JIP-IMAC112E-1.3

Information Management Systems (IMS)

Procedures for Responding toComplaints and Appeals on IMS Accreditation
JIP-IMAC112E-1.3

January 9, 2024

ISMS Accreditation Center (ISMS-AC)
1-9-9 Roppongi, Minato-ku, Tokyo 106-0032 Japan
Tel.+81-3-5860-7570
Fax.+81-3-5573-0564
URL https://isms.jp/
Copyright © ISMS-AC All rights reservedThis document is translated into English by ISMS-AC.
The Japanese version shall be the authorized version.
In the event of any question as to the English version, comply with the original(Japanese) version.
ISMS-ACCONTENTS1.

Scope ............................................................................................................................. 1

2.

Related documents ....................................................................................................... 1
2.1 Complying standard .................................................................................................. 1
2.2 Normative references ................................................................................................ 1
2.3 Related standards ...................................................................................................... 1

3.

Terms and definitions ................................................................................................... 1

4. How to lodge complaints/ appeals................................................................................... 2
4.1 Contact representative .............................................................................................. 2
4.2 Complaint procedure ................................................................................................. 24.3 Appeal procedure ....................................................................................................... 24.4 How to send the Form ............................................................................................... 2
5. Accepting and handing complaints ................................................................................. 3
5.1 Accepting complaints ................................................................................................. 3
5.2 Cases where ISMS-AC takes actions ........................................................................ 3
5.3 Cases where ISMS-AC does not take actions ........................................................... 45.4 Cases which are not subject to this procedure or which are not to be accepted ..... 45.5 Response to complaints and resubmission ............................................................... 56. Accepting and processing appeals .................................................................................. 56.1 Acceptance appeals .................................................................................................... 56.2 Deliberation on appeals ............................................................................................. 66.3 How an appeal affects accreditation assessments and accreditation expiry dates 67. Disclosure of complaints and appeals ............................................................................ 78. Records ............................................................................................................................ 7Annex A Complaint Processing Flow.................................................................................. 8Annex B Processing Flow of complaintsagainst organizations/certification bodies……...9Annex C Processing Flow of complaints against auditors/ certification bodies of persons........................................................................................................................................... 10Annex D Processing Flow of complaints dealt within ISMS-AC..................................... 11
Annex E Appeal Processing Flow ..................................................................................... 12

JIP-IMAC112E-1.3

1.

ScopeThis document specifies the procedures for ISMS Accreditation Center (ISMS-AC) todeal with complaints and appeals related to the accreditation activities.
2.

Related documents

2.1 Complying standard
This document complies with the relevant clauses in the following standard.
ISO/IEC 17011:2017 Conformity assessment – Requirements for accreditation bodies
accrediting conformity assessment bodies
2.2 Normative references
The following documents contain provisions, which, through references in this text andonly to the extent of the reference, constitute provisions of this procedure.
ISO/IEC 17000:2022 Conformity assessment – Vocabulary and general principlesISO 9000:2015 Quality Management System – Fundamentals and vocabulary
2.3 Related standards
ISO 10002: Quality management – Customer satisfaction – Guidelines for complaints
handling in organizations
JIP-IMAC110 Procedures for Accreditation of IMS Certification Bodies
3.

Terms and definitions

For the purpose of this document, the relevant definitions in the standards listed inclauses 2.1 and 2.2 and the following definitions apply.
1)complaint: lodging of dissatisfaction from individuals/ organizations pertaining
against the activities of ISMS-AC, or certification bodies or certification bodies ofpersons accredited by ISMS-AC, and lodging of dissatisfaction excluding appeals
from certification bodies or certification bodies of persons

2)

appeal: dissatisfaction and request pertaining to the accreditation decision fromcertification bodies or certification bodies of persons accredited or to be accreditedby ISMS-AC

3)

certification body: a body which certifies organizations’ management system

4)certification body of persons: a body which certifies persons, and here the term
refers to a body which evaluates and registers auditors

15)

CB: a collective term for certification body and certification body of persons

6)organization: an organization certified or to be certified by a certification body thatis accredited by ISMS-AC7)

auditor: an auditor who is registered or wishes to be registered to a certificationbody of persons that is accredited by ISMS-AC and an auditor who is formallyapproved as such by a certification body8)

complaints/ appeals handler: a person in ISMS-AC who is appointed by Director ofAccreditation Services to handle complaints/ appeals. In principle, Registration
Manager shall be in charge of this.

9)

Conciliation Committee: a board in ISMS-AC which deliberates complaints andappeals10) complainant/ appellant: a person, an organization or their representative wholodges complaints/ appeals11) complaining/ appealing body: a certification body or a certification body of persons
which lodges complaints/ appeals
4. How to lodge complaints/ appeals
4.1 Contact representative
The following is the contact representative for complaints and appeals.
Registration Manager, ISMS Accreditation Center
4.2 Complaint procedure
A complainant shall submit a Complaint Form in writing to the contact representativewith the details of the complaint identifying the date, the complainant’s name andcontact details in principle.
Note: Refer to the website of ISMS-AC for how to fill out a complaint form.
4.3 Appeal procedure
An appellant CB shall submit an Appeal Form in writing (any format is acceptable) in
principle to the contact representative in the name of the representative of the CB.
The appellant CB shall notify the intention to appeal within 10 days following thereceipt of an accreditation decision notice and send a formal Appeal Form within 30days. When these due dates are passed, the appeal shall be invalid.
4.4 How to send the Form
Complaints/ appeals shall be documented and sent by postal mail, facsimile or email. In2

case of email, the attachment can be regarded as a document.
The procedure in this document does not apply to telephone conversations or the text ofemail.
The language for complaints/ appeals lodging shall be Japanese.
5. Accepting and handing complaints
5.1 Accepting complaints
When ISMS-AC receives a complaint form, it shall decide according to Annex A whether
to take actions in reference to Annex B – D or to request a complainant to take actions.
-Complaints against the accreditation activities of ISMS-AC – Refer to Annex D-Complaints against certified organizations/ certification bodies – Refer to Annex B-

Complaints against auditors/ certification bodies of persons – Refer to Annex C-Cases where ISMS-AC takes actions toward complaints against parties other thanitself – Refer to Annex D

5.2 Cases where ISMS-AC takes actions
The complaint handler checks if the content of a complaint meets the conditions foracceptance. If the complaint is determined to be dealt with by ISMS-AC, the complainthandler shall notify the complainant of acceptance in accordance with Annex D.
Complaints are classified to be handled as follows. Director of the Accreditation Services
decides if the issue shall be dealt with by the Conciliation Committee.
1) Cases where the complaint handler takes actions
The complaint handler shall check the facts surrounding the case and reply directly tothe complainant after hearing the opinions of the accreditation assessors and theparties concerned as appropriate.
2) Cases where the Conciliation Committee takes actions
When the Conciliation Committee is going to be held to deal with complaints, thecomplainant shall be notified to that effect.
The Conciliation Committee to deliberate complaints shall be comprised of more than
two members including external experts, chosen from the pre-selected members taking
into account the content of the complaints. It shall be confirmed in advance that there isno conflict of interest between the members and the case and the confidentiality pledge
shall be signed by the selected Conciliation Committee members.
The complainant can inquire about the composition of the Conciliation Committee andsubmit objection to a specific member if well founded.
3

The complainant can present its opinion at the Conciliation Committee.
5.3 Cases where ISMS-AC does not take actions
1) Complaints against certified organizations
Complaints against organizations certified by certification bodies accredited by
ISMS-AC will not be dealt with in this procedure. ISMS-AC will request thecomplainant in accordance with Annex B to first lodge it to the relevant organization orthe certification body.
When the complainant does not want to lodge directly to the organization or thecertification body, ISMS-AC accepts it as a complaint and may request the certificationbody to investigate the situation. When ISMS-AC finds it necessary, it will notify the CB
that a complaint against it has been lodged to ISMS-AC and disclose the information
obtained from the complainant with its consent.
2) Complaints against auditors
Complaints against the qualification of auditors registered to certification bodies ofpersons accredited by ISMS-AC will not be dealt with in this procedure. ISMS-AC shallrequest the complainant to first lodge it to a certification body of persons in accordancewith Annex C.
Complaints against an auditor’s audit methodology and ethical issues shall not be dealt
with in this procedure. ISMS-AC will request the complainant to first lodge it to therelevant certification body.
When the complainant does not want to lodge directly to the relevant CB, ISMS-AC
accepts it as a complaint and may request the CB to investigate the situation.
When ISMS-AC finds it necessary, it will notify the CB that a complaint against the CB
has been lodged to ISMS-AC and disclose the information obtained from thecomplainant with its consent.
3) Complaints against certification bodies or certification bodies of persons
ISMS-AC shall request the complainant to first lodge complaints against a certificationbody accredited by ISMS-AC to the relevant certification body in accordance with Annex
B. ISMS-AC shall request the complainant to first lodge complaints to a certificationbody of persons accredited by ISMS-AC to the relevant certification body of persons inaccordance with Annex C.
5.4 Cases which are not subject to this procedure or which are not to be accepted
1) Cases which don’t meet the conditions for complaints

4When a complaint form is not adequately filled out or when a complaint does not meetthe conditions to be accepted, such as not being relevant to the ISMS-AC’s accreditation
activities, those cases will not be subject to this procedure.
Cases where the content of the complaint is the same as those on trial or in conciliation
process will not be subject to this procedure.
2) Complaints from parties requesting anonymity
Complaints from anonymous parties shall not be accepted in principle. However, assome of the complaints from anonymous parties such as whistle-blowing could be highly
credible and have social significance, they could be handled by ISMS-AC not inaccordance with this procedure.
3) Cases which are not accepted as ISMS-AC cannot take actions
Apart from the cases of anonymity, cases where a name and contact details are notknown or cases which are not obviously deemed to be a complaint cannot not beaccepted.
4) Complaints without complainants
When events, incidents or breach of laws and regulations which can lead to a social
problem and will adversely affect the operation of the conformity assessment scheme ofISMS-AC are covered by mass media, even though there are no complainants, they
could be handled by ISMS-AC not in accordance with this procedure.
5.5 Response to complaints and resubmission
The results of investigation by the complaint handler or the Conciliation Committee
shall be sent to the complainant within 30 days.
If the response cannot be provided within 30 days, the latest situation and thescheduled date of response shall be notified to the complainant.
When new facts, evidences and change in the situation arise after the initial submissionof complaints or ISMS-AC’s response, the complainant can resubmit a complaint within
30 days from receiving a reply from ISMS-AC.
6. Accepting and processing appeals
6.1 Acceptance of appeals
The appeal handler shall check if the content of an appeal meets the conditions foracceptance in accordance with Annex E. If the appeal is determined to be dealt with by
ISMS-AC, the appeal handler shall notify the appellant of the acceptance. When the5case does not satisfy the requite to be handled as an appeal e.g. which is not relevant toISMS-AC’s decision on accreditation decision, it shall not be dealt with in accordancewith this procedure or not be accepted.
6.2 Deliberation on appeals
1) Cases where the appeal handler takes actions
The appeal handler shall check the facts surrounding the case and reply to theappellant in writing within 30 days after hearing the opinions of the accreditationassessors and the parties concerned as appropriate.
If the appellant body is not satisfied with the reply, the appellant shall contact ISMS-AC
withing 10 days of the reply from IAMS-AC and request within 30 days for conciliationin the Conciliation Committee. When these due dates are passed, the appellant isdeemed to agree to the reply from the appeal handler. ISMS-AC shall send a letter of
acceptance in response to the request for actions at the Conciliation Committee.
2) Cases where the Conciliation Committee takes actions
The Conciliation Committee to deliberate the appeals shall be comprised of more than
two members including external experts, chosen from the pre-selected members taking
into account the content of the appeals. It shall be confirmed in advance that there is noconflict of interest between the members and the case and the confidentiality pledge
shall be signed by the selected Conciliation Committee members.
The appellant can inquire about the composition of the Conciliation Committee andsubmit objection to a specific member if well founded.
The appellant can present its opinion at the Conciliation Committee.
ISMS-AC shall notify the appellant of the deliberation results at the Conciliation
Committee in writing within 60 days from the acceptance date of the request.
6.3 How an appeal affects accreditation assessments and accreditation expiry dates
When an accreditation assessment is being conducted and it is decided that a CB’saccreditation shall be withdrawn, suspended or its scope shall be reduced due to otherreasons which are not relevant to the assessment at that time and an appeal is raised
against the decision, the assessment shall be suspended. The assessment shall beresumed when the appeal is closed out.
Withdrawal, suspension or reducing the accreditation scope shall be suspended until
the appeal against them is closed. When the accreditation expiry date comes aroundduring that period, the extension of the expiry date shall be deliberated in theAccreditation Review Board.
67. Disclosure of complaints and appeals
Complaints and appeals dealt with in the Conciliation Committee and the outline of theresults from the actions taken shall be disclosed in principle. Even the cases which were
not dealt with in the Conciliation Committee shall be disclosed if deemed appropriate.
The name of a complaining/ appealing person, an organization or a CB shall be disclosed
where deemed appropriate with the consent of the complainant/ appellant.
8. Records
The process from the receipt to closure of complaints and appeals, the results and otherrelated issues shall be recorded. Although these records are not to be disclosed, it can bedisclosed for investigation required by law and for the evaluation of IAF/APAC andinternal audits with confidentiality protection such as nondisclosure agreement.
Complaints against certification bodies and certification bodies of persons can bereferred to in accreditation assessments with confidentiality protection.

7Annex A

Complaint Processing FlowClassification of complaints

Complaints about acertified organization
or a certification body?

The contact representative ofISMS-AC receives acomplaint
Yes

Refer to Annex B

NoComplaints about anauditor or a certificationbody of persons?
The complaint meetsthe conditions to be
accepted in ISMS-AC?

Yes

Refer to Annex CNo
Yes
NoNot subject to this procedureor to be dismissed

8

Refer to Annex DAnnex B

Processing Flow of complaints
against organizations/certification bodies
Complaints against

Complaints againstorganizations

certification bodies

WhenISMS-AC
contact
representative receives a complaint
against an organization, it requests
the complainant to lodge thecomplaint
totherelevantorganization, and to lodge it to therelevant certification body when thecomplainant is not satisfied with theresponse of the organization.
The complainant lodges thecomplaint to the organization.
Is the complainantsatisfied with theorganization’sresponse?

Is the complainantsatisfied with thecertification body’sresponse?

Yes

Close

No

The complainant lodges
against the certification
body.
Yes
No
The complainant lodges thecomplaint to ISMS-ACagain

Go to the complaint
processing flow in Annex D

9CloseWhenISMS-ACcontact
representative receives a complaint
against a certification body, it
requests the complainant to lodge
the complaint to the relevant
certification body.

Annex C

Processing Flow of complaints
against auditors/ certification bodies of persons

Complaints against auditors’Complaints against auditors’auditing methodology andqualification

When the contact
representative of ISMS-AC
receives the complaints above,it requests the complainant tolodge to the certification body
if known.

When the contact
representative of ISMS-AC
receives the complaints
against auditors, it requests
the complainant to lodge tothe personnel certificationbody.

The complainant lodges
the complaint to theorganization.

The complainant lodges thecomplaint to the certificationbody of persons.

Is the complainant satisfied
with the certification body’s
response?

Yes
No

The complainant lodges thecomplaint to ISMS-AC again

Gotothecomplaint
processing flow in Annex A

10When ISMS-AC contact
representative receives acomplaint
againstacertification body, it requests
the complainant to lodge thecomplaint to the relevant
certification body.

Is the complainant satisfied
with the certification body ofpersons’ response?

Close

No

certification bodies ofpersons

ethical issues

Yes

Complaints against

CloseAnnex D

Processing Flow of complaints dealt within ISMS-AC
ISMS-AC takes actions

The complaint meets theconditions for acceptance.
Notify the complainant of
the acceptance
Preliminary investigation
by Handler
Can be handled
by Handler?

Summon,investigate andmake conclusions

Disclosure

Re-investigation byHandler

Yes
No
Handled in theConciliation Committee

Handler takes
actions

Handler notifies thecomplainant of the results

Did new facts,
evidence and change
in the situation arise?

Yes

Resubmission accepted?

Resubmission

Yes

NoCloseNoDismissal11Annex E

Appeal Processing Flow
Appeal from CABs

The contact representative ofISMS-AC receives an appeal
The appeal meets theconditions to be
accepted in ISMS-AC?

Not subject to thisprocedure or to bedismissed

Ｎｏ

Ｙｅｓ

Notify the appellant
body of the acceptance.

Investigation by the handler
and notification to the appellant
The appellant is notsatisfied with the noticeand refiles the appeal?

ＮｏＹｅｓ
Deliberation at theConciliation Committee
Notification to the appellant

Disclosure
Close

12