Vexatious complaints policy

This policy describes the approach to be taken in the response to persistent and/or vexatious complaints received by the National Football Museum regarding its own work, staff and volunteers, and processes.

1. Introduction

  • The National Football Museum (the “Museum”) is committed to upholding the highest standards of behaviour, professionalism, and visitor experience. The Museum aims to ensure that every interaction reflects its values, respect for visitors, and dedication to delivering a high-quality and welcoming environment for all.
  • The Museum acknowledges that occasionally things may go wrong. In such cases, it is committed to investigating complaints thoroughly, providing clear and timely responses, and taking corrective action where necessary. This includes learning from mistakes and implementing improvements to help prevent similar issues from occurring in the future.
  • The Museum can only respond to complaints relating to its own staff, trustees, volunteers, processes, or activities.
  • This Vexatious Complaints Policy (this “Policy”) applies solely to unreasonable

/unreasonably persistent and/or vexatious complaints from external individuals, such as visitors. Internal (staff or trustees) complaints are to be addressed through the Grievance Policy. Volunteer concerns are to be addressed through the Volunteering Process.

  • On the whole, dealing with complaints is a simple process but there are a small number of complainants who because of the frequency, nature or tone of their contact with us, adversely affect our ability to deliver Museum activities and services. We will refer to these complainants, whether an individual or group, as ‘unreasonably persistent’ and/or vexatious and apply this policy.
  • For the purposes of this policy, unreasonable or unreasonably persistent complainants are those who make complaints that:
  • clearly do not have any serious purpose or value
  • are designed to cause disruption or annoyance
  • have the effect of harassing the Museum or can be easily seen as obsessive or unreasonable.

Some complainants may have justified complaints but pursue them in inappropriate ways. Others may pursue complaints which appear to have no substance or which have already been investigated.

  • Electronic copies of this Policy are available on the Museum’s website (the “Website”). The Website also contains contact details in the event that (i) any person is unable to download this Policy; and/or (ii) any person requires this Policy in another format, for example, large print. All requests will be considered on their merits on a case-by-case basis. In circumstances where an individual has been recognised as having an intellectual impairment, the Museum shall use all reasonable endeavours to communicate the contents of this Policy to such individual in the most appropriate

manner and form in liaison with the parents of, or other persons with legal responsibility (where appropriate) for such individual.

2. Scope

  • This policy should only be used in exceptional circumstances after all reasonable measures have been taken to try to resolve complaints under the Museum’s Complaints Procedure.
  • This Policy covers vexatious complaints about:
  • The standard of service received at the Museum or its Website;
    • Staff, trustee or volunteer conduct;
    • Accessibility and inclusion issues;
    • Facilities and exhibitions;
    • Breaches of Museum policies, procedures and expected behaviours (e.g. safeguarding, equality);
    • Data protection and privacy concerns; and
    • Any other issue that causes dissatisfaction or concern.
  • This Policy does not cover:
  • Complaints by staff, trustees or volunteers;
    • Freedom of Information or Subject Access Requests (these are handled under separate
    • procedures);
    • Complaints about third-party services (e.g. café franchisees or external events). The Museum will redirect you to the relevant provider.

3. Power to Change, Rescind or add to the Provisions of this Policy

  • In the event an issue arises that is not foreseen in this Policy, it will be addressed by the Museum in a manner that protects and promotes the objectives identified in this Policy.
  • The Museum is committed to reviewing this Policy periodically which may be amended from time to time by the Museum.
  • The Museum reserves the right to change, rescind or add to the provisions of this Policy at any time. Any such changes, rescinds or additions shall come into force and take effect upon the date specified by the Museum.

4. Definition of Vexatious and Unreasonable Complaints

  • Complainants or anyone acting on their behalf may be deemed to be vexatious, unreasonable or unreasonably persistent if one or more of the following applies:
    • Refusing to specify the grounds of a complaint, despite offers of help.
    • Being abusive, threatening or acting in a manner intended to intimidate staff, volunteers or trustees. This includes racist, sexist, homophobic or other discriminatory language.
    • Putting, or threatening to put, information on social media or websites that includes personal information of a member of staff, volunteer or trustees without their consent and/or making defamatory statements about individuals online.
    • Refusing to co-operate with the Museum’s Complaints Procedure.
    • Making what appear to be groundless complaints about the staff and/or trustee dealing with the complaint and looking to have them replaced.
    • Taking an excessive ‘scattergun’ approach – complaining officially to the Museum as well as raising the same complaint with other bodies such as the Charity Commission.
    • Changing the basis of the complaint as the investigation moves forward and/or denying earlier statements.
    • Raising trivial information and expecting this to be taken into account or raising lots of detailed but unimportant questions and insisting they are answered.
    • Electronically recording meetings and conversations without the prior knowledge and consent of the other people involved.
    • Making excessive demands on staff or trustees while a complaint is being dealt with.
    • Sending a high volume of letters, emails, social media messages and/or phone calls. Discretion must be used in determining the precise number and length of “excessive contacts” applicable under this section, using judgement based on the specific circumstances of each individual case.
    • Registering repeat complaints after the complaint has been fully investigated and completed, and/or if they have already exhausted other statutory routes of appeal.
    • Refusing to accept the final decision of a complaint and/or repeatedly arguing points with no new evidence.
    • Refusing to accept a complaint is outside the remit of the complaints procedure.
    • Persistently contact the Museum through different routes about the same issue.
    • Someone who is not looking to resolve a dispute but is looking to cause unnecessary difficulties or problems for the Museum.
    • Refusing to accept that matters aren’t within the Museum’s power to investigate if the matter is the responsibility of another organisation.
    • If a complainant isn’t happy with the outcome of their complaint and wishes to challenge it, this is not necessarily grounds to label them as ‘unreasonably persistent’.

5. Managing Vexatious and Unreasonable Complaints

  • Where and individual or group have been identified as unreasonably persistent and/or vexatious under the scope of this policy, taking account of the above criteria, the relevant SLT representative, in consultation with the CEO will determine what action to take. The SLT representative will implement such action and will notify individual/s, in writing, of the reasons why they have been classified as unreasonably persistent or vexatious and what action will be taken. They will also be notified of the review procedure under section 6 below.
    • This notification may be copied for the information of others already involved in the complaint or matters closely related to it, e.g. Members, staff. A record must be kept for future reference of the reasons why a individual has been classified as unreasonably persistent or vexatious.
    • SLT representative may decide to deal with complainants in one or more of the following ways.
      • Requesting contact in a specific format (e.g. by email only)
      • Placing limits on the number and duration of contacts with staff or trustees per week or month and offering a restricted time slot for necessary calls.
      • To restrict contact to liaison through a designated officer.
      • Requiring any personal contacts to take place in the presence of a witness and in a suitable location.
      • Refusing to deal with future correspondence on the same matter if a decision has already been reached.
    • The complainant/s will receive a copy of this policy with a covering letter explaining that the policy has been applied and how it will affect their contact with us. The letter will outline the length of time the restrictions will be in place and how they can ask for the restricted status to be reviewed at the end of this period.

6. Reviewing & Withdrawing of Vexatious Status

  • Once an individual or group has been determined as being a unreasonable and/or vexatious complainant, such status must be reviewed and, where appropriate, withdrawn at a later date. Such action may be appropriate where an individual/group subsequently demonstrates a more reasonable approach or submits a further complaint for which the normal complaints procedures would appear appropriate.
    • Individuals/groups also have an opportunity to apply to have their unreasonable and/or vexatious status withdrawn. The review process will be outlined in the notice.
    • The SLT representative, in consultation with the CEO will review their decisions to categorise an individual/group as unreasonable and/or vexatious initially after six

months. In addition, they will review that decision on receipt of a request to do so from the person/group categorised, provided such a request has not been received in the preceding six months or period of time as notified.

  • If the person/group categorised as unreasonable and/or vexatious is not satisfied with the decision reached by the Museum they may request that the decision is reviewed. Such a request for a review may only be received once in any six-month period or longer as notified in the review letter. Upon receipt of such a request, the SLT representative will review the decision, in consultation with the CEO. Notice of that decision will be given, as far as is practical, within 21 working days of receipt of the request.
    • On review, the SLT representative may either withdraw the categorisation of a person/group as unreasonable and/or vexatious if a more reasonable approach is being used by the complainant or amend the strategy being applied to that person. This may include extending the date of the review to 12 months if no improvement is identified and/ or the introduction of additional restriction(s). The review date may be extended further to 18 months if the review identifies a marked increase in nature and/ or frequency of their contact with the Museum.
    • If the SLT representative considers it appropriate to withdraw the status of unreasonable and/or vexatious complainant, normal contact with the individual and application of the Museum’s complaints procedure will be resumed. Notice of that decision will be supplied to the person or persons forthwith.