{"id":18918,"date":"2021-11-23T12:34:16","date_gmt":"2021-11-23T12:34:16","guid":{"rendered":"https:\/\/bant.org.uk\/?page_id=18918"},"modified":"2025-08-27T15:06:36","modified_gmt":"2025-08-27T14:06:36","slug":"complaints","status":"publish","type":"page","link":"https:\/\/bant.org.uk\/bant-professional-practice-handbook\/complaints\/","title":{"rendered":"COMPLAINTS"},"content":{"rendered":"<p>[vc_row css_animation=&#8221;&#8221; row_type=&#8221;row&#8221; use_row_as_full_screen_section=&#8221;no&#8221; type=&#8221;full_width&#8221; angled_section=&#8221;no&#8221; text_align=&#8221;left&#8221; background_image_as_pattern=&#8221;without_pattern&#8221; el_id=&#8221;top-section&#8221; z_index=&#8221;&#8221; css=&#8221;.vc_custom_1619334407087{padding-bottom: 45px !important;}&#8221;][vc_column][vc_raw_html]JTVCcHJpbnRmcmllbmRseSU1RA==[\/vc_raw_html][vc_column_text]Different complaint procedures are in place for complaints made against members in their roles of Registered Nutritional Therapy Practitioner (NT) and BANT Registered Nutritionist\u00ae (BANT RN). If a member suspects a complaint is going to be made against them, or if they know a complaint has been made, they are advised to contact the PPP. To enable the PPP to support the NT with complaints to the CNHC or another statutory regulatory body, permission needs to be granted from the complainant for the PPP to view complaint, or the information needs to be anonymised. Details of how to do this are covered here along with the BANT Complaint Record Retention Policy.[\/vc_column_text][\/vc_column][\/vc_row][vc_row css_animation=&#8221;&#8221; row_type=&#8221;row&#8221; use_row_as_full_screen_section=&#8221;no&#8221; type=&#8221;full_width&#8221; angled_section=&#8221;no&#8221; text_align=&#8221;left&#8221; background_image_as_pattern=&#8221;without_pattern&#8221; z_index=&#8221;&#8221; anchor=&#8221;main_anchor1&#8243;][vc_column]\n\n\t<a href=\"#complaints-and-disciplinary-procedures\" target=\"_self\"  class=\"qode-btn qode-btn-medium qode-btn-solid qode-btn-icon anchor qode-btn-with-shadow qode-btn-default-hover\"  >\n\t    <span class=\"qode-btn-text\">Complaints &amp; Disciplinary Procedures<\/span><span class=\"qode-button-v2-icon-holder\"  ><i class=\"qode_icon_font_awesome fa fa-arrow-circle-down qode-button-v2-icon-holder-inner\" ><\/i><\/span>\t<\/a>\n\n[vc_separator type=&#8221;transparent&#8221; thickness=&#8221;5&#8243; up=&#8221;2&#8243; down=&#8221;2&#8243;]\n\n\t<a href=\"#informing-the-ppp-of-a-complaint-or-investigation\" target=\"_self\"  class=\"qode-btn qode-btn-medium qode-btn-solid qode-btn-icon anchor qode-btn-default-hover\"  >\n\t    <span class=\"qode-btn-text\">Informing the PPP of a Complaint or Investigation<\/span><span class=\"qode-button-v2-icon-holder\"  ><i class=\"qode_icon_font_awesome fa fa-arrow-circle-down qode-button-v2-icon-holder-inner\" ><\/i><\/span>\t<\/a>\n\n[vc_separator type=&#8221;transparent&#8221; thickness=&#8221;5&#8243; up=&#8221;2&#8243; down=&#8221;2&#8243;]\n\n\t<a href=\"#anonymising-client-data\" target=\"_self\"  class=\"qode-btn qode-btn-medium qode-btn-solid qode-btn-icon anchor qode-btn-default-hover\"  >\n\t    <span class=\"qode-btn-text\">Anonymising Client Data<\/span><span class=\"qode-button-v2-icon-holder\"  ><i class=\"qode_icon_font_awesome fa fa-arrow-circle-down qode-button-v2-icon-holder-inner\" ><\/i><\/span>\t<\/a>\n\n[vc_separator type=&#8221;transparent&#8221; thickness=&#8221;5&#8243; up=&#8221;2&#8243; down=&#8221;2&#8243;]\n\n\t<a href=\"#complaint-record-retention-policy\" target=\"_self\"  class=\"qode-btn qode-btn-medium qode-btn-solid qode-btn-icon anchor qode-btn-default-hover\"  >\n\t    <span class=\"qode-btn-text\">Complaint Record Retention Policy<\/span><span class=\"qode-button-v2-icon-holder\"  ><i class=\"qode_icon_font_awesome fa fa-arrow-circle-down qode-button-v2-icon-holder-inner\" ><\/i><\/span>\t<\/a>\n\n[vc_separator type=&#8221;transparent&#8221; thickness=&#8221;30&#8243;][vc_row_inner row_type=&#8221;row&#8221; type=&#8221;full_width&#8221; text_align=&#8221;left&#8221; css_animation=&#8221;&#8221; anchor=&#8221;complaints-and-disciplinary-procedures&#8221; el_class=&#8221;anchordiv&#8221;][vc_column_inner el_class=&#8221;anchor_col&#8221; css=&#8221;.vc_custom_1618397491357{padding-top: 30px !important;padding-right: 30px !important;padding-bottom: 30px !important;padding-left: 30px !important;}&#8221;][vc_column_text]<\/p>\n<h3>Complaints &amp; Disciplinary Procedures:<a id=\"\" class=\"hanbooktotop\" href=\"#top-section\"><i class=\"qode_icon_font_awesome fa fa-arrow-circle-up\"><\/i><span class=\"hanbooktotopspan\"> Top<\/span><\/a><\/h3>\n<p>The different processes for complaints made against members in their roles of Registered Nutritional Therapy Practitioner (NT) and BANT Registered Nutritionist\u00ae (BANT RN) are set out below.<\/p>\n<p><strong>Complaints against Registered Nutritional Therapy Practitioners (NTs)<\/strong><\/p>\n<p>Complaints against BANT members relating to 1:1 nutritional therapy consultations are handled by the member\u2019s registrant body, the Complementary and Natural Healthcare Council (CNHC) or their statutory regulatory body. A complainant making a complaint against an NT should be informed of their complaints procedures and directed to the CNHC or the relevant statutory regulator, information of which is typically available on members\u2019 practice details and on the\u00a0<a href=\"https:\/\/practitioner-search.bant.org.uk\/\">BANT Practitioner Directory.<\/a><\/p>\n<p>Please note that unless there are exceptional circumstances, the CNHC will not consider complaints about something that happened more than two years ago, or about something you became aware of more than two years ago.<\/p>\n<p>If a member suspects a client might make a formal complaint against them, they should ensure their client documentation is organised. In the event of an official complaint, they will need to submit all documentation relating to that client to their regulatory body, including relevant correspondence between appointments as well as clinic notes. The information below outlines the process based on CNHC regulations as the main regulatory body for BANT member practitioners.<\/p>\n<p>Once the complaint has been received by the CNHC, the process is as follows:<\/p>\n<ol>\n<li>The CNHC CEO contacts the NT to advise them of the complaint<\/li>\n<li>The complaint is emailed to the NT<\/li>\n<li>The NT has 7 days to submit their client file to the CNHC.<\/li>\n<li>The NT then has a further 28 days to respond to the complaint.<\/li>\n<\/ol>\n<p>As soon as the NT is made aware of the complaint, they must inform their insurance company and accept the legal advice offered. The appointed solicitor will support the NT with their response to the complaint to the CNHC. They are advised to also inform the Professional Practice Panel (PPP), however the PPP will be limited in the support it can offer the NT and will only be able to signpost the member to areas to address in their response, where guidelines may have been breached. The PPP cannot comment or override any specific legal advice given to the NT by their appointed solicitor or legal team.<\/p>\n<p>Submissions to the CNHC should be factual accounts using neutral language, which is not emotional or inflammatory. Members are advised to ensure documentation is easy to navigate by dating all documents and including an index. This will also enable the member to refer to sections of the client file in their response to the complaint.<\/p>\n<p>If the NT would like PPP support with their response to the complaint to the CNHC, they should ask the client\u2019s permission for the PPP to view the complaint file. The PPP cannot request this from the complainant unless they have previously been contacted by them regarding the complaint and therefore already have their contact details. If the NT does not want to ask the complainant for this, or if permission to view the complaint file is not granted, the PPP can only view the file if it is sufficiently anonymised so that the client cannot be identified, see\u00a0<a href=\"https:\/\/bant.org.uk\/bant-professional-practice-handbook\/complaints\/#anonymising-client-data\">Anonymising Client Data<\/a>.<\/p>\n<p>Once the complaint has concluded with the CNHC, and if a fitness-to-practice issue has not been upheld, the PPP will offer to review the complaint with the NT if they feel it is appropriate.\u00a0 Whilst recommended, this is voluntary, and there is no obligation for the member to participate. The PPP will highlight any relevant sections of the Professional Practice Handbook to the complaint and advise the NT how to incorporate changes into their practice to try to avoid future complaints.<\/p>\n<p>&nbsp;<\/p>\n<p><strong>Complaints against BANT Registered Nutritionists\u00ae (BANT RN)<\/strong><\/p>\n<p>Complaints which do not relate to a 1:1 nutritional therapy consultation are reviewed by the Professional Practice Panel (PPP).\u00a0 If a member of the public or another BANT practitioner wishes to make a complaint against a member in their role as a BANT RN, they will need to complete the\u00a0<a href=\"https:\/\/bant.org.uk\/bant\/content\/pdf\/PPP\/BANT_COMPLAINTS_FORM.docx\">BANT Complaint Form<\/a>\u00a0and\u00a0<a href=\"mailto:bantpractice@bant.org.uk\">email it to the PPP<\/a>\u00a0with any relevant supporting documentation.\u00a0 If any additional information is required, this will be requested within 16 days of receipt of the complaint. By signing the form, the complainant is consenting to BANT processing the complaint and to the retention of all files relevant to the complaint in line with the BANT\u00a0<a href=\"https:\/\/bant.org.uk\/bant-professional-practice-handbook\/complaints\/#complaint-record-retention-policy\">Complaint Record Retention Policy<\/a>.<\/p>\n<p>Please note that unless there are exceptional circumstances, BANT will not consider complaints about something that happened more than two years ago, or about something you became aware of more than two years ago.<\/p>\n<p>The PPP will inform the member who is the subject of the complaint and provide them with the submitted BANT Complaints Form and supporting documentation. The member has 16 days to submit their written report in response to the complaint, along with any supporting documentation.<\/p>\n<p>On receipt, the PPP will review the complaint to assess if there have been any breaches of the guidelines and to determine if any remedial action is required. The PPP will reach its decision based on the facts of the case, as far as can reasonably be established, but it may be necessary to consider whether there have been any prior incidents or warnings. The member will be informed of the outcome as soon as possible, however, due to the volunteer nature of the PPP; this may take up to 2 months.<\/p>\n<p>Resulting actions are:<\/p>\n<ul>\n<li><strong>No action<\/strong><\/li>\n<li><strong>Informal warning<\/strong>\u2013 Remedial action such as CPD may be required.<\/li>\n<li><strong>Formal warning<\/strong>\u2013 Remedial action will be required as deemed appropriate.<\/li>\n<li><strong>Membership suspension<\/strong>\u2013Remedial action needs to be undertaken before the practitioner continues in practice and the practitioner\u2019s membership will be suspended until they have demonstrated that they are fit to practice. If a member continues to practice during a suspension period, their membership will be rescinded.<\/li>\n<li><strong>Membership rescinded \u2013\u00a0<\/strong>If the breaches identified are of a very serious nature, the practitioner\u2019s membership will be rescinded and BANT Council will be informed.<\/li>\n<\/ul>\n<p><strong>Appeals Process<\/strong><\/p>\n<p>A member has the right to appeal the outcome decision of the complaint. The appeals process is not an opportunity for the BANT RN to present new evidence, but for BANT Council to consider whether the original process was fair and reasonable. The appeal will be set out in writing by the member, in conjunction with their solicitor if engaged, and must provide clear details of what is being appealed, i.e., the findings, the disciplinary penalty, or both.<\/p>\n<p>If the BANT Council is satisfied that the original process was fair and reasonable, the appeal will be dismissed. If there is a reasonable argument that the investigation should have covered in more detail, the appeal will be upheld, and further investigation arranged. An independent review panel will be \u00a0formed, consisting of representatives, as relevant to the circumstances, from the PPP, training providers and BANT RNs. The decision from the appeal will be reached as soon as possible and the BANT RN notified of the outcome in writing.<\/p>\n<p><strong>Membership Reassessment<\/strong><\/p>\n<p>After five years following a membership rescinded, the practitioner is able to reapply for membership but must declare their previous complaint on their membership application. BANT Council must be informed that the former practitioner has reapplied for membership.<\/p>\n<p>The PPP will review the original complaint and assess whether the breach has been addressed. All communication must be documented in writing and the final decision sent in writing to the applicant.[\/vc_column_text][\/vc_column_inner][\/vc_row_inner][vc_separator type=&#8221;transparent&#8221; thickness=&#8221;30&#8243;][vc_row_inner row_type=&#8221;row&#8221; type=&#8221;full_width&#8221; text_align=&#8221;left&#8221; css_animation=&#8221;&#8221; anchor=&#8221;informing-the-ppp-of-a-complaint-or-investigation&#8221; el_class=&#8221;anchordiv&#8221;][vc_column_inner el_class=&#8221;anchor_col&#8221; css=&#8221;.vc_custom_1618397548620{padding-top: 30px !important;padding-right: 30px !important;padding-bottom: 30px !important;padding-left: 30px !important;}&#8221;][vc_column_text]<\/p>\n<h3>Informing the PPP of a Complaint or Investigation:<a id=\"\" class=\"hanbooktotop\" href=\"#top-section\"><i class=\"qode_icon_font_awesome fa fa-arrow-circle-up\"><\/i><span class=\"hanbooktotopspan\"> Top<\/span><\/a><\/h3>\n<p>The Professional Practice Panel (PPP) is available to support members experiencing difficulties with clients and if a member suspects a complaint could be made or has been made against them, they are advised to <a href=\"mailto:bantpractice@bant.org.uk.\">contact the PPP<\/a>. Members are advised to inform the PPP whenever they are subject to a complaint or an investigation regarding their nutrition business or practice.<\/p>\n<p>If they are subject to legal or police action or investigation by another professional body, members must provide full details to the PPP. BANT may be able to offer moral and professional support to the member in any legal proceedings, depending on the circumstances.[\/vc_column_text][\/vc_column_inner][\/vc_row_inner][vc_separator type=&#8221;transparent&#8221; thickness=&#8221;30&#8243;][vc_row_inner row_type=&#8221;row&#8221; type=&#8221;full_width&#8221; text_align=&#8221;left&#8221; css_animation=&#8221;&#8221; anchor=&#8221;anonymising-client-data&#8221; el_class=&#8221;anchordiv&#8221;][vc_column_inner el_class=&#8221;anchor_col&#8221; css=&#8221;.vc_custom_1618397548620{padding-top: 30px !important;padding-right: 30px !important;padding-bottom: 30px !important;padding-left: 30px !important;}&#8221;][vc_column_text]<\/p>\n<h3>Anonymising Client Data:<a id=\"\" class=\"hanbooktotop\" href=\"#top-section\"><i class=\"qode_icon_font_awesome fa fa-arrow-circle-up\"><\/i><span class=\"hanbooktotopspan\"> Top<\/span><\/a><\/h3>\n<p>If a complainant has not provided permission for their client file to be shared with the PPP, the only way the PPP can view the complaint details and assist the member, is if the client file has been sufficiently anonymised. Data protection law does not apply to data rendered anonymous in such a way that the data subject is no longer identifiable, and if it is unlikely to allow any individual to be identified by combining the provided details with other information.<\/p>\n<p>Members are advised to read the ICO document <a href=\"https:\/\/ico.org.uk\/media\/1061\/anonymisation-code.pdf\" target=\"_blank\" rel=\"noopener\">Anonymisation: managing data protection risk code of practice<\/a> for guidance on anonymising their client file. Members are advised to consider whether using information which could identify the client is necessary to enable the PPP to view the complaint. Certain details may not be useful or relevant, and other details which may be relevant such as age, can be anonymised by using an age bracket instead (e.g., age 30-35).<\/p>\n<p>The following steps will help to ensure the client\u2019s data is sufficiently anonymised. Any deletions or amendments must be made on copies of the client file with the original version kept intact:<\/p>\n<ol>\n<li>Remove all personal information from the health questionnaire and consultation documentation such as name, exact age, date of birth, address, telephone number, email address, occupation, height, weight, GP surgery details, extensive medical history details or details of past medical procedures with dates*.<\/li>\n<li>Remove any exact dates from documentation, leaving just the month and year.<\/li>\n<li>Ensure all personal details are removed from any test results and referral letters.<\/li>\n<li>If there are any photos of a client\u2019s symptoms, ensure the face is not shown and that there are no identifying items in the photo such as a client\u2019s jewellery or objects in the background. These can be blurred out if necessary.<\/li>\n<\/ol>\n<p><em>*For example, weight can be provided as underweight\/normal\/overweight\/obese\/clinically obese, and medical history and procedures as a simple list in chronological order, along with symptoms, without further identifiable details.<\/em>[\/vc_column_text][\/vc_column_inner][\/vc_row_inner][vc_separator type=&#8221;transparent&#8221; thickness=&#8221;30&#8243;][vc_row_inner row_type=&#8221;row&#8221; type=&#8221;full_width&#8221; text_align=&#8221;left&#8221; css_animation=&#8221;&#8221; anchor=&#8221;complaint-record-retention-policy&#8221; el_class=&#8221;anchordiv&#8221;][vc_column_inner el_class=&#8221;anchor_col&#8221; css=&#8221;.vc_custom_1618397548620{padding-top: 30px !important;padding-right: 30px !important;padding-bottom: 30px !important;padding-left: 30px !important;}&#8221;][vc_column_text]<\/p>\n<h3>Complaint Record Retention Policy:<a id=\"\" class=\"hanbooktotop\" href=\"#top-section\"><i class=\"qode_icon_font_awesome fa fa-arrow-circle-up\"><\/i><span class=\"hanbooktotopspan\"> Top<\/span><\/a><\/h3>\n<p>BANT is required to keep a record of complaints against its members in line with UK GDPR, legal requirements and professional standards.\u00a0 This is to ensure that:<\/p>\n<ul>\n<li>Previous complaints against members can be considered if a further complaint is made against them within the complaint record retention period<\/li>\n<li>BANT is able to review any previous complaints against an ex-member should they reapply at a later date after having their membership rescinded<\/li>\n<li>The public are safeguarded from unsafe practice by assessing if a member has applied recommendations following a previous complaint.<\/li>\n<\/ul>\n<p>The following record retention periods apply to complaints against BANT members in their roles of Registered Nutritional Therapy Practitioner (NTs) and BANT Registered Nutritionist\u00ae:<\/p>\n<p>All data relating to a complaint against a BANT member will be securely stored by BANT for a period of <strong>7 years<\/strong> following the outcome decision of the complaint unless there are extenuating circumstances.<\/p>\n<p>If the complaint is not upheld, the complaint data will be kept for exactly <strong>1 year<\/strong> following the outcome decision of the complaint, to cover the event that the complainant appeals the decision.<\/p>\n<p>If the following conditions apply, the retention period for the complaint file will be extended to <strong>15 years<\/strong>:<\/p>\n<ul>\n<li>There is legal involvement in the complaint<\/li>\n<li>There is insurance involvement following a complaint, i.e., a payout<\/li>\n<li>A practitioner\u2019s membership was rescinded as a result of a complaint.<\/li>\n<\/ul>\n<p>BANT will securely store all complaint data in accordance with the above record retention periods and UK GDPR.\u00a0 Data will be destroyed on the required date by either permanently deleting online data or shredding paper files.[\/vc_column_text][\/vc_column_inner][\/vc_row_inner][\/vc_column][\/vc_row]<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Different complaint procedures are in place for complaints made against members in their roles of Registered Nutritional Therapy Practitioner (NT) and BANT Registered Nutritionist\u00ae (BANT RN). If a member suspects a complaint is going to be made against them, or if they know a complaint has been made, they are advised to contact the PPP.<\/p>\n<p> <span style=\"color: #ff0000; font-size: 80%\"><b>(LAST UPDATED &#8211; 12 NOVEMBER 2024)<\/b><\/span><\/p>\n","protected":false},"author":12,"featured_media":18922,"parent":4059,"menu_order":1,"comment_status":"closed","ping_status":"closed","template":"page-handbook-child.php","meta":{"footnotes":""},"tags":[909,419,910,911,912,913,914,480,915,916,917,229],"class_list":["post-18918","page","type-page","status-publish","has-post-thumbnail","hentry","tag-anonymise","tag-anonymising","tag-complainant","tag-complaining","tag-complaint","tag-concerns","tag-disciplinary","tag-investigation","tag-policy","tag-procedures","tag-record-retention","tag-support"],"rankMath":{"parentDomain":"bant.org.uk","noFollowDomains":[],"noFollowExcludeDomains":[],"noFollowExternalLinks":false,"featuredImageNotice":"The featured image should be at least 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