Customer behaviour policy

Published: 26 August 2021
Freedom of information class: How we manage our resources

Learn about our customer behaviour towards staff policy

Purpose and Scope

  1. This policy sets out RoS’ commitment to protect our staff from customer behaviours we consider to be unacceptable. RoS strives to provide excellent customer services to all our customers. We also are committed to providing services that are accessible to all and we will treat all customers fairly and equally. Occasionally, the behaviour or actions of some customers using our services make it impossible for us to continue our role as a impartial registration organisation trusted for our integrity.
  2. In these small number of cases, RoS must consider taking steps to protect our staff and ensure that our ability to provide an effective registration service is not undermined. This policy will explain how we will approach these situations. Customers who are judged to be displaying unacceptable behaviours will have contact restricted and actively managed. These customers are placed on the Customer Behaviour List
  3. This policy applies to all customer contacts received by RoS’ colleagues.
  4. The aim of the policy is to support to the corporate strategic objectives of:
    • Being customer focussed – ensuring that we are delivering excellent service and treating our customers fairly and equally
    • Invest in our people – putting mechanisms in place that protect our staff from customers who exhibit unacceptable behaviours
  5. Documented procedures on how we manage our customer contacts support this policy and will be maintained by the customer experience team. These will be published on our website.

Guiding principles

  1. The principles of the policy are to:
    • Protect of our staff – RoS staff have the right to work without being subjected to unacceptable behaviours from customers
    • Consistency – Ensuring RoS customers are being treated consistently when exhibiting unacceptable behaviours
    • Fairly - ensuring customers are being treated with respect whilst on our Customer Behaviour List
    • Optimisation – Ensuring RoS is using its resources to best manage customers with complex registration and other enquiry issues

Policy aims and objectives

  1. This policy as framed by the guidelines at Annex 1 aims to address the very limited number of customers who exhibit unacceptable behaviours, place unreasonable demands on our organisation and/or are unreasonably persistent in their correspondence.
  2. This policy explains how we will restrict or change access to a service when we consider a customer’s actions to be unacceptable. This is to ensure that we protect our staff, treat customers who have behaved unacceptably fairly and consistently as well as maximising our resources.

Roles and responsibilities

  1. The Head of Customer Services is responsible for the content of this policy, its approval and review. They are responsible for ensuring its implementation in practice and for monitoring this over time. They are responsible for ensuring that appropriate procedures and guidelines as are required to support this are maintained and ownership for these assigned appropriately.

Approval and review

  1. The customer contact policy will be reviewed and approved by Policy and Practice Group at least bi-annually, unless earlier review is appropriate.

Customer Behaviour Policy Guidelines

Defining customer behaviours that we will manage

  1. RoS understands that customers who engage with us are normally dealing with an issue in relation to the registration of their or their client’s land or property. We acknowledge that this can be hugely stressful and that they sometimes may act out of character. However, RoS takes the importance of our work very seriously and whilst we will provide the best customer service we can to our customers, we do not expect our staff to tolerate unacceptable behaviour.
  2. Dealing with behaviours such as those defined below, detract from the service that RoS offers and places a significant burden on the organisation. Dealing with unacceptable behaviours diverts necessary resources from delivering our core business and services.

Unreasonable persistence

  1. Sometimes an individual will contact RoS repeatedly about the same issue or closely related issues. Whilst individually these contacts may be quite acceptable, the persistence of the approach takes up a disproportionate about of time and resources in exchanges that are unproductive to either party. Such cases will be considered as unreasonable persistence and examples of such behaviour include:
    • serial complaining – lodging complaints about the handling of their complaints, often across different parts of the organisation
    • Refusal to follow proper process in relation to the decisions taken by RoS in relation to their land or property (i.e. continuing to contact RoS rather than follow next steps in the appeals process)
    • Causing disruption by excessive contact in relation to information about their land/and or property without clear acceptance of the updates previously given
  2. At the conclusion of a stage 1 or stage 2 complaints investigation, a customer will be informed about the appropriate routes of appeal, and if we have concluded our complaints handling procedure (if appropriate). If they continue to correspond with RoS then consideration will be given to restricting contact with that individual under the terms of this policy.

Unreasonable demands

  1. RoS provides an impartial registration service for the people of Scotland. Sometimes people can make unacceptable demands on our resources by the nature and the scale of the service that they expect. Examples of such behaviour may include:
    • Repeatedly demanding responses within an unrealistic timescale
    • Insisting on speaking to a particular member of staff, even when it is not possible
  2. It will be judged to be an  unreasonable demand when it  reaches the point of disrupting our ability to undertake our work or is amounting to harassment, bullying  or unacceptable treatment of our staff. Consideration will then be given to restricting contact with that individual under the terms of this policy.

Offensive, threatening, and abusive behaviour

  1. RoS operates a zero-tolerance approach on any kind of offensive, threatening and abusive behaviour. This will include any action that is designed to insult or degrade. This includes but is not limited to being racist, xenophobic, homophobic, transphobic, bi-phobic or language that causes any offence will be managed under this policy.

How we will manage these behaviours in practice.

  1. There are currently two main ways in which to correspond with RoS. By telephone or in writing (email or post).


  1. If a customer contacting or being contacted by RoS over telephone displays unacceptable behaviours detailed above, the member of staff should do the following:
    • If the behaviour is offensive, threatening or abusive you may inform the customer that you are immediately terminating the call.
    • If this does not resolve the matter and the person continues to display these behaviours, then contact will be terminated.
    • Inform your manager or a team leader will the full details of what happened
    • The manager will then bring this to the attention of either the Head of Customer Services or Head of Customer Experience for further action, in line with the description under section 6.
  2. Inbound and outbound calls to customer experience teams are recorded and will be used as evidence in the application of this policy.  This does not include invoice payments line in accordance with PCI-DSS regulations.

In writing

  1. If a customer contacting RoS in writing is offensive, threatening, or abusive. These should be reported to your manager immediately. The manager will then inform Head of Customer Services or Head of Customer Experience who will consider an appropriate course of action, in line with the description under section 6.
  2. If a customer contacts RoS in writing that is placing unreasonable demand on RoS, on when RoS has already taken a decision on the following:
    • An application for registration
    • A potential inaccuracy in the register
    • Processing of an application for rectification
    • Processing of a compensation payment
  3. These should be reported to your line manager who will inform the customer in writing of our expected levels of service and/or the next steps which may signpost customers where a statutory route of appeal exists.
  4. Once RoS has taken a final decision we will  advise the customer of that decision including any statutory route of appeal they may wish to take . If the customer continues to contact RoS regarding the case rather than pursue the appropriate next steps then RoS will consider restricting contact with the individual under the terms of this policy.

Restricting access

  1. Once a customer has been reported as having behaved unacceptably, RoS will decide whether that person should have restricted access to our services and/or whether we should manage their correspondence differently. We can choose to restrict contact in a variety of different ways – by the subject matter, to a named staff member, contact channel used or a combination of these.
  2. In all cases we will appoint a single point of contact to manage any existing and future correspondence from these individuals. Details of how we will manage this correspondence is narrated within section 7.
  3. RoS do not take these decisions lightly and rarely impose such restrictions. But we will not hesitate to impose restrictions where we think that it is necessary to protect our staff or our services from the behaviours outlined in this policy.

Access restricted on a specific case or subject matter

  1. We may refuse to communicate in respect of a particular application for registration, where we have undertaken our statutory obligations and any potential resolution of the issue is outwith RoS’ control.
  2. Once the Customer Behaviour Policy has been applied, RoS will not enter into any further correspondence about the specific application for registration in the absence of either a registrable deed, new evidence that has not already been considered or a judicial determination.

Access restricted to specific people

  1. We may refuse to communicate with specific individuals following offensive, threatening or abusive behaviour. Once the Customer Behaviour Policy has been applied, RoS will not enter any further correspondence other than to facilitate any requests for information that fall under our access to information obligations or to purchase a product or service from RoS.

Access restricted to specific channels

  1. We may choose to restrict the way that a customer can contact us, for example by informing them that we will only correspond with them in writing.  We will inform the customer of this and manage this by routing their emails directly to their named contact.

Decision to restrict contact

  1. RoS will carefully manage the process of terminating contact with an individual and the decision will not be taken lightly. We will carefully consider the form of such a termination in order to balance the rights of the individual against the Keeper’s duty to perform her statutory functions, protect RoS staff and avoid any disruption to our work.
  2. The decision to restrict or terminate contact will be taken by a member of EMT. There is no route of appeal once the decision has been taken to apply the customer behaviour policy to an individual.

Managing ongoing customer contact

  1. Once a customer has been reported as behaving unacceptably, we will appoint a single point contact with an appropriate deputy will be assigned to each individual. All customer contact from that specific individual will be routed to their contact by telephone and email. This ensures continuity of service, reduction of time wasted re-visiting matters already concluded and the person appointed will have the appropriate history of the customer’s correspondence.
  2. On receipt of any further correspondence, the appointed RoS contact will consider if the matter is in relation to the area in which our policy applies to the individual and if so, the correspondence will not be acknowledged. If the request does require a response, the correspondence will be acknowledged and passed onto the appropriate part of the business to be dealt with. A record of the customer behaviour list will be held centrally by customer experience and a review of the contacts will be undertaken quarterly.

Equality and diversity

  1. RoS are committed to providing services that are accessible to the broadest range of customers. Our service commitment encompasses our legal obligations under the Equality Act 2010. Where a customer is behaving in an unacceptable manner, we must consider whether this may be caused by any personal difficulties or characteristics that they have, that may be making our services more difficult to access or use. However, a customer who has rights under the Equalities Act 2010 may still be considered to be acting in an unacceptable manner under this policy.
  2. Customer Experience will work with People and Change colleagues to ensure that we are supporting customers with rights under the Equalities Act 2010 appropriately in the application of the CBP.

Further Actions

  1. In addition to the actions described in this policy, RoS reserve the right to take any further action that may be appropriate in order to protect our staff from unacceptable customer behaviour. Where appropriate, this may include reporting behaviour to Police Scotland or taking legal action. Any decision to report a customer's behaviour to a third party will be taken by a member of EMT following advice from relevant information governance and/or legal colleagues.
  2. Whist instances are very rare, sometimes a customer’s behaviour can cause significant alarm, distress or concern that a criminal act may have taken place or be about to take place. When such situations arise, we will consider reporting the matter to the police or other relevant authorities. We will base our decision on an assessment of risk. The underlying principle will be the need to protect our staff and others from harm or the threat of harm.
  3. A member of staff encountering behaviour of this type should inform their manager immediately.
  4. We will consider reporting incidents whereby:
    • a RoS member of staff is being harassed, and/or is subject to a criminal act by a customer.
    • a customer threatens to harm a member of staff, staff of other organisations, members of the public or themselves.
    • a customer has acted in a way that is otherwise malicious or vexatious to the extent that intervention is regarded as necessary.
  5. If there is reason to believe there is an imminent threat to life, we will call the emergency services. When we have decided to report an incident, we must document and record it as part of the ongoing customer contact information.


Gillian Martin, Head of Customer Services