Unreasonable behaviour policy

24 March 2025

This policy is to help London TravelWatch staff manage unreasonable or unreasonably persistent contact from those who appeal to us 

Dealing with complaints from someone who is unreasonable or unreasonably persistent can take up a disproportionate level of resources. London TravelWatch is accountable for the proper use of public funds and we must therefore ensure that our resources are used wisely and provide value for money. 

We will ensure that every appeal raised with us is reviewed and, where appropriate, we will make representations to the appropriate organisation where we believe there has been an injustice. However, we are unable to overturn or change the final decision made by a transport provider or ticket retailer. 

In a very small number of cases, people can pursue their complaints or queries in a way which can either hinder our investigation or create serious resource issues. These actions can occur either while their complaint is being investigated, or once we have concluded our investigations. 

Defining unreasonable or unreasonably persistent behaviour 

Persistence is different to being unreasonably persistent due to the number and type of contacts someone makes or by continued contact. Unreasonable or unreasonably persistent behaviour has been defined by London TravelWatch as: 

1. making numerous, continued or scattergun contacts by phone or email to our staff, that does not allow give a caseworker an opportunity to both review a complaint and make representations on behalf of the person complaining. Continuous contact will delay any appeal being made. 
2. continually demanding an immediate response 
3. continually demanding that London TravelWatch provides an outcome which it has previously explained it is unable to secure 
4. appeals which are obsessive, unreasonable or personal to an individual staff member
5. making many appeals about different issues in succession and/or insisting on a financial reward for each 
6. new appeals with minor alterations on matters we have already dealt with or insisting upon effort disproportionate to the matter pursued
7. making unsubstantiated accusations against the organisation or specific employees
8. repeated contact insisting on an outcome that would negatively affect other passengers 
9. repeated contacts refusing to accept a final decision. 

Using this policy 

The Head of Casework may decide to activate this policy to manage a passenger’s appeals. London TravelWatch may: 

• insist that someone complaining confirms in writing all the points that the caseworker will raise with a transport provider or ticket retailer before an appeal is made. This is to ensure all elements of the appeal are captured at the outset and to prevent additional issues being raised at a later time 
• refuse to take certain aspects of an appeal forward where there is no added value to the complaint 
• only liaise with a passenger in writing 
• refuse to continue liaising on a case where a final decision has been given 
• provide a dedicated caseworker for all the passenger’s appeals 
• only respond within specified timeframes and at no other time
• will cease to correspond if the request or appeal is frivolous or vexatious

Appealing the decision to use this policy 

You can appeal the decision to activate this policy to manage your appeals by contacting our CEO, Michael Roberts at info@londontravelwatch.org.uk, who will make the final decision. There is no further appeal process. 

For TfL appeals only. Where someone remains unsatisfied with their appeal outcome with a TfL complaint, they can take their complaint to the Local Government and Social Care Ombudsman (LGSCO). The LGSCO will check our handling of the case and can provide direction if they believe we have not carried out our role to our own standards. The LGSCO will not re-investigate the appeal and they cannot direct London TravelWatch to provide an outcome that is not within our gift to achieve. NB The LGSCO will only consider complaints about TfL.

London TravelWatch will not engage with any person who uses discriminatory, abusive or threatening language against any London TravelWatch staff member.