Unreasonable Contact Policy

The vast majority of the contacts we receive deal with us in a reasonable manner. Given the nature of the issues we deal with, some contacts can experience considerable stress and we do our utmost to understand and deal compassionately with this.

However, a small number of the contacts we receive do not act in a reasonable manner. The Competition and Consumer Protection Commission (CCPC) cannot tolerate behaviour which is abusive, offensive, threatening or, due to the frequency of contact, accounts for a disproportionate use of time and resources that could be spent more effectively dealing with other issues or other members of the public.

Unreasonable conduct

Behaviour is classified as unreasonable if it comprises:

Unreasonable persistence

Persistence on an issue which has already been considered and closed. The persistence may be manifested in different ways; for example, insisting that the issue be looked at again, re-framing the matter to present it as a new issue, persevering with an argument that has earlier been addressed or making multiple duplicate contacts over a short period of time, through one or more channels.

Unreasonable demands

An outcome or approach is expected that is unrealistic or disproportionate. An example would be a demand for us to consider an issue which is outside of our remit.

Unreasonable lack of co-operation

Persistent presentation of a request in a manner which we cannot progress. Examples include: not identifying the issue clearly, not providing details in writing when requested, presentation of potentially unnecessary voluminous material while expecting almost instantaneous responses, altering the nature of the issue midway through the investigation process and dishonesty in the statement of facts.

Unreasonable arguments

Examples include: exaggerating issues, presenting irrelevant and/or unreasonable arguments, placing too much emphasis on trivialities, insisting that the contact’s version of events be accepted as fact where there is no objective evidence to support this view or refusing to consider reasonable counter-arguments.

Unreasonable behaviour

Unreasonable behaviour includes: threats of violence, abuse of staff, rude or aggressive conduct and threats of self-harm. It also includes the unauthorised recording of conversations with CCPC staff and their broadcast without the express permission.

How we will manage such behaviour

When we consider that a contact’s behaviour is unreasonable, we will tell the person and we will ask them to change their behaviour.

If, however, the unreasonable behaviour continues, we will take steps to restrict the contact’s interaction with us. A decision to restrict access will only be taken after we have reviewed, in consultation with the Service Manager, the service which we have given. Any restrictions imposed will be appropriate and proportionate. The options we are most likely to consider are:

  • a request for contact to take a particular form (letter or email) only,
  • requiring contact to take place with a named member of staff only,
  • restricting access to our offices or other communications channels,
  • asking the contact to enter into an agreement about their future conduct, and, ultimately,
  • terminating all contact where the behaviour shows no signs of abating (this decision will be taken following a review by the Service Manager and the Director of the relevant Division).

Regardless of the contact’s behaviour, we will act respectfully at all times.

*The CCPC acknowledges that this policy is based on that of the Office of the Ombudsman. 

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