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Housing Ombudsman Complaint Handling Code – Self-assessment 2022

Introduction

The Housing Ombudsman’s Complaint Handling Code sets out requirements for landlords that’ll allow them to respond to complaints in a fair and effective way. It’s intended to enable landlords to resolve complaints raised by their residents quickly and to use the learning from them to drive service improvements.

The Code ensures complaint handling data is used consistently across landlord members, promotes engagement at different levels of landlord organisations and sets out expectations for boards or equivalent governance, senior executives and frontline staff.

It promotes the progressive use of complaints, providing a high-level framework to support effective handling and prevention; promoting continuous learning and development and helping to create and embed a positive complaint handling culture amongst staff and residents.

At Longhurst Group, we take all matters of dissatisfaction and complaints seriously. We recognise that they’re an essential tool in helping us to identify areas for improvement.

We acknowledge that in recent months we’ve not been able to resolve a number of customer complaints within the set timescales and want to reassure our customers that we’ve put plans in place to address this in the coming months.

We’ve therefore completed a revised complaint handling self-assessment which outlines the areas that require improvement and the changes we’ve made to improve our service offer and bring us back to acceptable service levels.

We’re committed to doing everything we can to improve our customers’ experience in this area as quickly as we can.

Updated: 01 November 2022


1 – Definition of a complaint

Mandatory ‘must’ requirements

Definition of a complaint

A complaint must be defined as: ‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents.

Compliance:   YES

This statement is included in the complaints policy.  

The resident does not have to use the word complaint for it to be treated as such

The resident does not have to use the word’ complaint for it to be treated as such. A complaint that is submitted via a third party or representative must still be handled in line with the landlord’s complaints policy.

Compliance:   YES

This statement is included in the complaints policy. Complaints that are submitted via a third party or representative are handled in line with our complaints policy.  

If further enquiries are needed to resolve the matter, or if the resident requests it, the issue must be logged as a complaint

Compliance:   YES

This code requirement is included in the complaints policy.  A new process map and procedure has been developed for operational purposes.

A landlord must accept a complaint unless there is a valid reason not to do so

Compliance:   YES

This code requirement is included in the complaints policy. Within the complaints policy there are set criteria for exclusions as per the Complaint’s Handling Code.    

A complaints policy must clearly set out the circumstances in which a matter will not be considered, and these circumstances should be fair and reasonable to residents

Compliance:   YES

Within the complaints policy there are set criteria for exclusions as per the Complaint’s Handling Code.    

If a landlord decides not to accept a complaint, a detailed explanation must be provided

If a landlord decides not to accept a complaint, a detailed explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman.

Compliance:   YES

As outlined in the complaints policy if we do not accept a complaint, a detailed explanation will be provided setting out the reason why the matter is not suitable for the complaints process.  

Best practice ‘should’ requirements

Landlords should recognise the difference between a service request and a complaint

Landlords should recognise the difference between a service request, where a resident may be unhappy with a situation that they wish to have rectified, and a complaint about the service they have/have not received.

Compliance:   YES

This is included in our new process map.

Survey feedback may not necessarily need to be treated as a complaint but the person completing the survey should be made aware of how to pursue a complaint

Survey feedback may not necessarily need to be treated as a complaint, though, where possible, the person completing the survey should be made aware of how they can pursue their dissatisfaction as a complaint.

Compliance:   NO – In progress

This is in progress. We currently have a service level agreement in place to contact customers where a dissatisfaction score is provided following a transactional survey. As part of our new procedure, we have added an additional requirement where the person contacting the customer following a dissatisfaction score informs the customer of the next steps and how they can make a complaint if they wish to.


2 – Accessibility and awareness

Mandatory ‘must’ requirements

Landlords must make it easy for residents to complain by providing different channels through which they can make a complaint

Landlords must make it easy for residents to complain by providing different channels through which residents can make a complaint such as in person, over the telephone, in writing, by email and digitally. While the Ombudsman recognises that it may not be feasible for a landlord to use all of the potential channels, there must be more than one route of access into the complaints system.

Compliance:   YES

As stated in our complaints policy - complaints may be made by phone, online form using our website or social media, in person or by letter or completing a complaints form.

Landlords must make their complaint policy available in a clear and accessible format for all residents

Landlords must make their complaint policy available in a clear and accessible format for all residents. This will detail the number of stages involved, what will happen at each stage and the timeframes for responding.

Compliance:   YES

We publish our complaints policy on our website.

The complaint policy details the stages involved and what will happen at each stage and the timescales for responding.

Landlord websites, if they exist, must include information on how to raise a complaint

Landlord websites, if they exist, must include information on how to raise a complaint. The complaints policy and process must be easy to find on the website.

Compliance:   YES

There is a dedicated complaint section on our website. Our complaints policy and leaflet are also included on our website.

Landlords must comply with the Equality Act 2010 and may need to adapt normal policies, procedures, or processes to accommodate an individual’s needs

Landlords must comply with the Equality Act 2010 and may need to adapt normal policies, procedures, or processes to accommodate an individual’s needs.

Landlords must satisfy themselves that their policy sets out how they will respond to reasonable adjustments requests in line with the Equality Act and that complaints handlers have had appropriate training to deal with such requests.

Compliance:   YES

Our complaints policy has a dedicated section on reasonable adjustments. We have added an additional equality and diversity statement to the complaints policy to strengthen our approach.

 All of our customer facing policies have been updated to state ‘the need to make reasonable adjustments to the policy to recognise, accommodate and support customers’ individual needs, where needed’. 

Equality, Diversity, and Inclusion on-line training is mandatory for the complaints team.

Landlords must publicise the complaints policy and process

Landlords must publicise the complaints policy and process. The Complaint Handling Code and the Housing Ombudsman Scheme in leaflets, posters, newsletters, online and as part of regular correspondence with residents.

Compliance:   YES

Our complaints policy is published on our website.  The complaints process is included within both the complaints policy and our new complaints leaflet. 

Details of the Housing Ombudsman Scheme and Code are included within the new complaints leaflet. A copy of the leaflet is sent with the stage 1 acknowledgement letter. The Housing Ombudsman details are also included within the stage 2 resolution letter. Information is also published on our website.

Landlords must provide residents with contact information for the Ombudsman as part of its regular correspondence

Landlords must provide residents with contact information for the Ombudsman as part of its regular correspondence with residents.

Compliance:   YES

The contact details are included in the complaints leaflet, which is available on our website. We issue the complaints leaflet with the stage 1 acknowledgement letter, so the customer is aware of the Housing Ombudsman scheme at the initial stages of their complaint. Contact details for the Ombudsman will also be included in every issue of our customer magazine.

Landlords must provide early advice to residents regarding their right to access the Housing Ombudsman Service

Landlords must provide early advice to residents regarding their right to access the Housing Ombudsman Service throughout their complaint, not only when the landlord’s complaints process is exhausted.

Compliance:   YES

Our new acknowledgement letter for stage 1 includes a hyperlink to the complaints leaflet (a copy can be sent in the customer in the post upon request), which provides details of the Housing Ombudsman scheme. This ensures customers are aware at the earliest point of the formal complaint process.     

Contact details of the Housing Ombudsman are also included within the stage 2 resolution letters.

Best practice ‘should’ requirements

Where a landlord has set up channels to communicate with its residents via social media, then it should expect to receive complaints via those channels.

Where a landlord has set up channels to communicate with its residents via social media, then it should expect to receive complaints via those channels. Policies should contain details of the steps that will be taken when a complaint is received via social media and how confidentiality and privacy will be maintained. 

Compliance:   YES

Our complaints policy includes the use of social media as an access route to make a complaint. 

We maintain privacy and confidentiality by having a triage process in place regarding complaints made via social media.  A link to our complaints on-line form will be sent to the customer via social media where this will be completed confidentially and processed by our internal teams.   


3 – Complaint handling personnel

Mandatory ‘must’ requirements

Landlords must have a person or team assigned to take responsibility for complaint handling

Landlords must have a person or team assigned to take responsibility for complaint handling to ensure complaints receive the necessary attention, and that these are reported to the governing body. This Code will refer to that person or team as the “complaints officer”.

Compliance:   YES

We have a dedicated team that takes responsibility for complaint handling.

The complaint handler appointed must have appropriate complaint handling skills and no conflicts of interest

Compliance:   YES

There is a comprehensive job description and person specification to ensure the Complaint Resolution Officers appointed possess the appropriate skills and competencies to fulfil the role. We also have a comprehensive induction learning and development programme, which covers all relevant processes and training required to fulfil the role effectively. 

Within the complaints policy it states that a complaint investigation will be conducted in an impartial manner. To ensure fairness we will take measures to address any actual or perceived conflict of interest.

Best practice ‘should’ requirements

Complaint handler requirements

Complaint handlers should:

  • be able to act sensitively and fairly
  • be trained to handle complaints and deal with distressed and upset residents
  • have access to staff at all levels to facilitate quick resolution of complaints
  • have the authority and autonomy to act to resolve disputes quickly and fairly.

Compliance:   YES

These key behaviours are included within the job description and person specification for the Complaint Resolution Officer role. Complaint Resolution Officers will always receive training to handle complaints. Internal governance structures and communication pathways have been strengthened so there is regular and structured access and lines of responsibility for key colleagues and teams across Longhurst Group. We have dedicated points of contact for each service area i.e., property services, sales, leaseholder services, development, care and support, housing services, income etc for both stage 1 and stage 2 complaints.


4 – Complaint handling principles

Mandatory ‘must’ requirements

Any decision to try and resolve a concern must be taken in agreement with the resident and a landlord’s audit trail/records should be able to demonstrate this

Any decision to try and resolve a concern must be taken in agreement with the resident and a landlord’s audit trail/records should be able to demonstrate this.

Landlords must ensure that efforts to resolve a resident’s concerns do not obstruct access to the complaints procedure or result in any unreasonable delay. It is not appropriate to have extra named stages (such as ‘stage 0’ or ‘pre-complaint stage’) as this causes unnecessary confusion for residents.

When a complaint is made, it must be acknowledged and logged at stage one of the complaints procedure within five days of receipt.

Compliance:   YES

Our complaints policy outlines our approach to early resolution/informal complaints. A procedure has been developed with supporting written customer communication.

Our complaints policy and communication to customers states this timescale.

Within the complaint acknowledgement, landlords must set out their understanding of the complaint and the outcomes the resident is seeking

Within the complaint acknowledgement, landlords must set out their understanding of the complaint and the outcomes the resident is seeking. If any aspect of the complaint is unclear, the resident must be asked for clarification and the full definition agreed between both parties.

Compliance:   YES

Our new acknowledgement letter template and procedure reflects this code requirement.

A complaint investigation must be conducted in an impartial manner

Compliance:   YES

This requirement is included within the complaints policy under the fairness in complaint handling section. The job description for the Complaint Resolution Officers reflects this code requirement.

Expectations of complaint handler behaviour

The complaint handler must:

  • deal with complaints on their merits
  • act independently and have an open mind
  • take measures to address any actual or perceived conflict of interest
  • consider all information and evidence carefully
  • keep the complaint confidential as far as possible, with information only disclosed if necessary to properly investigate the matter.

Compliance:   YES

Our Complaint Resolution Officers will act independently and fulfil an advocacy role on behalf of the customer with the aim of resolving complaints promptly and to a satisfactory conclusion, where possible. The Complaint Resolution Officers will act independently throughout the investigation and management of the complaint case.

These requirements are included in the job description and person specification for the Complaint Resolution Officer role.

There is a separate section on fairness with complaints handling within the complaints policy, which covers all these key points.

Landlords must adhere to any reasonable arrangements agreed with residents in terms of frequency and method of communication

Compliance:   YES

This requirement is included with the complaints policy. We will use different communication methods to keep customers up to date. The complaints team act as a single point of contact for the customer. They will liaise with colleagues, our contractors and third parties (where appropriate) to gain a resolution for the customer. Each process map and procedure developed has identified touch points with the customer at key stages of the complaint journey.

The resident, and if applicable any staff member who is the subject of the complaint, must also be given a fair chance to set out their position and comment

The resident, and if applicable any staff member who is the subject of the complaint, must also be given a fair chance to:

  • set out their position
  • comment on any adverse findings before a final decision is made.

Compliance:   YES

This code requirement is included in the complaints policy. Complaints of this manner are treated as confidential complaints. We have revised our confidential complaint procedure in light of this requirement.

A landlord must include in its complaints policy its timescales for a resident to request escalation of a complaint

Compliance:   YES

Within the complaints policy it states that a customer has one month to escalate their complaint for a stage 2 review. This timescale is communicated to the customer as part of the stage 1 resolution letter.

A landlord must not unreasonably refuse to escalate a complaint

A landlord must not unreasonably refuse to escalate a complaint through all stages of the complaints procedure and must have clear and valid reasons for taking that course of action.

Reasons for declining to escalate a complaint must be clearly set out in a landlord’s complaints policy and must be the same as the reasons for not accepting a complaint.

Compliance:   YES

The complaints policy has been updated to reflect this code requirement. The criteria set for declining a stage 2 complaint review are also detailed within the policy.

A full record must be kept of the complaint, any review and the outcomes at each stage

A full record must be kept of the complaint, any review and the outcomes at each stage.

This must include the original complaint and the date received, all correspondence with the resident, correspondence with other parties and any reports or surveys prepared.

Compliance:   YES

As outlined in our complaints policy, all correspondence and communication details are recorded on our system where we have access to the complaint history, case notes and correspondence. The new internal process maps that have been developed focus on record keeping and recording evidence, communication, and correspondence.

Landlords must have policies and procedures in place for managing unacceptable behaviour from those pursuing a complaint

Landlords must have policies and procedures in place for managing unacceptable behaviour from residents and/or their representatives when pursuing a complaint.

Compliance:   YES

We have a procedure for managing unacceptable behaviour from customers in relation to complaint handling. There is reference to this within our complaints policy.

Best practice ‘should’ requirements

A complaint should be resolved at the earliest possible opportunity

A complaint should be resolved at the earliest possible opportunity, having assessed what evidence is needed to fully consider the issues, what outcome would resolve the matter for the resident and whether there are any urgent actions required.

Compliance:   NO – in progress

With the ICT Team we have agreed a process to identify and categorise high risk/high priority complaints, so these can be flagged on our system. This action has been added to our complaints improvement plan.

Landlords should give residents the opportunity to have a representative deal with their complaint on their behalf

Landlords should give residents the opportunity to have a representative deal with their complaint on their behalf, and to be represented or accompanied at any meeting with the landlord where this is reasonable.

Compliance:   YES

This is included in our complaints policy within the reasonable adjustment section. We also aim to keep the representative up to date throughout the management of the complaint case.

Communication with the resident should not generally identify individual members of staff or contractors

Compliance:   YES

This requirement has been included in our new stage 1 procedure.

Landlords should keep residents regularly updated about the progress of the investigation

Compliance:   YES

An additional statement has been added to the complaints policy. The new complaint process maps for each complaint stage will include communication as a critical part of the complaint journey.  

Landlords should seek feedback from residents in relation to the landlord’s complaint handling

Landlords should seek feedback from residents in relation to the landlord’s complaint handling as part of the drive to encourage a positive complaint and learning culture.

Compliance:   YES

We collect feedback on our complaints handling via telephone surveys on a monthly basis. A monthly report is produced and discussed at monthly meetings with key colleagues where improvement actions are noted.

Landlords should recognise the impact that being complained about can have on future service delivery

Landlords should recognise the impact that being complained about can have on future service delivery. Landlords should ensure that staff are supported and engaged in the complaints process, including the learning that can be gained.

Compliance:   YES

Work has progressed significantly with a focus on a positive complaint handling culture and the importance of everyone contributing towards this. This has been a key focus at Longhurst Group across both Executive, Senior and Operational tiers. We hosted a Customer Experience Lab event, whereby over 60 Managers from across the organisation joined together to review and resolve stage 2 complaints. The Stop the Clock style event was an important opportunity for us to hold up the mirror to ourselves, our way of working and draw out areas of learning.

This has supported a step change in reinvigorating our approach to collaborative working and the adoption of a resolution- focussed mindset at Longhurst Group.

From the start of the new repair contracts (July 2022) we emphasised the importance of a positive complaints culture and communicated our expectations to achieve this. During a dedicated joint briefing session with the complaints team and contractors we focused on the importance of complaints and the role they play in future service delivery.

Any restrictions placed on a resident’s contact due to unacceptable behaviour should be appropriate to their needs and should demonstrate regard for the provisions of the Equality Act 2010

Compliance:   YES

The complaints policy refers to this requirement. The unacceptable customer behaviour procedure states that will reflect the requirements of the Equalities Act 2010 and show regard for a customer’s individual circumstances and our colleagues, before deciding how best to manage the situation.


5 – Complaint stages

Mandatory ‘must’ requirements

Stage 1

Landlords must respond to the complaint within 10 working days of the complaint being logged

Landlords must respond to the complaint within 10 working days of the complaint being logged. Exceptionally, landlords may provide an explanation to the resident containing a clear timeframe for when the response will be received. This should not exceed a further 10 days without good reason.

Compliance:   NO

This timescale is stated in our complaints policy. This resolution timescale is discussed with the customer at the point of the acknowledgement stage and is confirmed within the stage one acknowledgement letter, so the customer is aware of the resolution timescales.

We will always engage with the customer to inform them of any extensions to the timescales. During the recent demobilisation and mobilisation of repairs contractors we have seen a dip in performance but have plans in place to bring performance back to expected levels.

This includes bringing in additional resources into the complaints handling team; weekly meetings with our repairs and maintenance team and contractors to focus on open complaints with clear escalation routes through to the Director of Customer Experience and Communities and the Director of Repairs and Maintenance.

We envisage that our improvement plans should see a return to meeting this target by February 2023 for all new complaints.

A complaint response must be sent to the resident when the answer to the complaint is known

A complaint response must be sent to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue, are completed.

Outstanding actions must still be tracked and actioned expeditiously with regular updates provided to the resident.

Compliance:   YES

This code requirement is included in the complaints policy.

There is a new monitoring system and procedure in place to record and monitor promises until completion (ie agreed remedies and actions). The procedure focuses on communication to the customer.

Dedicated resource within the complaints team has been allocated to this code requirement.

Landlords must address all points raised in the complaint and provide clear reasons for any decisions

Landlords must address all points raised in the complaint and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.

Compliance:   YES

The complaints policy reflects this code requirement.  

Landlords must confirm the following in writing to the resident at the completion of stage one in clear, plain language

Landlords must confirm the following in writing to the resident at the completion of stage one in clear, plain language:

  • the complaint stage
  • the decision on the complaint
  • the reasons for any decisions made
  • the details of any remedy offered to put things right
  • details of any outstanding actions
  • details of how to escalate the matter to stage two if the resident is not satisfied with the answer

Compliance:   YES

This requirement is included within the complaints policy. Our procedure and letter templates reflect this code requirement.

Stage 2

If all or part of the complaint is not resolved to the resident’s satisfaction at stage one it must be progressed to stage two of the landlord’s procedure, unless an exclusion ground now applies

If all or part of the complaint is not resolved to the resident’s satisfaction at stage one it must be progressed to stage two of the landlord’s procedure, unless an exclusion ground now applies.

In instances where a landlord declines to escalate a complaint it must clearly communicate in writing its reasons for not escalating as well as the resident’s right to approach the Ombudsman about its decision.

Compliance:   YES

Within the complaints policy there are clear criteria for a stage 2 review. 

All stage 2 complaints are reviewed by a manager.  There will be a lead responsible manager in the first instance.  This ensures consistency and accountability in terms of ensuring the requirements of the Code are met and we do not exclude any cases from a stage two review that meet the criteria.

Our procedure and letter templates  have been updated to reflect this requirement. 

All stage 2 complaints that relate to properties where we are the managing agents, we will involve the landlord in the resolution at stage 2.

On receipt of the escalation request, landlords must set out their understanding of issues outstanding and the outcomes the resident is seeking

On receipt of the escalation request, landlords must set out their understanding of issues outstanding and the outcomes the resident is seeking. If any aspect of the complaint is unclear, the resident must be asked for clarification and the full definition agreed between both parties.

Compliance:   YES

We have improved the acknowledgement process at stage 2 to reflect this code requirement. The new stage 2 procedure and letter templates incorporate this.  

The person considering the complaint at stage two, must not be the same person that considered the complaint at stage one

Compliance:   YES

The complaints policy states that the stage 2 review is completed by a manager who wasn’t involved in the complaint at stage 1

Within the complaints team we have dedicated team members working solely on stage 2 complaints.

Other colleagues engaged at stage 2 reviews will not be colleagues involved at the stage 1 process.

Landlords must respond to the stage two complaint within 20 working days of the complaint being escalated

Landlords must respond to the stage two complaint within 20 working days of the complaint being escalated. Exceptionally, landlords may provide an explanation to the resident containing a clear timeframe for when the response will be received. This should not exceed a further 10 days without good reason.

Compliance:   NO

This timescale is stated in our complaints policy. This resolution timescale is discussed with the customer at the point of the acknowledgement stage and is confirmed within the stage one acknowledgement letter, so the customer is aware of the resolution timescales. We will always engage with the customer to inform them of any extensions to the timescales.

During the recent demobilisation and mobilisation of repairs contractors we have seen a dip in performance but have plans in place to bring performance back to expected levels.

This includes bringing in additional resources into the complaints handling team; weekly meetings with our repairs and maintenance team and contractors to focus on open complaints with clear escalation routes through to the Director of Customer Experience and Communities and the Director of Repairs and Maintenance.

We envisage that our improvement plans should see a return to meeting this target by February 2023 for all new complaints.

Landlords must confirm the following in writing to the resident at the completion of stage two in clear, plain language

Landlords must confirm the following in writing to the resident at the completion of stage two in clear, plain language:

• the complaint stage
• the complaint definition
• the decision on the complaint
• the reasons for any decisions made
• the details of any remedy offered to put things right
• details of any outstanding actions
and
• if the landlord has a third stage, details of how to escalate the matter to stage three
• if this was the final stage, details of how to escalate the matter to the Housing Ombudsman Service if the resident remains dissatisfied.

Compliance:   YES

We have improved the stage 2 review to reflect this code requirement. The new stage 2 procedure and letter templates incorporate this. 

Stage 3

Two stage landlord complaint procedures are ideal – this ensures that the complaint process is not unduly long

Two stage landlord complaint procedures are ideal. This ensures that the complaint process is not unduly long. If landlords strongly believe a third stage is necessary, they must set out their reasons for this as part of their self-assessment. A process with more than three stages is not acceptable under any circumstances.

Compliance:   YES

Our complaints policy states that we have a two-stage complaints process, which meets the requirements of the Complaint’s Handling Code.  We do not have a third stage within our complaints procedure.  

Landlords must confirm the following in writing to the resident at the completion of stage three in clear, plain language

Landlords must confirm the following in writing to the resident at the completion of stage three in clear, plain language:

  • the complaint stage
  • the complaint definition
  • the decision on the complaint
  • the reasons for any decisions made
  • the details of any remedy offered to put things right
  • details of any outstanding actions
  • details of how to escalate the matter to the Housing Ombudsman Service if the resident remains dissatisfied

Compliance: Not applicable

We do not have a third stage within our complaints procedure.  

Best practice ‘should’ requirements

Stage 1

Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details

Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details so the resident can challenge the landlord’s plan for responding and/or the proposed timeliness of a landlord’s response.

Compliance:   YES

This code requirement has been added to the new stage 1 procedure.  

Where the problem is a recurring issue, the landlord should consider any older reports as part of the background to the complaint

Where the problem is a recurring issue, the landlord should consider any older reports as part of the background to the complaint if this will help to resolve the issue for the resident.

Compliance:   YES

The Complaints team would review the history of the service failure as part of the stage one complaint. This is included within the complaints policy. 

Where residents raise additional complaints during the investigation, these should be incorporated into the stage one response if they are relevant

Where residents raise additional complaints during the investigation, these should be incorporated into the stage one response if they are relevant and the stage one response has not been issued. Where the stage one response has been issued, or it would unreasonably delay the response, the complaint should be logged as a new complaint.

Compliance:   YES

This code requirement has been added to the new stage 1 procedure.  

Stage 2

If an extension beyond 10 working days is required to enable the landlord to respond to the complaint fully, this should be agreed by both parties

Compliance:   YES

This requirement is included within the complaints policy. This code requirement has been added to the new stage 2 procedure.  The agreement for a further extension is only by exception and will need approval from the Complaint and Improvement Manager.

Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details

Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details so the resident can challenge the landlord’s plan for responding and/or the proposed timeliness of a landlord’s response.

Compliance:   YES

This code requirement has been added to the new stage 2 procedure. 

Stage 3

Complaints should only go to a third stage if the resident has actively requested a third stage review of their complaint

Complaints should only go to a third stage if the resident has actively requested a third stage review of their complaint. Where a third stage is in place and has been requested, landlords must respond to the stage three complaint within 20 working days of the complaint being escalated. Additional time will only be justified if related to convening a panel. An explanation and a date for when the stage three response will be received should be provided to the resident.

Compliance: Not applicable

We do not have a stage three within our complaints procedure 

Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details

Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details so the resident can challenge the landlord’s plan for responding and/or the proposed timeliness of a landlord’s response.

Compliance: Not applicable

We do not have a stage three within our complaints procedure 


6 – Putting things right

Mandatory ‘must’ requirements

Effective dispute resolution requires a process designed to resolve complaints

Effective dispute resolution requires a process designed to resolve complaints. Where something has gone wrong a landlord must acknowledge this and set out the actions it has already taken, or intends to take, to put things right.

Compliance:   YES

The theme of putting things right is in the complaints policy. As good practice we’ve made the Housing Ombudsman dispute resolution e-learning training mandatory for the Complaint Resolution Officers.  We have achieved a 100% completion rate.

Any remedy offered must reflect the extent of any service failures and the level of detriment caused to the resident as a result

Any remedy offered must reflect the extent of any service failures and the level of detriment caused to the resident as a result. A landlord must carefully manage the expectations of residents and not promise anything that cannot be delivered or would cause unfairness to other residents.

Compliance:   YES

This code requirement is included within the complaints policy. 

The remedy offer must clearly set out what will happen and by when in agreement with the resident where appropriate

The remedy offer must clearly set out what will happen and by when in agreement with the resident where appropriate.  Any remedy proposal must be through to completion.

Compliance:   YES

This code requirement is included within the complaints policy.  Written communication to the customer will reflect this code requirement.

There is a new monitoring system and procedure in place to record and monitor promises until completion (ie agreed remedies and actions). 

In awarding compensation, a landlord must consider whether any statutory payments are due

In awarding compensation, a landlord must consider whether any statutory payments are due, if any quantifiable losses have been incurred, the time and trouble a resident has been put to as well as any distress and inconvenience caused.

Compliance:   YES

We have a compensation procedure in place. An additional statement has been added to the complaints policy referring to this code requirement. To strengthen our approach, we will be reviewing our compensation procedure.  

Best practice ‘should’ requirements

Landlords should look beyond the circumstances of the individual complaint

Landlords should look beyond the circumstances of the individual complaint and consider whether anything needs to be ‘put right’ in terms of process or systems to the benefit of all residents.

Compliance:   YES

We have a complaints improvement plan in place that has captured a number of lessons learnt and system improvements.

In some cases, a resident may have a legal entitlement to redress

In some cases, a resident may have a legal entitlement to redress. The landlord should still offer a resolution where possible, obtaining legal advice as to how any offer of resolution should be worded.

Compliance:   YES

Reference to this code requirement has been included within the stage 1 acknowledgement letter template.


7 – Continuous learning and improvement

Mandatory ‘must’ requirements

Accountability and transparency are integral to a positive complaint handling culture

Accountability and transparency are integral to a positive complaint handling culture. Landlords must report back on wider learning and improvements from complaints in their annual report and more frequently to their residents, staff and scrutiny panels.

Compliance:   YES

There is a 'Learning from Complaints' section within the complaints policy, which reflects this code requirements.

We present complaint handling performance and learning to our Customer Forum on a quarterly basis as part of their scrutiny and assurance role. The report is also presented to the Directors Group. Our annual report also included wider learning.  

Learning is published to customers and colleagues using the 'You said, We Did' page on our website. 

To strengthen our approach, a customer experience panel whereby customers, contractors and colleagues will meet to review complaint insight (and agree proactive solutions for service improvement.  

Best practice ‘should’ requirements

A member of the governing body should be appointed to have lead responsibility for complaints to support a positive complaint handling culture

A member of the governing body should be appointed to have lead responsibility for complaints to support a positive complaint handling culture. This role will be responsible for ensuring the governing body receives regular information on complaints that provides insight to the governing body on the landlord’s complaint handling performance.

Compliance:   NO

We will keep this under review. An action to review this code requirement as good practice has been added to our complaints improvement plan.

As a minimum, governing bodies should receive the following information

As a minimum, governing bodies should receive:

  • Regular updates on the volume, categories and outcome of complaints, alongside complaint handling performance including compliance with the Ombudsman’s orders
  • Regular reviews of issues and trends arising from complaint handling,
  • The annual performance report produced by the Ombudsman, where applicable
  • Individual complaint outcomes where necessary, including where the Ombudsman made findings of severe maladministration or referrals to regulatory bodies. The implementation of management responses should be tracked to ensure they are delivered to agreed timescales.
  • The annual self-assessment against the Complaint Handling Code for scrutiny and challenge.

Compliance:   YES

Comprehensive reports are provided to the Group Board on a quarterly basis. The annual self-assessment against the Complaint Handling Code will be presented to the governing body for scrutiny and challenge.

Any themes or trends should be assessed by senior management

Any themes or trends should be assessed by senior management to identify potential systemic issues, serious risks or policies and procedures that require revision. They should also be used to inform staff and contractor training.

Compliance:   YES

This code requirement is included within the complaints policy. Quarterly reports are discussed by the Directors Group. We review the Housing Ombudsman determination outcomes at a senior management level; with actions taken to improve policies and procedures.  

Landlords should have a standard objective in relation to complaint handling for all employees

Landlords should have a standard objective in relation to complaint handling for all employees that reflects the need to:

  • have a collaborative and co-operative approach towards resolving complaints, working with colleagues across teams and departments
  • take collective responsibility for any shortfalls identified through complaints rather than blaming others
  • act within the Professional Standards for engaging with complaints as set by the Chartered Institute of Housing.

Compliance:   NO

This forms part of a wider review.  As part of our drive to embed a positive complaints culture this requirement will be developed further. 

This action has been added to our complaints improvement plan  


8 – Self-assessment and compliance

Mandatory ‘must’ requirements

Landlords must carry out an annual self-assessment against the Code to ensure their complaint handling remains in line with its requirements

Compliance:   YES

We will carry out the annual self-assessment against the Code and present this to our Group Board.  We will then publish this on our website following approval. 

Landlords must also carry out a self-assessment following a significant restructure and/or change in procedures

Compliance:   YES

This self-assessment has been reviewed following recent significant changes to our complaints team following a restructure, as well as changes to our property services department; with the aim of strengthening our complaints handling service.

The requirements of the Complaint Handling Code were incorporated into our new responsive repair delivery model, along with our new heating contract.

Following each self-assessment, a landlord must do the following

Following each self-assessment, a landlord must:

  • report the outcome of their self-assessment to their governing In the case of local authorities, self- assessment outcomes should be reported to elected members
  • publish the outcome of their assessment on their website if they have one, or otherwise make accessible to residents
  • include the self-assessment in their annual report section on complaints handling performance.

Compliance:   YES

This completed self-assessment was presented to the Group Board on 29 September 2022.

In line with this code requirement, we’ve included additional narrative referring to the Complaint Handling Code within the Annual Report. A hyperlink to the completed self-assessment will also be published.

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