Complaints Policy

Company: Tyrogen Limited (16884876)
Owner: Operations / Customer Support
Approved by: Governing Body (or delegated authority per MD/GOVERNANCE/DELEGATION_OF_AUTHORITY.md)
Status: Draft (controlled policy)
Version: 0.1
Last updated: 2026-03-10
Next review: 2026-03-31

1) Purpose

To ensure complaints are handled fairly, consistently, promptly, and transparently, in a way that:

• protects learners and maintains confidence in Tyrogen’s assessment and service delivery
• supports continuous improvement through corrective and preventive action
• provides an accessible route for centres, employers, learners, and other stakeholders to raise concerns.

1.1 Ofqual alignment

This policy supports compliance with:

• D4 (responding to enquiries and complaints procedures)
• PR1 (fairness, integrity, openness, public confidence)

Where complaints indicate potential malpractice/maladministration or issues that could have an Adverse Effect, Tyrogen will route them into the relevant procedures and consider Ofqual notification requirements.

2) Definitions and related processes

For clarity, Tyrogen distinguishes between:

• Complaint: an expression of dissatisfaction about Tyrogen’s services, systems, processes, staff conduct, communications, or the aspects of centre operations within Tyrogen’s control.
• Appeal: a request to review a result or an assessment-related decision (see MD/POLICIES/APPEALS.md).
• Malpractice / maladministration report: an allegation of wrongdoing (deliberate) or process failure/error (negligent) in assessment delivery or administration (see MD/POLICIES/MALPRACTICE_AND_MALADMINISTRATION.md).

If an issue is submitted as a complaint but is better handled as an appeal or a malpractice/maladministration report, Tyrogen will redirect it to the appropriate process and will inform the complainant.

3) Scope (who can complain and what can be complained about)

This policy applies to complaints raised by:

• learners
• centres / providers
• employers
• invigilators / proctors (where applicable)
• other stakeholders who receive services from Tyrogen.

Complaints may relate to any aspect of Tyrogen’s operations within its control, including (non-exhaustive):

• customer support and service delivery
• platform availability, access, and usability
• administrative processes and communications
• assessment delivery arrangements (including proctoring logistics)
• the conduct of Tyrogen staff/contractors
• the operations of an approved centre, where the matter falls within Tyrogen’s approval/monitoring remit and the complainant has first exhausted the centre’s own complaints procedure.

4) Principles

Tyrogen will handle complaints in a manner that is:

• Fair and impartial: decisions based on evidence and documented rationale
• Timely: clear acknowledgement and response timeframes
• Transparent: clear explanation of outcomes and any remedy
• Confidential: information shared only on a need-to-know basis
• Accessible: reasonable steps taken to support complainants (see MD/POLICIES/REASONABLE_ADJUSTMENTS.md)
• Non-retaliatory: complainants will not be disadvantaged for raising a complaint in good faith.

5) When Tyrogen may not investigate / may close a complaint

Tyrogen will not normally investigate complaints:

• that are being, or have been, considered by a court, tribunal, or similar body
• submitted more than 30 calendar days after the matter being complained about (unless there is a clear and justified reason for delay)
• that are vexatious, malicious, or frivolous (see section 13)
• where the complainant is seeking a change to an assessment decision that should be progressed as an appeal.

Where Tyrogen declines to investigate, Tyrogen will record the decision and the rationale.

6) How to make a complaint (intake channels)

Complaints should be submitted via one of the following routes:

• Email: complaints@tyrogen.example
• In‑platform form: Tyrogen Platform (Complaints form)
• Post (optional): Tyrogen Limited — registered office address (as per Companies House)

If you need support to make a complaint (e.g., alternative formats, accessibility needs), contact us and we will provide reasonable assistance.

6.1 Information to include

To help Tyrogen triage and investigate effectively, please provide (where available):

• your name and contact details (unless making an anonymous complaint)
• your relationship to Tyrogen (learner / centre / employer / other)
• relevant identifiers (e.g., learner ID, centre number, order/reference number)
• the qualification/assessment/service the complaint relates to
• a clear description of the issue (what happened, when, where)
• what outcome you are seeking
• copies of any relevant correspondence or evidence (emails, screenshots, logs).

7) Informal resolution (Stage 0)

Where appropriate, Tyrogen may attempt to resolve issues informally (e.g., clarification, quick fix, correction of an administrative error). Any informal complaint and its outcome will still be recorded in the complaint log.

8) Formal complaints procedure

Tyrogen operates a two-stage formal complaints process.

8.1 Stage 1 — Complaint investigation and response

1. Acknowledgement: Tyrogen will acknowledge receipt within 2 working days.
2. Triage: the complaint will be categorised (e.g., service, assessment delivery, centre-related, data/privacy, etc.) and assigned an owner.
3. Investigation: Tyrogen will review the available evidence, speak with relevant parties, and assess whether policies/processes were followed.
4. Response: Tyrogen will issue a written response within 10 working days of acknowledgement (or explain why more time is needed and provide an updated target date).

The Stage 1 response will normally include:

• a summary of the complaint
• what was investigated and what evidence was considered
• the outcome (upheld / partially upheld / not upheld)
• any remedy/corrective action
• escalation rights (Stage 2) and how to request it.

8.2 Stage 2 — Escalation / review

If the complainant remains dissatisfied, they may request an escalation to Stage 2 within 10 working days of receiving the Stage 1 outcome.

• Stage 2 will be conducted by a more senior manager or a designated independent reviewer (i.e., not the original decision maker), subject to conflict-of-interest checks.
• Tyrogen will acknowledge the Stage 2 request within 2 working days and provide a written outcome within 20 working days.

Tyrogen may close the complaint at Stage 2 if it concludes that all issues have been appropriately considered and responded to. Where new material evidence emerges, Tyrogen may reopen the investigation.

9) Outcomes and remedies

Where a complaint is upheld (in full or part), Tyrogen will consider proportionate remedies, which may include:

• an explanation and apology
• correction of records or administrative errors
• service improvements (process changes, training, monitoring)
• where an assessment delivery failure is identified: steps to correct or mitigate impact on affected learners, and prevent recurrence.

10) Confidentiality, data protection, and information handling

Tyrogen will handle complaint information in line with applicable data protection requirements and internal access controls.

• Information will be shared only with those who need it to investigate and decide the complaint.
• Tyrogen is not obliged to disclose information where to do so would breach confidentiality, data protection obligations, or other legal duties.

11) Anonymous complaints

Tyrogen will consider anonymous complaints. However:

• anonymity may limit the ability to investigate and provide feedback
• Tyrogen may need to verify allegations through independent checks before approaching any individuals/centres.

Complainants who disclose their identity may request that Tyrogen does not reveal their identity to other parties. Tyrogen will respect such requests where practicable.

12) Complaints involving centres and employers

Where a complaint primarily concerns a centre/employer:

• complainants should normally first use the centre/employer’s own complaints procedure
• Tyrogen may request evidence that the centre/employer process has been exhausted
• Tyrogen will consider the matter only insofar as it relates to Tyrogen’s approval, monitoring, or assessment delivery responsibilities.

13) Vexatious, abusive, or persistent complainants

Tyrogen will not tolerate abusive, threatening, or harassing behaviour towards staff or contractors.

Tyrogen may treat complaints or contact as vexatious where, for example, a complainant:

• uses abusive or threatening language (in writing, by phone, or in person)
• repeatedly contacts Tyrogen within a short period without providing new information
• makes unreasonable demands outside the agreed scope of the investigation
• makes persistent accusations without evidence, or refuses to accept documented outcomes.

Where behaviour is deemed vexatious, Tyrogen may:

• restrict communication channels (e.g., written only)
• set reasonable boundaries on frequency of contact
• close the complaint with a written explanation.

Escalations relating to vexatious behaviour will be referred to the Compliance Lead (or RO where regulatory risk is indicated).

14) Records, reporting, and continuous improvement

Tyrogen will maintain a complaints record sufficient to support auditability and trend analysis, including:

• a complaint log (date received, category, owner, status, outcome)
• investigation notes and evidence references
• communications (acknowledgements, responses, escalation requests)
• corrective and preventive actions and closure verification.

Complaint trends will be reviewed quarterly to identify systemic issues and improvement opportunities.

15) External escalation (regulators and other bodies)

If a complainant remains dissatisfied after completing Tyrogen’s complaints and/or appeals processes, they may have the right to refer the matter to an external body as appropriate to the subject and regulatory framework.

• Primary regulator(s): Ofqual (where the matter falls within Ofqual’s remit)
• Other relevant body/bodies (where applicable): Information Commissioner’s Office (ICO) for data protection matters; other bodies as applicable to the qualification context.

Tyrogen will cooperate with legitimate external enquiries and will provide records where lawful and appropriate.

16) Associated policies and documents

• MD/POLICIES/APPEALS.md
• MD/POLICIES/MALPRACTICE_AND_MALADMINISTRATION.md
• MD/POLICIES/REASONABLE_ADJUSTMENTS.md
• MD/POLICIES/DOCUMENT_CONTROL.md

17) Change log