Housing Ombudsman Complaint Handling Code - self assessment

Section 1 - definition of a complaint

Mandatory 'must' requirements

Code section

1.2

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Our complaint policy was updated in September 2022. The updated definition is as follows: A complaint is 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 or group.

Actions

A new complaint process is to be developed by March 2023 to align with the new policy and staff will be given training on this. This is to ensure ongoing compliance with the complaint handling code requirements and adherence to our policy.

Code section

1.3

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

We do not insist on residents using the word complaint for a matter to be handled as a complaint and this is covered within our policy. "All customer complaints and compliments will be treated equally regardless of the method they are submitted, and customers do not have to use the word complaint for it to be treated as such." Any complaint submitted via a third party will be handled in line with our complaints policy and is stated within the policy

Code section

1.6

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Our complaints policy defines a service request. Where there is then a repeated request for a service or where a resident raises dissatisfaction with the response to their service request then this would be raised as a complaint.

Code section

1.7

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

The council will accept all complaints unless the complaint falls within matters that cannot be dealt with under our complaints policy. Included at Appendix 1 in our policy.

Code section

1.8

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

The complaints policy at Appendix 1 details circumstances where a matter will not be considered under the policy. Anything that has an appeal process: issuing of parking tickets, a decision on a planning application, housing application scheme, an eviction decision, review of homelessness application, entitlement to housing benefit

Code section

1.9

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Where the council does not accept a complaint the customer will be provided with an explanation and of their right to take the decision to the Ombudsman. This is detailed within our complaints policy.

Best practice 'should' requirements

Code section

1.4

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Our complaint policy sets out the difference between a request for service and a complaint.

Code section

1.5

Code requirement

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 if they wish to.

Do we comply

Yes

Evidence, commentary and explanations

Wording has been added to our surveys to highlight how customers can make a complaint if they are dissatisfied with the service received

Section 2 - accessibility and awareness

Mandatory 'must' requirements

Code section

2.1

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Our complaints policy makes clear the different channels residents can complain by. Either by phone, e-mail, online form, in person or in writing.

Code section

2.3

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Our complaints policy is available on our website in an accessible format detailing how a complaint can be made, the number of stages involved and what will happen at each stage.

Code section

2.4

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Our complaints policy is available on our website and is available in a clear and accessible format

Code section

2.5

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

The council has a corporate equality and diversity document. Equality and Diversity is important to us and we are committed to making sure that people are treated fairly and with dignity. Our aim is to remove unnecessary barriers for everyone who works for us or uses our services. All staff receive training on equality and diversity and will respond to any requests for reasonable adjustments in line with the Equality Act

Code section

2.6

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Residents are advised about the complaints process, Housing Ombudsman scheme and complaint handling code through various channels, including the website, in correspondence and in our newsletter.

Code section

2.7

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Residents are provided with contact information for the Ombudsman within our newsletter, on our website and in correspondence with them about complaints.

Actions

We are reviewing and updating further letter templates within housing to include contact information for the Ombudsman.

Code section

2.8

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

The councils website includes information on complaints and the right to access the Housing Ombudsman Service, not only when the councils complaints process has been exhausted. Residents are informed within the complaint acknowledgement that they have the right to access the Housing Ombudsman service.

Best practice 'should' requirements

Code section

2.2

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Any complaint received via social media will be dealt with in line with our complaints policy. "Any complaints made via our social media sites will be dealt with in line with this complaint policy, to protect confidentiality and privacy we will reply and ask you to message us directly with further details so that we can log your complaint. "

Section 3 - complaint handling personnel

Mandatory 'must' requirements

Code section

3.1

Code requirement

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”.

Do we comply

Yes

Evidence, commentary and explanations

Our Infomanagement team receive formal complaints, and will then pass these over to the relevant service areas. Within each service area there are officers who will respond to complaints. There is an officer who tracks complaints to ensure they are given the necessary attention and responded to in the timescales prescribed

Code section

3.2

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Complaint handlers are trained in complaint handling and the 2 stage process is in place to ensure that there is no conflict of interest.

Actions

To ensure continued compliance with the complaint handling code training will be offered to staff on the new policy and a process implemented in housing to ensure it is consistently applied. Complaints training and awareness of the code will also be included within the induction process for new staff

Best practice 'should' requirements

Code section

3.3

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

The councils complaint policy makes clear what a complainant can expect from the nominated person dealing with the complaint. Act independently and have an open mind. Take measures to address any actual or perceived conflict of interest. Consider all relevant information and evidence carefully. Keep the complaint confidential as far as possible with information only disclosed if necessary to properly investigate the matter. All housing staff have recently undertaken the free Housing Ombudsman training

Actions

To ensure continued compliance with the complaint handling code we will establish an ongoing training programme for complaint handlers.

Section 4 - complaint handling principles

Mandatory 'must' requirements

Code section

4.1

Code requirements

Do we comply

Yes

Evidence, commentary and explanations

The council does not have any extra/pre named stages such as stage '0'. All complaints are handled in line with our 2 stage process and are acknowledged within five days of receipt.

Code section

4.2

Code requirements

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.

Do we comply

Yes

Evidence, commentary and explanations

All acknowledgements include. The name and contact details of the complaint handler, our understanding of the complaint and the outcomes the customer is seeking and a date or timeframe by which they can expect to receive a response. If any aspect of the complaint is unclear we will ask the resident for clarification. This is contained within our complaints policy

Code section

4.6

Code requirements

A complaint investigation must be conducted in an impartial manner.

Do we comply

Yes

Evidence, commentary and explanations

Staff who are the subject of the complaint will not be involved in the complaint investigation

Code section

4.7

Code requirements

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.

Do we comply

Yes

Evidence, commentary and explanations

The complaint policy sets out how the complaint handler will deal with the complaint, and includes all areas referred to in 4.7.

Actions

Ongoing training for complaint handlers will be established to ensure adherence to the complaint handling code.

Code section

4.11

Code requirements

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

Do we comply

Yes

Evidence, commentary and explanations

Where arrangements have been agreed with residents these will be adhered to and communicated to any staff who will be dealing with the complaint.

Code section

4.12

Code requirements

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.

Do we comply

Yes

Evidence, commentary and explanations

Staff members who are the subject of the complaint, will be interviewed as part of the complaint investigation. This will allow them to set out their position. The residents position is confirmed at acknowledgement stage.

Code section

4.13

Code requirements

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

Do we comply

Yes

Evidence, commentary and explanations

Timescales are set out within our complaints policy. This includes the timescales for escalating to stage 2 .

Code section

4.14

Code requirements

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.

Do we comply

Yes

Evidence, commentary and explanations

In appendix 1 of the complaints policy we set out the circumstances in which a matter will not be considered under the complaints policy. The council does not unreasonably refuse to escalate complaints.

Code section

4.15

Code requirements

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.

Do we comply

Yes

Evidence, commentary and explanations

We record our complaints via spreadsheets and record contacts on our housing management system. We are currently developing a new housing system with the aim of providing improved functionality and efficiency.

Code section

4.18

Code requirements

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

Do we comply

Yes

Evidence, commentary and explanations

The council has an unreasonable behaviour policy.

Best practice 'should' requirements

Code section

4.3

Code requirement

Landlords should manage residents’ expectations from the outset, being clear where a desired outcome is unreasonable or unrealistic

Do we comply

Yes

Evidence, commentary and explanations

Unrealistic outcomes will be managed as and when received and will be managed as part of the complaint acknowledgement and investigation

Code section

4.4

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Our complaint policy makes clear we will take action to put things right as quickly as possible. We aim to resolve all complaints at Stage 1

Code section

4.5

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Our complaints policy states how we will deal with complaints via a third party.

Code section

4.8

Code requirement

Where a key issue of a complaint relates to the parties’ legal obligations landlords should clearly set out their understanding of the obligations of both parties.

Do we comply

Yes

Evidence, commentary and explanations

The complaint handler will clarify any legal obligations at acknowledgement stage and the complaint response will detail the council's obligations and the obligations of the resident.

Code section

4.9

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Individuals will not be identified or named as part of the complaint process.

Code section

4.1

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

We aim to keep responses to all complaints within the timeframes set out within our policy. If it is known that timeframes cannot be met, the complaint handler will inform the complainant of this.

Code section

4.16

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

In April 2022 we set up a process for measuring satisfaction with complaint handling via transactional surveys that are sent out upon closure of a complaint.

Code section

4.17

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

We view complaints as a way to help us improve our standards and the quality of service provided. Staff are supported within the council and understand the value of learning from complaints.

Code section

4.19

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Our unreasonable behaviour policy sets out the type of restrictions that could be put In place. Prior to any restrictions being put In place the residents will be given notice of their possible implementation and given the opportunity to amend their behaviour.

Section 5 - complaint stages

Mandatory 'must' requirements

Stage 1

Code section

5.1

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

We aim to respond to complaints within 10 working days. If we need to extend the timescale this will be explained to the resident and a new timeframe given, this will not exceed a further 10 days without good reason.

Code section

5.5

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

This is stated within our complaint policy, outstanding actions will then be tracked and updates provided to residents

Code section

5.6

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

This is standard practice. A standard letter template has been developed to assist staff and ensure consistency

Code section

5.8

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

This is standard practice. A standard letter template has been developed to assist staff and ensure consistency

Stage 2

Code section

5.9

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

This is standard practice and complaints will be progressed to stage 2 of our complaints policy. Appendix 1 sets out the circumstances where a complaint would not be considered under the complaints policy.

Code section

5.1

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

When acknowledging the stage 2 complaint we will set out our understanding of the complaint and the outcomes the resident is seeking, if any aspect of the complaint in unclear we will ask for clarification.

Code section

5.11

Code requirement

Landlords must only escalate a complaint to stage two once it has completed stage one and at the request of the resident.

Do we comply

Yes

Evidence, commentary and explanations

Complaints are only escalated to stage 2 once a stage 1 has been completed and at the request of the resident.

Code section

5.12

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Stage 2 complaints are dealt with by a senior officer independent of the original complaint

Code section

5.13

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

We always aim to respond within 20 working days. If we need to extend the timescale this will be explained to the resident and a new timeframe given, this will not exceed a further 10 days without good reason.

Code section

5.16

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

This is standard practice. A standard letter template is being developed to assist staff and ensure consistency

Stage 3

Code section

5.17

Code requirement

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 [sic]

Do we comply

Yes

Evidence, commentary and explanations

The council operates a two stage complaint process

Code section

5.2

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Not-applicable as the council operates a two stage complaint process

Best practice 'should' requirements

Stage 1

Code section

5.2

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

We aim to respond to complaints within the target timescales, if an extension is required this is discussed with the resident and they are kept informed of the timeframe.

Code section

5.3

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

The details of the ombudsman would be provided in cases where we cannot reach an agreement

Code section

5.4

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Background information is considered as part of the complaint investigation

Code section

5.7

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

This is stated within our complaint policy "Where you raise additional complaints during the investigation, these will be incorporated into Stage 1 response if they are relevant, and the stage 1 response has not been issued".

Stage 2

Code section

5.14

Code requirement

If an extension beyond 20 working days is required to enable the landlord to respond to the complaint fully, this should be agreed by both parties.

Do we comply

Yes

Evidence, commentary and explanations

We aim to respond to complaints within the target timescales, if an extension is required this is discussed with the resident and they are kept informed of the timeframe

Code section

5.15

Code requirement

Do we comply

Yes

Evidence, commentary and explanations

The details of the ombudsman are on our website and also would be provided in cases where we cannot reach an agreement

Stage 3

Code section

5.18

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

This council operates a two stage complaints process

Code section

5.19

Code requirement

Do we comply

Yes

Evidence, commentary and explanations

Not applicable the council operates a two stage complaints process

Section 6 - putting things right

Mandatory 'must' requirements

Code section

6.1

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Our complaints policy sets out that when things go wrong we will apologise and take actions to put things right as quickly as possible and use the feedback to change and improve the way we deliver our services.

Code section

6.2

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

When applying remedies staff consider the Ombudsman's guidance on remedies, and also refer to our compensation policy concerning redress to be made.

Actions

To ensure ongoing compliance with the complaint handling code we will provide regular training to staff on applying remedies

Code section

6.5

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

Our complaint response letters are written clearly and considerately, setting out the remedies offered and will be followed through to completion and tracked by the complaint handlers.

Code section

6.6

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

In awarding compensation these points are considered, the council also has a compensation policy in place to refer to on these matters

Best practice 'should' requirements

Code section

6.3

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Service managers review the learnings from complaints, identifying trends, seeking to drive forward improvements and identify if anything needs to be changed in terms of process or systems.

Code section

6.7

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

Where a resident may have a legal entitlement to redress we will offer a resolution where possible, and will obtain legal advice as required

Section 7 - continuous learning and improvement

Mandatory 'must' requirements

Code section

7.2

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

A consistent process for tracking and collating data from complaints is consistently improving. Wider learning and improvement from complaints will be reported via the annual report and in our residents magazine. Learning from complaints is also shared with our residents group.

Best practice 'should' requirements

Code section

7.3

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

The Group Head of Law and Governance has lead responsibility for complaints. With the support of the Head of Housing regular performance reports will be presented to committee commencing in 2023.

Code section

7.4

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

The provision of regular performance information to the committee is being collated and will be presented to committee commencing in 2023.

Code section

7.5

Code requirement

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.

Do we comply

Yes

Evidence, commentary and explanations

A quarterly report on themes and trends will be presented to the Corporate management team, and a monthly report will be presented to the housing management team to discuss potential systemic issues, serious risks, or policies and procedures that require revision. This will commence in early 2023.

Code section

7.6

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

We are working towards service transformation that will include review of objectives for employees, which will include best practice around complaint handling.

Section 8 - self-assessment and compliance

Mandatory 'must' requirements

Code section

8.1

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

This will be undertaken annually in December

Code section

8.2

Code requirement

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

Do we comply

Yes

Evidence, commentary and explanations

This will be undertaken in the event of a significant restructure and/or change in procedures

Code section

8.3

Code requirement

Following each self-assessment, a landlord must: • report the outcome of their self-assessment to their governing body. 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

Do we comply

Yes

Evidence, commentary and explanations

This self-assessment was reported to committee on 25 January 2023. The self assessment will be published on our complaints page on our website and will be included within our annual report.

Housing Ombudsman Complaint Handling Code - self assessment