Victim Notification Scheme (VNS): independent review

Section 31: Feedback and Complaints

We examined to what extent the Scheme already has feedback and effective complaints processes. Whilst the delivery organisations each have complaints processes, we found limited evidence of uptake, low levels of satisfaction amongst users and little indication that management saw complaints as a valuable source of information to drive improvements. There are some informal feedback processes to be found and officials were individually responsive, but there is no obvious culture of using systematic feedback as a positive tool. We heard from the former England and Wales Victims Commissioner that this issue had been considered by her office and a move to take feedback surveys away from the delivery organisations into the Victims Commissioner's realm had improved confidence and uptake.

We are aware of a substantiated complaint against COPFS, which had been escalated to the Scottish Public Services Ombudsman in November 2022, which indicated the distance still to go to achieve a trauma aware culture. We believe our proposal to create a new contact team should help improve the communications and service victims receive.

We were concerned to learn that data held on the SPS system is immediately deleted upon completion of a sentence or the death of an offender. This was explained to us as a data protection requirement. Whilst this may be so, it has the unfortunate effect of deleting any historical data which might be needed in a complaint investigation subsequently. This seems short-sighted and could even impede a later enquiry, which, beyond determining accountability, might also help lead to system improvements. We are aware of other parts of the system, the VNS for mental health, where information is retained for a limited period, with supporting rationale.

We considered how a new Victims Commissioner for Scotland might play a role in user feedback, but we have concluded that, whilst the role is as yet unestablished, it would not be appropriate now to nominate that position as having any delivery responsibility for the efficient operation of the VNS. This was also the view of the workshop delegates.