This document describes the procedure used by QANU for filing complaints about QANU’s working methods as a quality assurance agency, or about the behaviour of individuals representing QANU or of members of panels supported by QANU.
A complaint can be filed by someone who is dissatisfied about the way he or she is treated during an assessment by someone representing QANU, either an employee of QANU or a board member of QANU, or by a member of a panel supported by QANU.
It is not possible to file a complaint against an assessment by a panel supported by QANU. It is possible to submit an appeal against such an assessment. QANU has a separate procedure for submitting appeals (cf. the next chapter of this document). Only institutions can submit an appeal on behalf of degree programmes or research units against the assessments of a panel supported by QANU.
Submission and consideration
Complaints about QANU’s working methods or the behaviour of individuals representing QANU or of members of panels supported by QANU can be filed through are website in the near future. Until then, please send these to the director of QANU. QANU informs the person filing the complaint within 5 working days how the complaint will be treated. The term for treating a complaint is in principle 15 working days. When more time is needed for a careful handling of the complaint, QANU will inform the person who filed the complaint.
A complaint about the behaviour of a staff member of QANU will in principle be treated by QANU’s director. A complaint about the behaviour of QANU’s director will in principle be treated by the chair of QANU’s Board. A complaint about the behaviour of one of QANU’s Board members will in principle be treated by QANU’s Appeals Committee. A complaint about a member of a review panel supported by QANU will in principle be treated by QANU’s director in consultation with the chair of QANU’s Board. Complaints about QANU’s working methods will in principle be treated by the chair of QANU’s Board and QANU’s director. It is, depending on the nature and character of the complaint, always possible to involve others in the handling of the complaint.
Article 1: Submitting an appeal
- If an institution, after it has had the opportunity to respond to the draft version of an assessment report, still cannot agree with an assessment of a review panel (in what follows: the Panel) about a degree programme or a research unit, it can submit an appeal against the assessment. The appeal will be treated by QANU’s Appeals Committee.
- The Appeals Committee is an independent committee that has three members: two permanent members and a third member who has expertise in the discipline covered by the degree programme or the research unit. The members of the Appeals Committee are appointed by QANU’s Board. They decide without obligation or compulsion.
Article 2: Grounds of appeal
- Institutions may, within the scope of the appeal outlined in Article 3, appeal against an assessment of the Panel about a degree programme or a research unit, claiming that
- the Panel has violated the starting points or guidelines for assessing a degree programme or research unit, general legislation or any commonly accepted principles of fair and equal procedures; or
- the Panel’s assessment was unreasonable or disproportionate in the light of the available evidence, for example in that the Panel has
o not considered or misunderstood certain facts and/or evidence duly provided in the assessment process; or
o failed to consider an aspect which is likely to be of substantial relevance for the assessment.
o based its decision on considerations which are evidently not substantially related to the issues in question, or
o based its assessment on facts and/or evidence which were not duly provided in the proceedings; or
Article 3: Scope of appeal
- The appeal may only be based on those facts and/or evidence which have been duly introduced into the assessment procedure and shall clearly state the grounds for appeal.
- The relevant assessment framework is the version that was valid at the time the Panel formulated its assessment.
- Except in case of grave and evident fault, the Appeals Committee will only consider those complaints which the applicant has put forward in the appeal.
Article 4: Appeals procedure
- An appeal shall be submitted to QANU within 60 days after the institution received the final version of the assessment report.
- The Appeals Committee should consider an appeal within 90 days from receipt of the appeal. The appeal shall be forwarded to the Panel for comment before a decision is made. The term of 90 days can be extended once with a maximum of 90 days.
- In case of lack of relevant information or need for clarification, the Appeals Committee may request further information from the Panel of the secretary of the Panel. The Appeals Committee may, if appropriate, request further information from the institution submitting the appeal.
Article 5: Decisions and consequences
- The Appeals Committee shall decide to either accept the appeal, reject the appeal, or deem it inadmissible. The institution that submitted the appeal and the Panel shall be notified of the decision and its grounds.
- If the appeal is accepted, the Panel shall reconsider its assessment, taking due account of the appeal and the decision of the Appeals Committee.
- If the appeal is rejected, the Panel’s assessment is final.
Article 6: Independence
- A member of the Appeals Committee who has a conflict of interest with regard to an institution may not take part in the consideration of an appeal submitted by that institution. A member of the Appeals Committee is assumed to have a conflict of interest if, for example,
- s/he receives financial compensation from the institution as employee, consultant, freelancer or otherwise, or
- s/he holds a position, whether paid or unpaid, with the institution, for example as a membe of a committee or a board, or
- s/he was involved in the assessment of the institution or a degree programme or research unit of the institution, or
- any of the above applies to a close relative or personal relation of the person, or
- any of the above applied within the last five years.
- A member of the Appeals Committee is expected to declare a possible conflict of interest of his/ her own accord.
- Institutions submitting an appeal shall notify the chair of the Board of QANU if they consider that a member of the Appeals Committee has a conflict of interest with regard to their appeal.
- Any disputes with regard to the independence of the members of the Appeals Committee shall be settled by the chair of the Board of QANU in consultation with the chair of the Appeals Committee.
Article 7: Further provisions
The Appeals Committee may specify the process further in its own Guideline for Appeals Procedures.