Commentary on Clauses Part 2: Investigations Section 26: Form and time limit for making complaint
It is for the NIPSO to determine the way in which complaints are to be submitted.  For example, the NIPSO could allow complaints to be made in writing, by email or online.  This could include a special procedure for allowing oral complaints in special circumstances as long as these are subsequently reduced to writing.  The ordinary time limit for making a complaint to the NIPSO is 6 months from the day that the complaints handling procedure has been exhausted.  If the NIPSO has decided to accept a complaint which hasn’t exhausted the internal complaints handling procedure, the time limit is 12 months from the day that the person aggrieved first became aware of the problem.