Housing Ombudsman Complaint Handling Code Self-Assessment 2024 – Action Plan

A complaint must be defined as:

‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the landlord, its own staff, or those acting on its behalf, affecting a resident or group of residents.’

Evidence required demonstrating fully embedded across whole HPS Service

Target – Oct 2024, through assurance report to Tenant liaison Panel

Transactional survey are being introduced for key priority service areas, those survey will include the required information

Target - September 2024

A complaints policy must set out the circumstances in which a matter will not be considered as a complaint or escalated, and these circumstances must be fair and reasonable to residents.

Acceptable exclusions include:

• The issue giving rise to the complaint occurred over twelve months ago.
• Legal proceedings have started. This is defined as details of the claim, such as the Claim Form and Particulars of Claim, having been filed at court.
• Matters that have previously been considered under the complaints 
  policy.

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

Landlords must consider their duties under the Equality Act 2010 and anticipate the needs and 
reasonable adjustments of residents who may need to access the complaints process.

Residents must be able to raise their complaints in any way and with any member of staff.

All staff must be aware of the complaints process and be able to pass details of the complaint to the appropriate person within the landlord.

High volumes of complaints must not be seen as a negative, as they can be indicative of a well-publicised and accessible complaints process.

Low complaint volumes are potentially a sign that residents are unable to complain.
 

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

This will detail the two stage process, what will happen at each stage, and the timeframes for responding. The policy must also be published on the landlord’s website.

Landlords must have a person or team assigned to take responsibility for complaint handling, including liaison with the Ombudsman and ensuring complaints are reported to the governing body (or equivalent).

This Code will refer to that person or team as the ‘complaints officer’. This role may be in addition to other duties.

The complaints officer must have access to staff at all levels to facilitate the prompt resolution of complaints.

They must also have the authority and autonomy to act to resolve disputes promptly and fairly.
 

Landlords are expected to prioritise complaint handling and a culture of learning from complaints. All relevant staff must be suitably trained in the importance of complaint handling.

It is important that complaints are seen as a core service and must be resourced to handle complaints effectively.
 

At each stage of the complaints process, complaint handlers must:

• deal with complaints on their merits, act independently, and have an open mind;
• give the resident a fair chance to set out their position;
• take measures to address any actual or perceived conflict of interest;

and

• consider all relevant information and evidence carefully.

Recording keeping in some areas of HPS has been inconsistent complicated by additional pressures such as contractor issues and related system and supplier changes.  This has been address through HPS briefings on expectations for record keeping.

Process improvement is required to ensure that reasonable adjustments, vulnerabilities, and disabilities are consistently recorded, reviewed, and considered.

Additional training and knowledge to be provided alongside improved system functionality.

The Council recognises that information held on vulnerabilities, disabilities and individual needs is inconsistent.

In accordance with the Councils Data Strategy approved March 2024, a tenants census will be undertaken during 2024/25.

Target – January 2025.

Expectations is covered within the draft Customer Services and Communication standard that is subject to Tenant Liaison Panel on 4 September 2024.

Partially compliant – we can demonstrate considerable improvement in this area.

However, additional time is often requested and agreed with the complainant.

Landlords must confirm the following in writing to the resident at the completion of stage 1 in clear and 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;

• details of how to escalate the matter to stage 2 if the individual is not satisfied with the response.

Partially compliant - Improvements needed to ensure deadlines are met 100%.

However, additional time is often requested and agreed with the complainant.

Evidence required demonstrating fully embedded across whole HPS Service

Target – Dec 2024, through continued improved performance.

Landlords must confirm the following in writing to the resident at the completion of stage 2 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

• details of how to escalate the matter to the Ombudsman.

Service if the individual remains dissatisfied.

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.

These can include:

• Apologising.
• Acknowledging where things have gone wrong.
• Providing an explanation, assistance or reasons.
• Taking action if there has been delay.
• Reconsidering or changing a decision.
• Amending a record or adding a  correction or addendum.
• Providing a financial remedy.
• Changing policies, procedures or practices.

Landlords must produce an annual complaints performance and service improvement report for scrutiny and challenge, which must include:

• the annual self-assessment against this Code to ensure their complaint handling policy remains in line with its requirements.
• a qualitative and quantitative analysis of the landlord’s complaint handling performance. This must also include a summary of the types of complaints the landlord has refused to accept.
• any findings of non-compliance with this Code by the Ombudsman.
• the service improvements made as a result of the learning from complaints.
• any annual report about the landlord’s performance from the Ombudsman.

and

• any other relevant reports or publications produced by the Ombudsman in relation to the work of the landlord.

This request will be complied with on or before 30 September 2024 in line with the Ombudsman’s request.

Target – September 2024

As a minimum, the MRC and the governing body (or equivalent) must receive:  

• regular updates on the volume, categories and outcomes of complaints, alongside complaint handling performance.
• regular reviews of issues and trends arising from complaint handling.
• regular updates on the outcomes of the Ombudsman’s investigations and progress made in complying with orders related to severe maladministration findings.

and

• annual complaints performance and service improvement report.

Landlords must have a standard objective in relation to complaint handling for all relevant employees or third parties 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.

and  

• act within the professional standards for engaging with complaints as set by any relevant professional body.