The intention of this is to give a review by someone independent of the practitioner and an opportunity to settle at a higher level of responsibility. This process should take no more than 20 days. If there is no Head office, then the clinic should ask us at Treatments You Can Trust. We will provide an independent mediator to negotiate an equitable outcome. We inform you and the practitioner how to proceed within 3 working days.
- Thirdly, in the unlikely event that mediation does not produce a result acceptable to both parties, then you should refer the matter to the TYCT Governance Board by informing TYCT Executive:
- by post to: Treatments You Can Trust, Keswick House, Langstone Avenue, Havant, PO9 1RU
- or by telephone to 02392 483 406.
- The Treatments You Can Trust Governance Board will, after obtaining your undertaking to accept our conditions below, refer your complaint to the Centre for Effective Disputes Resolution (CEDR) whose expert mediators will facilitate further dialogue between you and the clinic and help both parties find a suitable settlement of the issues. The service is free of charge to you.
- Our conditions are:-
- You accept the CEDR Treatments You Can Trust Conciliation Rules - (PDF 109 KB)
- You accept that any settlement reached is legally binding once it has been put into writing and signed by the parties.
- You understand that applications related to disputes that are, or have been, subject to court action or Alternative Disputes Resolution provided by another body, cannot be accepted.
- You understand that Mediation by CEDR is the final stage in resolving a dispute under Treatments You Can Trust arrangements.
- You understand that the TYCT has adopted the Independent Healthcare Sector Complaints Adjudication Service (ISCAS) Guidance for managing unacceptable behaviour by complainants.
- You know that nothing in these arrangements prevents you from resorting to law.
Further information for those in dispute
- Independent Healthcare Sector Complaints Adjudication Service (ISCAS)
The ISCAS Code will be followed by some practitioners’ clinics and meets TYCT Standards.
- Centre for Effective Dispute Resolution (CEDR)
CEDR is a London-based mediation and alternative dispute resolution body. It was founded as a non-profit organisation in 1990, with the support of The Confederation of British Industry (CBI) and a number of British businesses and law firms, to encourage the development and use of Alternative Dispute Resolution (ADR) and mediation in commercial disputes. It is entirely independent of both your clinic and Treatments You Can Trust.
- What is mediation?
Mediation is an informal process for settling disputes through direct negotiations. A trained mediator contacts the parties directly, usually by telephone, to attempt to facilitate mutually acceptable resolution to the complaint.
- Who are the mediators working with CEDR?
The mediators have all been trained and accredited under CEDR Mediator skills training course to be professional mediators. CEDR Accreditation is internationally recognised as the standard of excellence.
What if your complaint (about anyone on the TYCT Register) is not suitable for adjudication (if offered) or mediation?
We expect mediation to address all normal consumer concerns. Examples that we envisage mediation (or adjudication) is NOT appropriate include: allegations of criminal intent (e.g., false claim to be statutorily registered); illegal offer of drugs; tax evasion; illegal employment; unsubstantiated claims to quality; selling prescriptions for drugs; concerns about a person not on the TYCT Public Register; Abuse of trust; dishonest business practice; professional incompetence; incapacity resulting from substance misuse; criminal acts or convictions; findings by a statutory regulator; concerns about an employer or his practices.
If you believe that your complaint may fall into this category, you should, as soon as your concern is substantiated and within 6 months of your treatment or symptomatic appearance write confidentially to TYCT with your case and providing the following information:
- Your Full name
Full address, email, telephone, and mobile telephone
Full Name of practitioner and, if known, his/her registration number with GMC, GDC or NMC
Full address where you received treatment
Name of clinic
Date(s) of treatment
Type of treatment (Botulinum toxin, dermal fillers, or both)
You may also email or telephone us with the same information.
If you need help, we will accept a complaint from you made by another person on your behalf with your approval. We will acknowledge receipt of your communication within 5 working days. We may call you to enquire further if there are things we think need clarification. We will keep your complaint private to ourselves and share only with anyone else that we find has a need to know in order to resolve the allegation. We may need to enquire with the clinic or practitioner you complain about. Unless you expressly permit us to release your name, we will preserve your anonymity. We will endeavour to keep you informed during investigation, and of the outcome.
We will then decide if the matter complained about may be remedied by one of the sanctions available to us - Advise, warn, refer or remove.
If it seems to us after investigation that none of these would be an appropriate remedy, we may refer the matter to one or more authorities with appropriate powers to ensure that public safety and good order are maintained. Examples include the Medicines and Healthcare Regulation Agency (MHRA); a professional regulator; the police.
If we believe that the matter can be resolved within the sanctions available to Treatments You Can Trust, we will convene the Treatments You Can Trust Governance Board either in person or in remote session to consider what action may be appropriate to provide resolution. The Governance Board will appoint a sub-group of its members to investigate your complaint and to report back to the full Board. We will inform you of the outcome of your complaint. The decision of the Treatments You Can Trust Governance Board is final.
What if your complaint is about the professional conduct of your practitioner?
You have the right to refer your complaint against a practitioner (but not a clinic) straight to a statutory Professional Regulator (ie, General Medical Council; General Dental Council; Nursing and Midwifery Council). We may also do this ourselves during our investigation of your complaint if we think that what you have told us merits doing so.
These links also allow you to check your practitioner’s statutory registration details.
- To check Doctors - General Medical Council (GMC)
- To check Dentists - General Dental Council (GDC)
- To check Registered Nurses - Nursing and Midwifery Council (NMC)
What if your complaint is about TYCT
TYCT expects that, if anyone has a complaint or concern about TYCT actions, this will first be put to TYCT for local resolution. If the complaint is about the TYCT executive, it will be referred to the Chair or Deputy Chair of the Treatments You Can Trust Governance Board. If a complaint against actions by TYCT cannot be settled between the parties, TYCT will, with the agreement of the complainant, refer the matter to the independent Centre for Effective Dispute Resolution (CEDR) for mediation. If the subject matter is inappropriate to resolution by mediation, or mediation fails, then it will be referred to the Professional Standards Authority (PSA).
PSA states that "if you are unhappy with the way that TYCT handled your complaint or another part of its role and think it does not meet our standards you can Contact Us".
Note: PSA do not consider complaints about individuals on the TYCT Accredited Register, as PSA expect TYCT to handle these concerns.