Using information from complaints to detect corruption

An effective complaints system that deals with complaints and reports made by customers or others outside an agency is an "essential part of the provision of quality service in the public and community sectors"1. It can also provide information that may be useful to an agency in the detection of corrupt conduct even if it does not specifically refer to corrupt conduct.

In a minority of cases, individual complaints may lead to further investigation which may uncover corrupt conduct. However, it is as a body of information that complaints data can be of most use to agencies in the detection of corrupt conduct. Agencies can review their complaints records to identify problematic trends, areas, functions or staff in the agency which may also warrant further investigation. 

Complaints or reports made by staff which are specifically about suspicions or evidence of corrupt conduct should be addressed in specific ways and are covered under the topic Internal reporting. 

What should an agency do?

Facilitate legitimate complaints

Agencies should take proactive steps to encourage and facilitate legitimate complaints. They should provide customers and clients with a simple and quick means of making a complaint which is well advertised, for example, by brochures, posters and on the agency's website.  Agencies should try to eliminate any barriers to complaints, for example staff who are unaware of the complaints process or who respond rudely or negatively to customers wishing to make a complaint.

Record complaints

It is important that complaints are recorded accurately and systematically for later analysis.  Enough detail should be captured to allow an appropriate level of analysis.

The critical data that needs to be captured in relation to each complaint is:

  • nature of the complaint
  • mode of the complaint, e.g. verbal or written
  • services or functions identified in the complaint
  • location of the complaint, e.g. unit or division
  • staff named or referred to in the complaint
  • root cause of the complaint
  • action taken in response to the complaint
  • systemic or procedural changes recommended to prevent or limit recurrences of the behaviour complained about.

Analyse and use complaint data

Agencies should regularly analyse their complaints data to identify trends, problematic staff, units, locations or functions, and other matters that might require further investigation. This analysis should be provided to senior management on a regular basis and should be used in the agency's corruption risk identification process.

External reporting

The complaints system should include a process for informing the principal officer about any complaints that relate to suspicions of corrupt conduct so that he/she can fulfil his/her obligation to report the matter to the ICAC under section 11 of the ICAC Act.2

Using information from grievances to detect corruption

Most staff grievances may not provide information which directly relates to corrupt conduct. However, as with customer complaints, an effective staff grievance system can provide information that may be useful to an agency in the detection of corrupt conduct. Many of the causes of staff grievances include behaviours that can indicate corrupt conduct, such as misuse of authority, perceived or actual unfairness and favouritism in such matters as recruitment and promotion, leave arrangements and allocation of overtime.3

What should an agency do?

As with customer complaints, agencies should ensure there is a simple, confidential and well advertised process in place for staff to lodge grievances. Information about grievances should be recorded accurately and systematically. 

Agencies should regularly review their grievances data to identify trends, problematic staff, units, locations or functions, or other matters that might require further investigation. This information should be provided to senior management on a regular basis and should be used in the agency's corruption risk identification process. Any grievances that relate to suspicions of corrupt conduct should be reported to the principal officer so that he/she can fulfil his/her obligation to report the matter to the ICAC under section 11 of the ICAC Act.

Case studies

Case study 1: Using complaints to detect corruption

In 2003 the ICAC  investigated aspects of safety certification and training in the NSW construction industry.  The ICAC's investigation focused on the conduct of:

  • a number of accredited assessors in carrying out competency assessments on operators of specified heavy plant and equipment
  • Occupational Health and Safety (OHS) induction training, and
  • training in the safe operation of cranes and plant in proximity to overhead power lines.

The ICAC's investigation disclosed deliberate and widespread abuse of the competency assessment regulations by six accredited assessors. The ICAC found evidence that these assessors had issued thousands of Notices of Satisfactory Assessment without having properly conducted the specified assessment procedures. The ICAC's investigation also disclosed that an accredited trainer and TransGrid employee had issued OHS induction training certificates in circumstances where no actual induction had taken place and had improperly manipulated training and certification practices designed to ensure the safe operation of cranes and other heavy plant operating near overhead power lines.

This investigation consistently demonstrated that WorkCover NSW failed to deal effectively with complaints, especially those concerning corrupt conduct, partly because it did not clearly differentiate between the two functions of audit and complaint investigations. The Certification Standards Unit (CSU) was tasked with competing responsibilities (including audits, assessor applications, technical questions and investigating complaints) and the inspectors had multiple, competing roles. The investigation of complaints in this setting gave way to other priorities and complaints-handling processes were deficient.

The ICAC's recommendations included that WorkCover NSW:

  • conduct a detailed fraud and corruption risk assessment of the certification system and develop a fraud prevention plan
  • develop and maintains a rigorous program of random site visits and re-testing of operator competence
  • amend the accident database to enable relevant training and certification information to be gathered in relation to licensed operators
  • provide training for assessors in ethical conduct
  • develop probity checks for potential assessors and accredited trainers
  • develop an Industry Code of Practice in conjunction with electricity authorities and the Department of Energy, Utilities and Sustainability.

Frequently asked questions

Complaints are just made by disgruntled customers. What can they tell us about corrupt conduct?

Complaints may well come from disgruntled or upset clients or other stakeholders. However, they can provide agencies with valuable information about specific acts of corruption or misconduct. They may also help identify poorly-functioning staff or divisions. Identifying and improving these poor practices could reduce the opportunity for corrupt conduct.


Publications – handling complaints

  • The Complaint Handler's Toolkit (2nd edition), NSW Ombudsman
  • Australian Standard AS ISO 10002-2006, Customer satisfaction – Guidelines for complaints handling in organizations, Standards Australia, 2006
  • Managing Unreasonable Complainant Conduct Practice Manual, NSW Ombudsman
  • Effective Complaint Handling (3rd Edition), NSW Ombudsman
  • Good Conduct and Administrative Practice: Guidelines for State and Local Government
  • Handling complaints, Public Sector Agencies fact sheet, NSW Ombudsman
  • Information to Providers, Health Care Complaints Commission, Sydney, undated
  • Investigating Complaints: A Manual for Investigators, NSW Ombudsman
  • Options for redress: Guidelines for Redress of Detriment Arising out of Maladministration, NSW Ombudsman


Relevant websites 


Relevant topics on the ICAC website



  1. Effective complaint handling, NSW Ombudsman, Sydney.
  2. Section 11 of the ICAC Act requires principal officers of NSW public authorities to report reasonable suspicions of corrupt conduct to the ICAC.
  3. Best practices – Staff administration, Independent Commission Against Corruption (Hong Kong), Hong Kong, 2003.