The objectives of Immigration New Zealand's new Complaints and Feedback Policy and Process are supported by the New Zealand Law Society.

The new policy and process was introduced in June 2017 and a post-implementation review of the new policy and process is now being undertaken.

"The Law Society supports the creation of a clearly defined policy and process by which clients and their representatives can lodge complaints and feedback with Immigration New Zealand," the Law Society says in its comments.

The Law Society comments that a six-month cut-off for complains seems unnecessarily strict.

"It is reasonable to encourage people to make their complaints properly but there should be an exemption to the strict cut-off where there are exceptional circumstances justifying the delay in making the complaint," it says.

While it is clear that the complaints and feedback process is not intended to be a forum to revisit the merits of INZ decisions, complaintants - particularly those who are self-represented - may not understand this, the Law Society says.

It says some complainants might have unrealistic expectations of what the complaints process can deliver for them in terms of the merits of their case. It would be helpful for some amendments to be made, to ensure that the Complaints Feedback Team (CFT) in its triage function takes responsibility for promptly explaining to complainants that their complaint is out of scope but that they may have appeal or reconsideration options.

"At a minimum, the CFT should advise such complainants that they should seek advice on their alternative options (such as seeking reconsideration of their application). This will need to be done promptly, to avoid prejudicing any applicable time limits for appeal/reconsideration."