oses of the consideration by the agency of any representations (including complaints). 114 Sections 26(3) and 26(3B) of the Children Act 1989 (the 1989 Act) require local authorities to establish a procedure for considering representations, including complaints, and for involving an independent person in that consideration. The Voluntary Adoption Agencies and Adoption Agencies (Miscellaneous Amendments) Regulations 2003 require VAAs to establish a complaints procedure. Regulation 11 of those regulations requires the agency to establish a written complaints procedure and regulation 12 provides for complaints to be fully investigated. Where an independent person has been appointed by the agency to consider any complaint or representations in relation to adoption services, they are likely to require access to the agency’s case records in order properly to investigate the complaint. In relation to adoption services, service users are children who may be adopted, birth parents and guardians, prospective adopters, adopted people and adoptive parents or any other person who the agency considers has sufficient interest in a child who is or may be adopted to warrant his representations being considered by them. See section 3(1) of the Act.  To a panel constituted under section 12 of the Act to consider a qualifying determination. Section 12 of the Act provides for an independent review mechanism (IRM) to be established to review a range of qualifying determinations made by the agency. Qualifying determinations may be made in respect of:  the suitability of a prospective adopter to adopt under AAR 30B; and  disclosure of ‘protected information’ under section 61 of the Act where AIR 15 sets out the duties of an agency where application is made to the IRM. Where the case record 