2.5 Feedback and Complaints

Page 1

6.1
2024
Version
January
Feedback and Complaints Management 2.5

2.5 Feedback and Complaints Management

2.5 Feedback and Complaints Management 2 of 18 Version 6.1 January 2024
Contents Preamble ............................................................................................................................. 3 2.5.1 Complaints Management System............................................................................ 3 2.5.2 Feedback and Complaints Processes 3 2.5.3 Continuous Improvement of Complaints and Feedback Processes ........................ 6 2.5.4 Informing Workers of Complaints Procedures ......................................................... 6 2.5.5 Whistleblower 6 Grievance Levels ................................................................................................................. 7 Level 1 Grievance ............................................................................................................ 7 Level 2 Grievance 7 Level 3 Grievance ............................................................................................................ 7 Procedures .......................................................................................................................... 8 Summary 9 CareMaster 10 NDIS Quality and Safeguards Commission ....................................................................... 13 Supporting Documents 14 Policies 14 Forms ............................................................................................................................. 14 Information 14 NGO Training 14 Legislation ...................................................................................................................... 14 NDIS Practice Standards and Quality Indicators 15 2.5 Feedback and Complaints Management 15 Human Services Quality Standards ................................................................................... 16 1 Governance and Management 16 5 Feedback, Complaints and Appeals 16 6 Human Resources....................................................................................................... 16 Delegation of Authority 16 Version Details 17

Preamble

BigDog Support Services Pty Ltd (BigDog) ensures that each client has knowledge of and access to the complaints management and resolution system. BigDog welcomes, acknowledges, respects and manages each complaint and feedback made by all parties.

BigDog listens to people and takes on feedback as a source of ideas for improving services and other activities. It includes the way BigDog responds to complaints from people using services and their right to have complaints fairly assessed and acted upon. It should also be recognised that being able to complain is empowering and BigDog has a philosophy of empowerment.

This fundamental right is a tool for change and improvement of service provision. As well it is a means of protection and accountability. It is therefore the responsibility of all involved with BigDog to have a clear understanding of the process and that the process is outcome based. The outcome may in fact be that a person has complained and that their complaint is recorded. Similarly, it may result in a change of a BigDog policy that has an overall effect. However, as a service provider it is up to us to ensure that we do whatever is required to provide the opportunity for this to be formalised with clients, so that we have measurable, accountable and transparent mechanisms. Both informal and the more formal opportunities for feedback both play an equal part in appropriate service delivery.

2.5.1 Complaints Management System

BigDog utilises the CareMaster complaints management and resolution system that is relevant and proportionate to the scope and complexity of supports delivered and the size and scale of our organisation.

The system follows principles of procedural fairness and natural justice and complies with the requirements under the National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018.

2.5.2 Feedback and Complaints Processes

BigDog listens to people and takes on feedback as a source of ideas for improving services and other activities. It includes the way BigDog responds to complaints from clients using services and their right to have complaints fairly assessed and acted upon.

Each client is provided with information on how to give feedback or make a complaint, including avenues external to the provider, and their right to access advocates. There is a supportive environment for any person who provides feedback and/or makes complaints. There is a separate policy that provides additional information and procedures for this particular practice standard.

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Key Elements

It should always be recognised that the client is the most vulnerable in the situation when they complain. They should therefore always be given the opportunity for appropriate advocacy when they make a complaint. This may mean using an external advocate.

A client may choose to complain in a medium other than verbally or in writing. They may need to utilise augmented or alternative communication means. This is to ensure that their views will be heard no matter what their disability.

It is the responsibility of the Directors, Workers, Volunteers or Contractors to ensure that clients are advised of their right to complain and to also make appropriate provision for clients to complain.

The Directors will be charged with the responsibility to ensure the integrity of the complaint process and to always be mindful of the inherent risk to clients in the process.

The Directors will ensure that a do no harm philosophy is followed.

The Directors are charged with following practices of natural justice in addressing issues.

A client must always be advised that they are entitled to speak to an independent person when they are making a complaint.

All complaints are to be recorded with outcomes and results and filed accordingly.

If the client is not satisfied and is funded through the NDIS, the client can contact the NDIS Quality and Safeguards Commission by calling 1800 035 544 or visiting ndiscommission.gov.au and make a complaint online.

Feedback

Compliments let us know what we’re doing well and help us recognise and reward our bestperforming people.

Clients are encouraged to complete the Client Compliment Form and tell us their positive story. It is an undertaking of BigDog that any staff member who is the recipient of a compliment will be informed of this compliment.

Written feedback is to be provided, in writing, by a director who is to ensure that all feedback is fair and transparent, is accessible and accountable and is handled expediently.

Clients, workers, and volunteers are also encouraged to give feedback through the surveys that are conducted annually. This feedback assists BigDog to review their services and practices and to inform the quality assurance process.

Appeals

BigDog also encourages any client who is dissatisfied with a decision or the written feedback to appeal against that decision and will be assisted to do so.

Any client or client representative can request a review of any decision made on the following basis:

• That not all available information was considered in reaching the decision,

• That subsequently more information has been discovered that was not previously available when the decision was being made,

• That the decision relied on information that has since found to be false.

Advocacy

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Advocating is speaking up for people with disability and helping them to get the things that they want and need.

Advocating for people with disability can be part of the work of BigDog. Sometimes when staff advocate for a person with disability there can be a conflict of interest. For example, a staff member must follow the rules of the service, but you might want something different. If there is a conflict of interest, it is generally better for you to ask for help from a separate advocacy agency. They will be able to independently advocate on your behalf.

An advocate is a person you choose to speak for you. They make sure that people listen to you. They might help you with talking or writing letters. There are many forms of advocacy.

Self-advocacy is when you speak up for yourself. Advocates from agencies can help you learn about your rights and how to speak up for yourself.

Informal advocacy is when you ask a friend or family member to speak up for you.

Family advocacy is when an advocate works with your parents and family members, so that the family knows how to best help you.

Citizen advocacy is when an advocacy agency matches you with a volunteer. The volunteer gets to know you and finds out what you need. They speak up for you and help you to get the support you need.

Individual advocacy is when an advocate works with a person to sort out bigger problems. These problems might be neglect, abuse or when your rights are not met.

BigDog will inform the client and other relevant stakeholders of any external avenues or appropriate supports for feedback, complaints or appeals and assist them to access or understand how they access them.

This may be sought through:

Anti-Discrimination Commission of Queensland

Complaints Infoline

Crime and Misconduct Commission (CMC)

Department of Communities, Disability Services

Department of Veteran Affairs

Disability Discrimination Commissioner – Australian Human Rights Commission

Office of the Public Advocate

Office of the Public Guardian

Queensland Ombudsman

ACROD - National Industry Association for Disability Services

The above list is not exclusive, and a client is entitled to be given as many options as possible to determine the most appropriate advocacy.

BigDog recommends TASC (formerly the Toowoomba Community Legal Service) which was founded in 1982 as the local legal service for disadvantaged people. Today TASC is nationally known for its innovative delivery of legal, and advocacy services across the whole south-west of the state and has worked with BigDog on a number of programs in the past.

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2.5.3 Continuous Improvement of Complaints and Feedback Processes

Working within a continuous improvement model allows us a framework in which to measure an activity, a process to implement and change, a process to trial and a method to analyse our results. It is also something that is not foreign to us as we enact this process in everyday life without the formality. A continuous improvement model is not just something that has been drawn up to ensure that as a service provider we strive for excellence, it is in fact how we behave in our day to day lives.

Plan-Do-Check-Act

Plan to improve BigDog operations first by finding out what things are going wrong (that is identify the problems faced) and come up with ideas for solving these problems.

Do changes designed to solve the problems on a small or experimental scale first. This minimises disruption to routine activity while testing whether the changes will work or not. Check whether the small scale or experimental changes are achieving the desired result or not. Also, continuously check nominated key activities (regardless of any experimentation going on) to ensure that you know what the quality of the output is at all times to identify any new problems when they crop up.

Act to implement changes on a larger scale if the experiment is successful. This means making the changes a routine part of your activity. Also Act to involve other persons (other departments, suppliers, or persons) affected by the changes and whose cooperation you need to implement them on a larger scale, or those who may simply benefit from what you have learned.

2.5.4 Informing Workers of Complaints Procedures

BigDog ensures all workers are aware of, trained in, and comply with the required procedures in relation to complaints handling.

Every worker of BigDog acknowledges that everyone has a right to complain. This fundamental right is a tool for change and improvement, as well as a means of protection and accountability. It is therefore the responsibility of all involved with the service to have a clear understanding of the process and that the process is outcome based. The outcome may in fact be that a person has complained and that their complaint is recorded. Similarly, it may result in a change of BigDog policy that has an overall effect.

To assist workers with the complaint process a Complaints Kit has been developed and is to be made available on request. BigDog has a Worker Grievance Procedure which outlines the process for workers making complaints.

2.5.5 Whistleblower

BigDog acknowledges that a transparent whistleblower policy is essential to good risk management and corporate governance. It helps uncover misconduct that may not otherwise be detected. Often, such wrongdoing only comes to light because of individuals (acting alone or together) who are prepared to disclose it, sometimes at great personal and financial risk.

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Grievance Levels

Level 1 Grievance

Clients and their advocates should feel free to speak directly with any person in the employ of BigDog stating their grievance and try to resolve the issue to their satisfaction at this point. This will be viewed as a non-formal complaint and seen as a collaborative way of resolving conflict or minor issues. Workers are required to record the grievance and pass this onto the Directors with the outcomes concluded within seven (7) days.

Level 2 Grievance

Clients and their advocates advise any worker they wish to make a formal complaint.

1. The worker will immediately advise the client of their right to make a complaint and ask how the client wishes to proceed.

2. This must be recorded on a Client Grievance Report with all relevant information and given to the Administration Officer.

3. The Administration Officer will record the date received and notify the Directors of the complaint at the earliest opportunity and a coordinator must be notified immediately.

4. Elements of the Client Grievance Report include:

a. Any immediate action taken

b. Recommended action

c. Details of responsible persons and their action roles

d. Date presented to the Management Meeting.

e. Response date and type.

5. A meeting must be scheduled with the client by an appropriate representative of BigDog as requested by the client to review and investigate the complaint.

6. All information is then to be forwarded to the Directors for assessment and direction. The directors are to acknowledge receipt of any grievance within two working days of receipt and an agreed time frame for the investigation of the grievance and follow up is to be negotiated between the Directors and the aggrieved party.

7. A directive may then be issued by a Director as to how to resolve the issue in the least intrusive manner, dependent upon circumstance.

8. All outcomes are to be recorded and a written response is to be given to the client or their advocate.

Level 3 Grievance

If there is no satisfactory outcome to a grievance of any client of BigDog, the Directors will assist the client to gain independent advocacy of their choice.

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Procedures

Complaints are best handled promptly and as close to the source as possible.

All complaints are to be taken seriously.

In negotiating outcomes, a Win-Win focus is to be employed where no parties are disadvantaged

Any complaint that has issues of legal impropriety must always be referred on to the appropriate legal authority.

Complaints will, whenever relevant, form part of BigDog continuous improvement.

All feedback is valued by BigDog.

Feedback is regularly sought from all stakeholders of the service. This includes workers, volunteers, clients and families.

Feedback helps to inform the quality assurance process.

Any decision made by BigDog can be appealed.

Any person can ask for more information in regard to a decision being made and can appeal that decision.

Public Interest Disclosures

The Queensland Ombudsman administers the Public Interest Disclosure Act 2010 (Qld) (PID Act). The PID Act provides unique protections from reprisal for public officers disclosing information in the public interest to an appropriate entity about: corrupt conduct maladministration waste of public funds negligent or improper management and a danger to public health, safety or the environment

In certain circumstances the PID Act also provides protection to members of the community who make a public interest disclosure about a danger to: public health and safety (including to the health or safety of a person with a disability) the environment and a reprisal

The organisation that receives and manages the disclosure must take action to protect a public officer from retribution or reprisal (such as bullying or harassment) for making a disclosure. This means a representative of the organisation may talk to the public officer about possible reprisals that may occur should another person identify the public officer as a discloser and determine how those possible reprisals will be managed to prevent them from occurring.

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Principles of Complaints Management Principle Description

Centred on people with disability

Management of a complaint is respectful of, and responsive to, a person with disability’s preferences, needs and values.

Outcome focussed Management of a complaint should reveal the factors that contributed to the complaint being made and seek to prevent matters giving rise to complaints from reoccurring, where appropriate.

Clear, simple and consistent

The process for receiving and responding to complaints is easy to understand, accessible and consistently applied.

Accountable NDIS providers are responsible for appropriately managing complaints. Everyone involved in the management of a complaint understands their role and responsibilities and will be accountable for decisions or actions taken in regard to a complaint.

Continual improvement

Proportionate

Surveys

The complaints process facilitates the ongoing identification of issues and implementation of changes to improve the quality and safety of NDIS supports and services.

The nature of any actions following a complaint will be proportionate to the issues raised and any risk of harm to people with disability.

Client surveys are important vehicles for BigDog, as they measure client satisfaction, and therefore help to determine client loyalty. A successful client survey requires clear and easy to understand questions and a simple method to record those responses. BigDog has developed a series of statements that broadly describe the internal dynamics of our service and we ask our clients to indicate whether they agree or disagree with the statement as it applies by "marking" the appropriate response. There are no right or wrong answers, so we ask that they please respond truthfully and not think too much about their answer and go with their first impression.

Summary

This policy applies to complaints, feedback or appeals received by BigDog. It does not apply to:

Minor issues raised with workers during normal client interaction Matters currently being dealt with or previously dealt with by an external complaint’s agency, tribunal or court Matters involving employment or worker conduct raised by other workers.

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CareMaster

Any Client Grievance can be logged and recorded from here. After clicking on the main menu, you can further select from the menu to show only Participant/Worker or Property incidents.

To create a new incident, click on the green New Incident button up to the top right. Enter in all details as below and click Save when finished:

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The client has the option to report incidents through both the worker app and the web portal. When the client has access to the web portal, they are limited to viewing only the incidents they themselves have created.

After an incident has been created, a director can edit it and upload related documents as needed.

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Green rows indicate resolved incidents, yellow indicates active incidents.

To the right of each incident there are 4 buttons:

Click on Edit to update/edit the incident or Details to just see an overview of the entered details. If you click on the Tick/Cross to mark the incident as Active or Resolved, and clicking on the red Bin icon will delete the incident.

Within the web portal, workers can:

1. Report new incidents.

2. Modify incident records they initiated.

3. They cannot make changes to incidents that have already been resolved.

4. They cannot mark a grievance as resolved or active.

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NDIS Quality and Safeguards Commission

The NDIS Quality and Safeguards Commission (NDIS Commission) is an independent government body that works to improve the quality and safety of NDIS funded services and supports.

The NDIS Commission can take complaints from anyone about:

NDIS services or supports that were not provided in a safe and respectful way.

NDIS services and supports that were not delivered to an appropriate standard.

How an NDIS provider has managed a complaint about services or supports provided to an NDIS participant

The NDIS Commission cannot take complaints from anyone about:

The NDIS

NDIS Plan access

NDIS participant plans

As well as dealing with complaints, the NDIS Commission works to educate providers about delivering quality and safe supports, and effectively responding to complaints. If a complaint raises a serious compliance issue, the NDIS Commission has powers to take action.

Participants are encouraged to try to talk directly to their NDIS service provider first to resolve a complaint. If they do not feel comfortable speaking to the provider or are not satisfied with the result of their complaint, contact the NDIS Commission.

In resolving an issue, the NDIS Commission may:

Request information to clarify the issues

Help you communicate with an NDIS provider

With participant consent, speak to the NDIS provider

Communicate responses from an NDIS provider to the participant.

A complaint can be withdrawn at any time.

An issue may be referred to conciliation or investigation. Conciliation helps everyone to understand the issues and to reach an agreement on how an issue can be resolved.

An investigation may be conducted if serious compliance issues or risks to people with disability are raised in the complaint.

NDIS Commission

Phone: 1800 035 544

Visit: www.ndiscommission.gov.au

NDIA or Commonwealth Ombudsman

Phone: 1800 800 110

Visit: www.ndis.gov.au or www.ombudsman.gov.au

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Supporting Documents

Policies

2.0 Governance and Operational Management

2.1.5 Continuous Improvement

2.5.5 Whistleblower Protections

Forms

BigDog Website – Have Your Say and Suggestion Box

CareMaster – Feedback and Complaints

Client Grievance Form

Client Survey

Service Improvement Form (SIF)

Information

External Complaints Agencies

Giving Feedback

Human Services Quality Framework October 2021 Version 8

NDIS (Complaints Management and Resolution) Rules 2018

NDIS Practice Standards November 2021 Version 4

Service Information

Speak Up Complaints (NDIS Commission)

Standards of Practice

NGO Training

Feedback, Compliments and Complaints

Communication and Supporting Skills

Solving Problems

To Stand Beside – Advocacy VALID

Legislation

All complaints that have issues of legal impropriety must always be referred on to the appropriate legal authority. All other complaints are to be considered confidential in accordance with the appropriate legislation:

Child Protection Reform and other Legislation Act 2022 (QLD)

Community Services Act 2007 (QLD)

Disability Discrimination Act 1992 (Cwth)

Disability Services and Inclusion Act 2023 (Cwth)

Disability Services Act 2006 (QLD)

Human Rights Act 2019 (QLD)

National Disability Insurance Scheme Act 2013 (Cwth)

NDIS (Provider Registration and Practice Standards) Amendment Rules 2021

Privacy Act 1988 (Cwth)

Public Interest Disclosure Act 2010 (QLD)

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NDIS Practice Standards and Quality Indicators

BigDog Support Services Pty Ltd (BigDog) is a registered NDIS provider and is required to apply the scheme’s practice standard and quality indicators. The standards have been developed to create an important benchmark to assess provider performance and ensure that high quality and safe supports and services are provided to NDIS participants.

The four core modules are:

1.0 Rights and Responsibilities;

2.0 Governance and Operational Management;

3.0 The Provision of Supports; and

4.0 The Support Provision Environment.

The supplementary modules cover:

5.0 Specialist Support

5.1 High intensity daily personal activities.

5.3 Implementing behaviour support plans.

2.5 Feedback and Complaints Management

Each participant has knowledge of and access to the provider’s complaints management and resolution system. Complaints and other feedback made by all parties are welcomed, acknowledged, respected and well-managed.

2.5.1 A complaints management and resolution system is maintained that is relevant and proportionate to the scope and complexity of supports delivered and the size and scale of the organisation. The system follows principles of procedural fairness and natural justice and complies with the requirements under the National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018.

2.5.2 Each participant is provided with information on how to give feedback or make a complaint, including avenues external to the provider, and their right to access advocates. There is a supportive environment for any person who provides feedback and/or makes complaints.

2.5.3 Demonstrated continuous improvement in complaints and feedback management by regular review of complaint and feedback policies and procedures, seeking of participant views on the accessibility of the complaints management and resolution system, and incorporation of feedback throughout the provider’s organisation.

2.5.4 All workers are aware of, trained in, and comply with the required procedures in relation to complaints handling.

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Human Services Quality Standards

The Human Services Quality Standards set a benchmark for the quality of service provision. Each Standard is supported by a set of performance indicators which outline what an organisation is required to demonstrate to meet that standard.

1 Governance and Management

Sound governance and management systems that maximise outcomes for stakeholders.

1.5 Mechanisms for continuous improvement are demonstrated in BigDog management and service delivery processes.

1.7 BigDog has effective information management systems that maintain appropriate controls of privacy and confidentiality for stakeholders.

5 Feedback, Complaints and Appeals

Effective feedback, complaints and appeals processes that lead to improvements in service delivery.

5.1 BigDog has fair, accessible and accountable feedback, complaints and appeals processes.

5.2 BigDog effectively communicates feedback, complaints and appeals processes to people using services and other relevant stakeholders.

5.3 People using services and other relevant stakeholders are informed of and enabled to access any external avenues or appropriate supports for feedback, complaints or appeals and assisted to understand how they access them.

5.4 BigDog demonstrates that feedback, complaints and appeals processes lead to improvements within the service and that outcomes are communicated to relevant stakeholders.

6 Human Resources

Effective human resource management systems, including recruitment, induction and supervisory processes, result in quality service provision.

6.5 BigDog ensures that people working in BigDog have access to fair and effective systems for dealing with grievances and disputes.

Delegation of Authority

Monique

Joel

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Name Position Details
Steven Paull Director Authorise review and implementation
Courtney Carroll Director Authorise review and implementation
David Burrett Operations Manager Ensure information dissemination
Paull HR Lawyer Ensure compliance by workers
Canning Accountant Taxation compliance

Version Details

This policy will be reviewed every twelve (12) months unless circumstances deem it necessary to review earlier. The review process will involve an analysis of the usefulness of the policy and to note any changes which are required to improve the policy.

If minor changes are made in wording or to clarify the intent, the version number will indicate this by adding a ‘point’ i.e. Version 1.0 indicates the original version and 1.1 with the first round of minor changes made. A significant change or intent of the policy will be indicated by a whole new number i.e. Version 2.0.

The following rules also apply in interpreting this policy:

• Headings are for convenience only and do not affect interpretation.

• A singular word includes the plural and vice versa.

• A word that suggests one gender includes the other genders. Date

October 2011

October 2011

March 2012

October 2013

February 2015

March 2015

Community Committee review policy – include Complaints Kit

1.2 Complaints kit developed and included in policy

1.3 Page header, new logo and page of pages

2.0 HSQF Standards replace Service Standard Indicators

Training sub-heading added to Supporting Documents

2.1 Updated CC Chairperson to Kerry Barker

Updated term 'Client' to NDIS term 'Participant'

Included list of relevant legislation for participant and employee complaints

External Complaints Agencies into Information Sheets

3.0 Consolidated Complaints and Disputes Policy and Participant Policy in a single HSQF Standard

Removed term ‘grievance’ to standard term ‘complaint’

Included imagery of forms and information sheets

July 2016

3.1

August 2016

October 2017

3.2

4.0

Added more information in key elements and removed reference to the Community Committee and CC representative

Changed ‘the director’ to ‘the directors’

Remove the procedure information

Added more information on feedback and appeals

Added NDIS information re grievances

Created an all-inclusive HSQF Policy to address each of the service standards indicators.

Included NDIS references

Returned supporting procedures to supporting policies

Updated Responsible Officers

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V Details
2009 1.0
Policy
2010 1.1
July
New Complaints
August
Updated “Service Provider” to BigDog

Date V Details

January 2019 4.1

January 2020 5.0

July 2020

Updated to new logo and style guide

Removed images of forms and information sheets

Removed HSQF Standards Indicators and Policy matched with NDIS Practice Standards and Quality Indicators

Front cover updated to Standards colour identification

Supporting Policies updated

Included Complaints Management Staff Training Module

January 2021 5.2 Updated Responsible Officers details

Changed ‘the director’ to ‘the directors’

Introduction of BigDog Training Portal and modules

January 2022 5.3 Updated officers and training modules

Combined policy with Client Grievance Policy

Included new policy Whistleblower Protections Policy

NDIS Practice Standards November 2021 Version 4

January 2023 6.0 Included Human Services Quality Standards and Child Protection Act and the term “Participant” is returned to “Client” to allow for policies to cover NDIS and Child Safety.

January 2024 6.1 Disability Services Act 1986 replaced with Disability Services and Inclusion Act 2023 and policy review process included.

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5.1

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