The services that worried me as an inspector were rarely the ones with a lot of complaints. They were the ones that appeared to have almost none. A very thin complaints log can feel reassuring, and it can also raise a fairly obvious question: are patients genuinely raising very few concerns, or is the service simply not seeing everything people are trying to tell it?
Those are very different things. Complaints, surveys, informal concerns and online reviews are not just records of dissatisfaction; taken together they are an early-warning system. When that system is working, small problems get caught while they are still small. When nobody is watching it, repeated weaknesses sit in plain sight for months.
Low complaint numbers are not evidence of good care on their own
There is an understandable temptation to present a nearly empty complaints log as evidence that a service is running well, but the number alone tells you very little. Complaint volumes are influenced not only by the quality of care but by how easy a service makes it for people to speak up. Does the patient know how to complain? Will staff recognise an informal concern as something worth recording? Does the patient believe they will be taken seriously? Will complaining affect an ongoing relationship with their clinician, and can they raise something without having to confront the person they are unhappy with?
These questions matter particularly in independent healthcare, where there is often an additional commercial relationship between the patient and the provider. Someone can be dissatisfied without ever making a formal complaint. They may mention something to reception and decide not to pursue it, request a refund, cancel further treatment, or say nothing to the service at all and write about the experience online instead.
None of those signals automatically means there is a problem with care. But a provider that counts only formal complaints is seeing one part of its patient experience and calling it the whole.
Why I looked at Google reviews during inspections
I would often look at a service's Google reviews before or during an inspection. I was not particularly interested in whether the service had 4.2 stars or 4.8. I was looking for two things: whether the same themes appeared repeatedly, and whether there was any evidence that the service was listening.
The issues themselves were often ordinary. Communication, waiting times, appointments running late, confusion about fees, uncertainty about follow-up or test results, cleanliness, the way somebody had been spoken to. And, of course, many reviews were positive.
An online review is not proof that something happened exactly as described. Reviews can be incomplete, subjective, unfair or occasionally malicious. That is not a reason to ignore them: they are still information being offered publicly by people describing their experience of the service.
What concerned me was when the same issues had appeared for months and nobody within the service seemed to know. No one monitored the reviews and no one had responded. The themes had not reached a governance meeting, prompted an audit, or produced an improvement action. Nobody had stopped to ask whether several apparently minor comments might be describing the same underlying problem.
At that point the concern was no longer the individual Google review. It was the monitoring system.
CQC is still finding this in practice
This is not a theoretical inspection concern, and recent assessments continue to show the distinction between having feedback and actually using it. In one 2026 assessment, a provider told CQC that it had received no formal complaints and that minor concerns were resolved immediately without being recorded, while other records reviewed by CQC referred to complaints having reduced. The two accounts could not both be right. In another recent assessment of an independent medical clinic, CQC found that the service relied partly on Google reviews and feedback given during consultations, but could not demonstrate that patient feedback had been analysed or that improvements had been made as a result.
The lesson is not that every conversation needs to become a formal complaint. It is that resolving something informally should not make the information disappear: a concern can be dealt with on the spot and still be worth recording as a signal.
Your complaints log is only one feedback channel
Patient experience reaches a provider through many routes:
- formal complaints
- patient surveys and questionnaires
- compliments
- online reviews
- informal concerns raised with reception or clinical staff
- concerns raised by relatives or carers
- feedback raised by staff on behalf of patients
- recurring refund, cancellation or service-contact themes where these indicate dissatisfaction.
None should be interpreted mechanically. A cancellation does not necessarily mean a patient is unhappy, and neither does somebody choosing not to return. The value comes from looking across sources rather than drawing conclusions from one data point.
Imagine a complaint about delayed results. On its own it may be an isolated event. Now imagine the same issue appearing in two Google reviews, several survey comments and repeated questions to reception. That is a different picture. No single piece of evidence proves a systemic failure, but together they give the provider a reason to look. That is what triangulation is for, and it is the same discipline that turns a pile of incident records into a theme rather than a filing cabinet.
Feedback is part of governance, not a separate customer-service exercise
CQC's current Listening to and involving people quality statement expects services to make it easy for people to give feedback, raise complaints and understand what changed as a result, and the Learning culture statement connects complaints and concerns with learning and improvement.
Regulation 16 requires providers to operate an effective and accessible complaints system, investigate complaints appropriately, take proportionate action where failures are identified, maintain records, and monitor complaints over time for trends and areas of risk. That page sets out the duty itself, along with what an inspector asks to see against it.
The important point here is simpler. CQC is not interested only in whether a complaints policy exists; the more useful question is whether information from complaints and other feedback reaches the people who can do something with it. That is where complaints become governance, and where Regulation 17 and good governance picks the thread up.
What a working feedback loop looks like
The strongest services could usually tell a straightforward story:
We received this feedback. We looked into it. This is what we found. This is what we changed. And this is how we checked whether the change worked.
That is a great deal more reassuring than "we do not really get complaints." Each part of the first answer should leave some evidence behind, and how the evidence loop works sets out the same shape across every kind of record.
We received it. The concern is visible somewhere appropriate, because staff understand what should be recorded rather than assuming an issue disappears once it has been resolved at reception.
We looked into it. Someone considered what had happened and whether further investigation was proportionate.
This is what we found. The service records the outcome, and a complaint does not have to be upheld to be useful: clinical care may have been entirely appropriate while the investigation still identifies poor communication, unclear information or an avoidable delay.
This is what we changed. Where action is required, there should be something more meaningful than "staff reminded". What changed, who owns it, and when should it happen?
This is how we checked. This is the part I most often found missing. An action was agreed, everyone moved on, and nobody went back later to ask whether the problem had actually improved. Without that final step you have evidence of activity, not assurance.
One complaint, nine records follows a single complaint through all five of those stages in a surgical clinic, if you would like to see the shape of it in practice.
Look for themes above individual complaints
Processing individual complaints well matters, but governance sits one level above that. Someone needs periodically to ask what people have been telling the service overall: whether the same issues recur, whether certain clinicians, services, locations, times of day or parts of the patient journey appear repeatedly, whether formal complaints tell the same story as survey responses, whether online reviews highlight something the internal log does not, and whether a problem everybody thought was fixed has come back.
That is where a complaints log becomes useful beyond the individual case. It stops being an archive and becomes a source of organisational intelligence, which is the whole argument behind treating complaints as a managed lifecycle rather than a folder of letters.
There is good current CQC practice to illustrate the difference. In a 2026 assessment where feedback systems were working well, CQC noted that the provider undertook quarterly thematic review of complaints, identified learning, and considered whether the actions taken had actually had an impact. That is considerably more valuable than reporting that three complaints were received and three were closed.
Responding to online reviews: listen publicly, investigate privately
Healthcare providers sometimes avoid responding to negative online reviews because of confidentiality concerns, and the caution is justified. For doctors and other professionals covered by GMC standards, public criticism does not remove the duty of confidentiality: a response must not disclose confidential information about a patient, or give a public account of their care, without appropriate consent. An online argument about the facts of somebody's treatment is usually the wrong response.
But confidentiality does not require a provider to ignore the review. A proportionate public response can acknowledge the feedback, explain that individual circumstances cannot be discussed publicly, and give the person a route to contact the service privately.
The important work then happens away from Google. Does the concern need investigating? Does it repeat an existing theme? Does it raise a safety, safeguarding or duty of candour issue? Is there something the service needs to change? The public reply is not the governance process; it simply shows that the feedback channel is being watched.
Make the independent route clear
Independent providers also need to be clear about where a patient can go if a complaint cannot be resolved internally, and the correct route depends on how the care was funded and the type of service.
The Parliamentary and Health Service Ombudsman does not investigate complaints about privately funded healthcare, although it can consider NHS-funded care delivered by an independent provider, and it signposts privately funded complainants to ISCAS where that applies. For eligible independent healthcare organisations treating private patients, ISCAS provides a voluntary complaints framework with independent adjudication for subscribers, and private dental care has a different external route through the Dental Complaints Service.
The practical governance question is not whether the correct organisation is named somewhere in a policy. Ask instead whether a patient could easily find the right escalation route today, and whether your staff would know what to tell them. A complaints policy sitting in a folder is not much help if the patient-facing information is wrong, inaccessible or out of date. If you are starting from nothing, the complaints policy template and the complaint-handling checklist are both free to take and adapt.
Do not become defensive about the record
I understand why complaints make providers uncomfortable. There can be an instinct that writing something down creates evidence against the service, so the issue gets dealt with informally: a conversation happens, the patient appears satisfied, nothing enters the complaints or feedback system, and the record stays clean.
From an inspection perspective that has the opposite effect from the one intended. A service that can show it receives concerns, investigates them, learns and follows through is demonstrating that its governance is alive. A service claiming that almost nobody ever complains simply invites the next question: how do you know?
Openness about problems is not evidence of poor governance. Repeatedly failing to see them can be.
The bigger question behind an empty complaints log
Feedback channels are rarely neglected in isolation. When I found online reviews that nobody appeared to have read, it made me look wider: what other information was arriving without being used? Were audit findings being acted on, were incidents producing learning, did staff concerns reach governance meetings, were risk controls checked after they were introduced, and did actions remain open month after month?
That is why something as apparently minor as unanswered Google reviews could concern me during an inspection. It was not that every provider needs to defend itself on the internet. It was that a service's response to feedback tells you how it handles information generally, which is the same instinct approached from the other direction in what evidence means to a CQC inspector and, more practically, in preparing for inspection.
The problem is not having complaints. The problem is not knowing what your patients are trying to tell you. And if nobody is watching what patients are saying in public, it is reasonable to ask what else is nobody watching.
Sources
- Care Quality Commission, Regulation 16: receiving and acting on complaints.
- Care Quality Commission, Listening to and involving people.
- Care Quality Commission, Learning culture.
- Care Quality Commission, 2026 assessment reports covering complaints, informal concerns, online reviews and thematic learning.
- Parliamentary and Health Service Ombudsman, private healthcare.
- Independent Sector Complaints Adjudication Service, information for healthcare providers.
- General Medical Council, confidentiality and responding to criticism in the media.