Give the AI your charity's size, who may complain, the stages you can staff and the timescales you can keep, and ask for numbered clauses with a gap marker wherever a fact is missing. Then run a sceptical second AI pass, test the draft on a made-up complaint, and have trustees confirm legal points against your regulator's guidance.
Free templates tend to fail in a different place from where people look. The wording is usually fine; the fit is not. A policy promises a reply within ten days when nobody is at the desk on weekdays, or sends a complaint about the director to the director. An AI draft reads even more smoothly than a free template, which makes those flaws harder to see. The routine below is built to find them before a real complainant does.
Everything here uses invented complaints and invented timescales. Real complaint details do not go into a chatbot, and the rules on donor data and ChatGPT explain what else to keep out.
Six decisions to make before you open the chat
If you leave these to the AI, it writes a plausible version of someone else's charity. Each one is a choice about your people, your calendar and your risks, so it belongs to the trustees and the person who will run the process. The settings in the table are illustrative.
| Decision | Illustrative setting | Why the AI cannot choose it |
|---|---|---|
| Stages | Informal fix; formal written review by one person; appeal to two trustees | The right number depends on how many people you have who were not involved |
| Timescales | Acknowledge in 5 working days; outcome in 20; ask for an appeal within 15; appeal decided in 20 | They must match who is in the office, and when trustees can meet |
| Who investigates | Operations manager; deputy is the shop manager | The investigator must not have been involved in the events complained about |
| Senior people | Complaints about the manager go to the chair; about the chair, to the vice-chair | An AI defaults to "senior management", which may be the person complained about |
| What sits elsewhere | Safeguarding concerns go to the safeguarding lead the same day; whistleblowing and staff grievances have their own policies | A complaint can contain a safeguarding concern, and the route must be explicit |
| Records and reporting | Log kept by the operations manager; retention period agreed with your data-protection adviser; anonymised summary at every board meeting | Retention touches data-protection duties, so it is a decision, not a default |
A seventh input comes later: your regulator's guidance on complaints, which you will use to check the draft rather than to write it. For a small charity, "trustees" can mean board members or directors, whichever term your governing document uses.
The drafting prompt, with a gap marker for every missing fact
The prompt below uses one device that matters more than the rest: a marker, [CONFIRM: ...], that the AI must write instead of guessing. Each marker becomes a question for the trustees. A draft with eleven markers is a better draft than one with none, because the one with none has answered those questions for you, probably wrongly.
Draft a complaints policy for a small charity. Use plain English (reading age
about 12) and numbered clauses. Use ONLY the facts below. Where a fact is
missing, write [CONFIRM: what is needed] instead of guessing. Do not cite
laws, regulators, codes of practice, ombudsmen or awards by name.
ABOUT US: [type of charity], [number of paid staff], [number of volunteers],
[number of trustees]; the board meets [how often].
WHO MAY COMPLAIN: [beneficiaries, donors, volunteers, public]
NOT COVERED HERE (and where it goes): safeguarding [route]; whistleblowing
[route]; staff grievances [route]; data requests [route]
HOW PEOPLE CAN COMPLAIN: [phone, email, post, in person, through someone else]
STAGES AND TIMESCALES WE CAN KEEP: informal [..]; stage 1 acknowledged in [5]
working days, outcome in [20]; appeal requested within [15], decided in [20]
WHO DOES WHAT: complaints lead [role]; deputy [role]; appeal panel [two
trustees not involved]; complaint about the lead [route]; about a trustee or
the chair [route]
RECORDS: log kept by [role]; retention [period]; anonymised summary to
trustees [how often]
OUTSIDE BODY: [name only if we have confirmed what it does; else leave blank]
SECTIONS IN ORDER: 1 Purpose. 2 What counts as a complaint. 3 What this policy
does not cover. 4 How to complain. 5 What happens at each stage (a table:
stage, who, timescale). 6 Complaints about senior people. 7 If you are not
satisfied. 8 Confidentiality and records. 9 Learning and reporting to
trustees. 10 Review date and approval.
After the draft, list every [CONFIRM] item, and every place where two clauses
could contradict each other.
Three choices in it are deliberate. "Do not cite laws, regulators, codes or ombudsmen by name" removes the commonest invention, because chat assistants will name an official-sounding body whether or not it has any power over you. Numbered clauses let a reviewer say "clause 6.2" instead of "somewhere in the middle". And the closing instruction asks the AI to audit itself, which catches the cheap contradictions (ten days in one clause, ten working days in another) before you spend your own attention on them.
A first draft, line by line: what the AI gets wrong
A first draft will usually read well and still carry a handful of the same mistakes. The table lists seven that turn up repeatedly in AI-drafted policies, with the repair for each. The "draft says" column is illustrative wording, not a quote from a real run.
| The draft says | What is wrong with it | The repair |
|---|---|---|
| "The Chief Executive will investigate and decide all complaints." | One person at every stage, and no route if the complaint is about them | Separate the investigator from the appeal; add the senior-people route you chose |
| "We will respond to every complaint within 10 days." | Calendar or working days? And can you keep it in August? | Say working days, put the due date in the acknowledgement, and add "if we need longer, we will tell you why and give a new date" |
| "All complaints are treated in strict confidence." | The person complained about, the trustees and an insurer may all need to know | "We share details only with people who need them to deal with the complaint" |
| A named ombudsman as the final stage | The AI cannot know the body exists, takes complaints about charities like yours or has any power over you | Leave a [CONFIRM] marker until you have read that body's own page |
| A named Act cited as the legal basis | It may be invented, out of date or from another country | Delete it; add a citation only after your regulator's guidance or a solicitor confirms it |
| "Complaints must be made in writing." | Shuts out people who cannot write, are in distress, or speak to a volunteer at the counter | Accept any channel; whoever hears it writes it down and passes it to the lead |
| "Safeguarding concerns will be investigated under this procedure." | A safeguarding concern needs its own immediate route, not a 20-day process | Clause 3 sends it to the safeguarding lead the same day; the complaint runs in parallel if it should |
Look at what these have in common. None is bad English. Each is a sentence that sounds like a decision and was not one you made, which is why the gap markers matter and why you compare the draft against your decisions table: any clause that states a rule you did not set is a guess. Drafts also drift into legalese ("shall", "hereinafter") or into another country's vocabulary, so ask for any clause that a volunteer would not say aloud to be rewritten at a reading age of 12 without changing its meaning.
The second pass: a sceptical reviewer who must not rewrite
Use a different assistant from the one that drafted, or at least a fresh chat, and forbid it to rewrite. A reviewer allowed to rewrite quietly fixes problems and hides them from you. Paste the draft after this prompt.
Act as a sceptical trustee who has to defend this policy at a board meeting.
Do not rewrite anything. List, by clause number:
(1) contradictions between clauses;
(2) timescales that do not add up, or that mix calendar and working days;
(3) any place where one person both investigates and decides;
(4) missing routes: a complaint about the complaints lead, a trustee, a
volunteer, or a person who cannot read or write;
(5) promises a small charity may not be able to keep;
(6) names of laws, regulators, codes or outside bodies I must verify;
(7) anything a person without internet access, or with a disability, could
not use.
Mark each item High, Medium or Low. If a category has nothing, say so.
Here is the kind of answer that comes back for a draft like the one in the previous section (illustrative).
1. HIGH - Clauses 5 and 7: the complaints lead investigates at stage 1 and
chairs the appeal panel. The same person decides twice.
2. HIGH - No route for a complaint about the complaints lead or a trustee.
Clause 6 says "senior staff" only.
3. MEDIUM - Clause 4 says "10 days"; clause 5 says "10 working days".
4. MEDIUM - Clause 8 promises "strict confidentiality"; clause 9 says the
board receives case details.
5. MEDIUM - Clause 8 sets no retention period for complaint records.
6. LOW - Clause 7 names an outside body. Verify that it exists, takes
complaints about charities like yours, and what it can order.
7. LOW - Clause 2 defines a complaint as "a written expression of
dissatisfaction", which excludes spoken complaints.
8. LOW - Clause 4 offers email and post only. No telephone option.
No other named laws or outside bodies found.
Treat the list as places to look, not a verdict. Items 1, 2 and 4 are real problems that would embarrass the charity. Item 3 is a slip that takes a minute to fix. Item 6 is a useful catch because it points at the line most likely to be wrong in a way nobody notices. Item 8 is the kind of gap an author who uses email all day cannot see, and a reviewer prompted to think about people without internet access can. Reviewers also over-flag, so decide for yourself which items matter, and note that the severity labels are the AI's guess.
Fix problems in the drafting chat rather than by hand: "Clauses 5 and 7 name the same person. Apply this rule: the appeal panel is two trustees who were not involved, and a complaint about the lead goes to the chair." Then run the review again on the revised draft. Stop when a pass returns only Low items, usually the second or third time round.
Test the timescales against your meeting calendar and your rota
This is the check no template can do for you, and it takes ten minutes with last year's figures. Take a charity with four paid staff, thirty volunteers, a shop and a food bank (illustrative) that had 12 formal complaints last year, two of which went to appeal.
| Promise | Who does the work | Illustrative effort | Where it breaks |
|---|---|---|---|
| Acknowledge in 5 working days | Complaints lead, or the deputy | 15 minutes a case | Lead on leave for two weeks in August and no deputy named |
| Stage 1 outcome in 20 working days | Operations manager | 4 hours a case, so 12 cases is 48 hours, more than a full working week | Two complaints in the weeks of the Christmas appeal |
| Appeal decided in 20 working days | Two trustees and a note-taker | 3 hours for each trustee plus 2 for the note-taker: 8 hours an appeal, so 16 hours for 2 appeals | Both available trustees knew the person complained about |
| Anonymised summary to the board | Operations manager | 1 hour a quarter | Nothing, if the log is kept up to date |
The board in this example meets quarterly, about 65 working days apart. The appeal promise is 20 working days, so an appeal cannot wait for the next meeting. The policy has to say that the two-trustee panel decides between meetings with the board's delegated authority and reports the outcome at the next one. That sentence is a governance decision, so it goes to the board as a question rather than being slipped into the clause.
Calendars matter in a second way. Public holidays and closure weeks stretch twenty working days into five or six calendar weeks. Decide what the policy says about closure periods, and let each acknowledgement letter carry a due date worked out on a real calendar. You can ask the AI to do the sums ("Complaint received on [date]; closure days are [dates]; list the three due dates"), then check them on a calendar yourself.
Walk a made-up complaint through it, day by day
This is the test that finds what neither AI pass can. Invent a complaint, give it a start date, and move it through the policy as if the clauses were instructions. Start with a donor who emails on a Monday to say that a paid collector from the charity's street-fundraising pilot, working outside a supermarket, was pushy and would not take no for an answer. The charity's policy uses the illustrative timescales from the table above. Day numbers are working days.
| Day | What happens | Entry in the log |
|---|---|---|
| 1 | Email reaches the general inbox; the admin volunteer forwards it to the complaints lead the same day | Complaint 14 opened; category: fundraising conduct |
| 2 | Lead sends the acknowledgement: how the process works, and the due date for the outcome (day 20) | Acknowledged on day 2; limit was day 5 |
| 3 to 8 | Lead asks the donor for the date, time and place; gets the collector's briefing sheet from the fundraising manager; speaks to the collector | Evidence: email, briefing sheet, collector's account |
| 9 | Finding: the briefing sheet says to stop after a first "no", and the collector did not | Upheld in part |
| 12 | Outcome letter: apology, what was found, what changes, and how to ask for a review within 15 working days | Sent on day 12; limit was day 20 |
| 20 | Donor asks for a review because they want the collector removed | Appeal received; decision due day 40 |
| 22 to 31 | Two trustees who were not involved each declare any link to the collector, read the file and speak to the lead | Panel: two trustees; no conflicts declared |
| 38 | Panel decision: the investigation was fair and the response proportionate; the letter explains why staffing decisions are not shared | Closed on day 38; 7.6 weeks in total |
On paper, every deadline was met with room to spare, and the complaint still exposed three weaknesses in the draft. First, the policy said the outcome was due 20 working days "from receipt", while the acknowledgement template said "from today", which would have given the charity a day of slack it never promised. Second, the pool of eligible panel trustees was too small, because two of the four had met the collector at a charity event; the policy now asks for a named list of at least four eligible trustees and a declaration of any link before anyone reads the file. Third, the donor's request that the collector be removed had no answer in the policy. The fix is a sentence in clause 7: "We do not discuss action taken about individual staff or volunteers. We will tell you what has changed."
Run two shorter tests before you stop. In the first, the complaint is about the complaints lead: on day 1 it should reach the chair, who acknowledges it, and the lead should have no access to the file. In the second, the complaint contains a line about a child being left alone at a shop counter: the safeguarding lead should hear the same day, under the safeguarding procedure, while the complaint process continues for everything else. If either test makes you hesitate over who does what, the clause is not finished.
What to confirm against your regulator's guidance
A chatbot's description of a regulator's rules is not a source, and it is the most likely place for a confident error. Use the AI as a comparer and the published guidance as the source. Six points are worth confirming for any charity, and none of them is something to take from memory.
- Whether your regulator expects a complaints procedure, and how it describes the trustees' responsibility for it.
- If you ask the public for money, whether a fundraising code applies, and what it says about handling complaints and about where a complainant can go if you cannot resolve the matter.
- Which outside body, if any, takes unresolved complaints about a charity like yours, what it will and will not look at, and any time limit it sets. Some bodies take individual complaints and others look only at wider governance concerns, so read the body's own page before you write a sentence about it.
- Which incidents must be reported to the regulator or your insurer, and whether a complaint can trigger a report.
- How long records must be kept, who may see them, and when they must be deleted under data-protection law.
- Any duty to make the process usable by disabled people or by people who need language support.
One fundraising regulator's published complaints-handling guidance makes a useful benchmark. It is written for complaints about fundraising, but it says it could apply equally to all complaints, and its points read as sound practice for any charity. A complaint is an expression of dissatisfaction, however made, about something done or not done, and where it is unclear whether something is a complaint, treat it as one. The procedure should be simple, clear and easy to find, say what can be complained about and what a complainant can expect, and include timescales and possible remedies. Acknowledge receipt, set realistic time limits for each stage, and keep the complainant informed if a deadline slips. Use investigators independent of the events where possible, give a staff member complained about the chance to respond, and report on numbers, themes and resulting changes to senior management and the board. It sets no fixed number of days, only realistic and reasonable time limits. That is the useful lesson: the numbers in your policy are yours to choose, and the test is whether you can keep them.
To compare your draft with guidance you have downloaded, paste the relevant section into a chat, or attach the file, and ask: "List each expectation in this guidance as a checklist item and quote the exact sentence it comes from. Then compare my policy against each item and mark it Met, Partly met or Not met, quoting the clause." The quotation is what makes the answer checkable. Search the original for each quoted sentence, and treat any item the AI cannot quote as unverified.
Trustee sign-off: three ways to read it, then the minute
The reviewing trustee should read the policy three times, each from a different chair.
- As a complainant. Can you find the policy in two clicks from the home page? Does it tell you what happens next and when? Could you use it by phone, or with someone speaking for you?
- As the person complained about. Will you be told? Can you respond before a decision? Is there a route if you believe the process is biased?
- As a volunteer at the shop counter. What do you do in the next sixty seconds? Is there a card to hand over, and a name to pass the complaint to?
Then approve it at a meeting, and let the minute carry the facts that someone will ask about later (illustrative wording):
The board approved the complaints policy, version 1.0. The operations manager is the complaints lead and the shop manager is the deputy. Appeals are decided by a panel of two trustees with the board's delegated authority between meetings, reported at the next meeting. The retention period was agreed with the charity's data-protection adviser. Volunteers will be briefed at induction. The policy will be reviewed in twelve months, or sooner after any appeal.
A twelve-month review date is a choice; what matters is that a date and a trigger exist. Good triggers are an appeal, a change of complaints lead, and any update to the guidance you checked the draft against. For volunteers, the volunteer onboarding checklist is the natural place to add a five-minute briefing on what to do when someone wants to complain.
A complaints log and the summary trustees actually read
A policy with no log cannot report anything to anyone, and the guidance expects regular reporting to the board. The log is a spreadsheet, and the columns below are enough for a small charity. The dates are what give it value: they let you check the timescales without asking anyone.
| Column | What goes in it |
|---|---|
| ID and channel | A running number, and how it arrived (phone, email, post, counter, third party) |
| Category | A fixed list: service, fundraising conduct, volunteer conduct, communications, data, other |
| Dates | Received, acknowledged, due, outcome sent, closed; the due date worked out on a calendar |
| Owner and stage | Who holds it now, and whether it is informal, stage 1 or appeal |
| Outcome | Upheld, partly upheld, not upheld, or resolved informally |
| Remedy and lesson | What was put right, and what changed in how you work |
Each quarter, ask the AI to draft the board summary from an anonymised export of the log: IDs, categories, dates and outcomes, with no names and no free-text notes. A good summary is short and specific. Here is an illustrative one.
Quarter 3: 7 complaints, of which 5 were formal and 2 were resolved informally. Acknowledged within 5 working days: 6 of 7 (one at day 8 during leave cover). Outcomes within 20 working days: 5 of 5 formal complaints. Outcomes: 2 upheld, 1 partly upheld, 2 not upheld. Themes: shop pricing (3), volunteer rota communication (2), fundraising conduct (2). Changes made: a pricing notice at the counter; rota changes now confirmed by text message. Appeals: none.
Count the rows yourself before the summary goes to the board. A model can miscount, and a quick test is that the themes add up to the number of complaints (3 + 2 + 2 = 7). Over a year, watch three things: whether acknowledgements are on time, whether outcomes arrive within the promised days, and whether the same theme keeps returning. A theme that returns means the lesson column is being filled in and nothing is changing.
A one-page version for the website and a card for the counter
Most people will never read the full policy, so give them the short version. Ask the AI to produce it from the approved policy with two constraints: use only the approved numbers, and keep every sentence under 20 words. This is illustrative output for the website.
If you are unhappy with something we have done, please tell us. You can phone, email, write, or tell any member of staff or volunteer, and we will write it down for you if you prefer. First, we reply within 5 working days to say we have your complaint and when you will hear from us. Second, someone who was not involved looks into it and writes to you within 20 working days. Third, if you are not happy with the outcome, tell us within 15 working days and two trustees who were not involved will decide within 20 working days. We will not treat you differently because you complained, and your details are shared only with people who need them to deal with it.
Check readability in a tool that measures it. Word's built-in readability statistics give a reading-ease score, and 60 to 70 with a grade level of 7 or 8 is a common plain-English target. An AI's own claim about reading age is an estimate.
Volunteers need something shorter still, a card that lives by the till:
- Listen without interrupting, and say sorry that they have had a poor experience. Do not accept blame or promise an outcome; if you are unsure how far an apology can go, ask your insurer.
- If you can put it right on the spot within your limit, do so and tell the manager.
- If they want to complain formally, hand over the card, or write down their name, contact details and what happened, and pass it to the complaints lead today.
- If it mentions a child or an adult at risk, tell the safeguarding lead at once.
With a card, a log, a summary and a dated review in place, the policy is a working process rather than a document in a drawer. The same draft-then-check routine suits the charity's other policies, starting with the AI policy for a small charity that governs how staff and volunteers use tools like the ones in this tutorial. The trustee risk register for AI shows where a complaints policy fits among the board's other oversight jobs.
Questions trustees ask before adopting an AI-drafted policy
Which AI tool should I use for the draft?
Any of the main chat assistants will produce a workable first draft, because the quality comes from your inputs and your checks rather than the tool. A free plan is enough for a policy with no personal data in it. Run the review pass in a different assistant from the one that drafted, so the two have different blind spots.
Should the policy cover complaints from staff and volunteers?
Staff grievances and whistleblowing normally follow their own procedures, so name them in a short 'what this policy does not cover' clause with the route for each. Volunteers can use the complaints policy for complaints about the charity's services or conduct. Disputes about a volunteer's own role usually belong in the volunteer handbook.
How long should we keep complaint records?
Decide a period with your data-protection adviser and write it into the policy, because a policy that is silent on retention has a gap. Insurers, regulators and fundraising codes may set minimums, so check each. Keep the log and the outcome letter, and delete working notes on the schedule you state.
Can we use AI to reply to a real complaint?
Use it for structure and tone on a version with names, dates and details removed, then have a person rewrite and send it. Do not paste a complainant's identity, health details or case history into a consumer chat tool. A person who has read the whole file should sign the reply.
What if the complaint arrives as a public social media post?
If it is an expression of dissatisfaction, treat it as a complaint. Reply in one line to say you have seen it and invite the person to use a private channel, log it like any other, and keep details out of the comments. Answer on the same timescales you promise elsewhere, because a public post is the one a supporter is most likely to see.
Further reads
- Charity AI Risks: Data Protection, Deepfakes, and Donor Trust — The data-protection and donor-trust risks behind the complaint-handling rules.
- Claude AI for Charities: Five Admin Jobs Set Up With Projects — Keep the policy and log wording in a Project the team can reuse.
- Can AI Handle Customer Complaints Without Making Them Worse? — Where AI helps with replies and where it makes complaints worse.
- ChatGPT Prompts for Nonprofit Organisations: 10 for Admin and Donors — Ten prompts for admin and donor writing, each with merge fields instead of donor data, a sample output and the checks it needs before sending.
- Museum Accreditation Checklist: Policies and Evidence With AI — Copy your scheme's requirements into an evidence tracker, let AI find the policy gaps, and keep trustees as the approvers.
- Sports Club Code of Conduct: Player and Parent Versions With AI — Player and parent versions, a five-step sanctions ladder and a safeguarding link, drafted with AI and approved by your committee.
- How to Manage a Community Centre: Where AI Helps and Where It Cannot — Four tests that sort community-centre jobs into AI drafts and person-only decisions, with worked examples for bookings, rotas, newsletters and grants.
- AI Tools and AI Development: The Complete 2026 Guide — the AI hub, including every tutorial in the AI-for-business series.
Sources: a fundraising regulator's published complaints-handling guidance, read in October 2026 (definition of a complaint, timescales, independence of investigators, escalation, record keeping and board reporting). Every stage, timescale, number and sample clause in the examples is illustrative; set your own and confirm legal points against your regulator's guidance and a solicitor.