Housing Ombudsman Complaints Code Self Assessment

We're committed to meeting the requirements of the Housing Ombudsman's Complaint Handling Code.

The Housing Ombudsman is a free, independent and impartial organisation which resolves disputes between tenants and landlords. It enables landlords to resolve complaints quickly.

We carry out regular self-assessments to make sure that we are complying with the Housing Ombudsman's Complaint Handling Code and to make sure we learn from customer feedback to improve our services.

Learn more about the Housing Ombudsman Service on their website.

Our self-assessment

The Housing Ombudsman's Complaint Handling Code sets out 'musts' (mandatory) and 'shoulds' (discretionary) requirements for complaints handling.

Below is a summary of what we must comply with and how we comply as of May 2023.

How we define a complaint

What we are required to do

We must:

Define a complaint 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'
Handle a complaint that is submitted via a third party or representative in line with the landlord’s complaints policy. A tenant does not have to use the word ‘complaint’ for it to be treated as such
Log a complaint if further enquiries are needed to resolve the matter, or if the resident requests it, the issue must be logged as a complaint
Accept a complaint unless there is a valid reason not to do so
Clearly set out the circumstances in which a matter will not be considered, and these circumstances should be fair and reasonable to residents
If we decide not to accept a complaint, we must provide a detailed explanation setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Housing Ombudsman.

How we comply

We:

Include the official definition of a complaint in our Complaints and Feedback Policy and the ‘how to make a complaint’ section on our website
Make sure all our colleagues are trained to:
Know when a complaint needs to be recorded as such and how to try to resolve dissatisfaction at the first point of contact
Understand when feedback is a complaint, even when the word 'complaint' is not used
How to manage complaints from a third party or representative
Clearly set out when we won't consider a matter as a complaint and the reasons why in our policy.

Making sure our complaints process is visible and accessible

What we are required to do

We must:

Make sure we offer different ways, including phone, digital and in-person.
Make sure our complaint policy is clear and in an accessible format.
Include information about making a complaint on our website and make sure it is easy to find.
Make sure that we comply with the Equality Act 2010.
Make sure that we signpost our complaints policy and process, the Complaint Handling Code and the Housing Ombudsman service and contact details in leaflets, posters, newsletters, online and letters.
Make sure that anyone making a complaint understands their right to access the Housing Ombudsman service at any stage.

How we comply

We:

Make sure that information about how to make a complaint is in our policy, easy to find on our website, included in our newsletters and leaflets.
Offer lots of different ways to contact us to make a complaint.
Provide accessible formats, including Easy Read, large print, clear print, plain English and video explainers with audio and captions.
Provide reasonable adjustments where required, dependent on the individual needs of the customer and train colleagues in the requirements of the Equality Act 2010.
Have an Equality, Diversity and Inclusion Policy and action plan.
Include information about the right to access the Housing Ombudsman service at any stage of a complaint in any letters regarding the complaint.
Information about the Complaint Handling Code and the Housing Ombudsman service is available on our website, relevant leaflets, and letters.

How our employees handle complaints

What we are required to do

We must:

Have a dedicated person or team who has overall responsibility for managing complaints.
Make sure that the dedicated person or team has appropriate complaint handling skills and no conflicts of interest.

How we comply

We:

Have a skilled complaints coordinator who is not directly involved with service delivery and a Continuous Improvement Team to make sure we have cover at all times.
Provide a report to Executive Board every quarter and to board every year
Train all colleagues involved in complaint handling.

Complaint handling principles

What we are required to do

We must:

Try and resolve a concern in agreement with the tenant. We must make sure that efforts to resolve a tenant's concerns do not obstruct access to the complaints procedure or result in any unreasonable delay.
Acknowledge and log a complaint within five days of receipt.
Set out our understanding of the complaint and the outcomes to the tenant when we acknowledge the complaint. If any aspect of the complaint is unclear, we must ask for clarification and agree on a full definition.
Investigate complaints in an impartial manner.
Make sure our complaint handlers:

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

Adhere to any reasonable arrangements agreed with tenants regarding frequency and method of communication.
Give a fair opportunity for the tenant and any colleague who is the subject of a complaint to:

Set out their position
Comment on any adverse findings before a final decision is made.

Include our timescales for a tenant to request a complaint be advanced to stage two in our policy.
Not unreasonably refuse to escalate a complaint through all stages of the complaints procedure and have clear and valid reasons for taking that action. Reasons for declining to escalate a complaint must be clearly set out in our policy and must be the same as the reasons for not accepting a complaint.
Keep a full record 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 tenant, correspondence with other parties and any reports or surveys prepared.
Have policies and procedures in place for managing unacceptable behaviour from tenants and/or their representatives when pursuing a complaint.

How we comply

We:

Train our complaint handlers in all aspects of complaints handling.
Try to resolve dissatisfaction at the first point of contact. Any that are resolved in this way are recorded accordingly and do not delay any dissatisfaction from progressing through our complaints procedure, nor is it an extra stage.
Assign complaints about an employee to their line manager. If a senior manager has been involved at stage one, they are not assigned as the stage two reviewing manager.
Record all correspondence to and from the customer.

Stage one of our complaints process

What we are required to do

We must:

Respond to the complaint within ten working days of being logged. Exceptionally, we may provide an explanation to the customer containing a clear timeframe for when the response will be received. This should not exceed a further ten days without good reason.
Send a response to the tenant when the answer to the complaint is known. Outstanding actions must still be tracked and actioned expeditiously with regular updates provided to the resident.
Address all points raised in the complaint and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.
Confirm the following in writing to the customer at the completion of stage one in clear, plain English:

- - 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 and details of how to escalate the matter to stage two if the tenant is not satisfied with the answer

How we comply

We:

Acknowledge a complaint within five working days and respond in writing within ten working days.
Train our complaint handlers in all aspects of complaints handling.
Record and monitor all actions on our housing management system.
Use template letters to make sure we include all the information required.

Stage two of our complaints process

What we are required to do

We must:

Advance a complaint to stage two if all or part of the complaint is not resolved to the tenant’s satisfaction at stage one unless an exclusion ground now applies. In instances where we decline to advance a complaint, we must clearly communicate in writing our reasons for not advancing it to stage two and the tenant’s right to approach the Ombudsman about the decision.
Set out our understanding of outstanding issues and the outcomes the tenant wants when we receive a request to escalate to stage two. We must ask the tenant for clarification and the full definition agreed between both parties if any aspect of the complaint is unclear.
Only escalate a complaint to stage two once it has completed stage one and at the tenant’s request.
Make sure that the person considering the complaint at stage two is not the same person that considered the complaint at stage one.
Respond to the stage two complaint within 20 working days of being escalated. Exceptionally, we 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.
Confirm the following in writing to the customer at the completion of stage two in clear, plain English:

Complaint stage
Complaint definition
Decision on the complaint
Reasons for any decisions made
Details of any remedy offered to put things right
Details of any outstanding actions
Escalate the matter to the Housing Ombudsman service if the customer remains dissatisfied

How we comply

We:

Make sure that we escalate to stage two if the tenant is not happy with the outcome of their complaint. We will advise in writing if a complaint is excluded from being escalated.
Ask for clarification if we need it.
Make sure that all stage two reviews are carried out by a senior manager who has not been involved in reviewing the complaint at stage one.
Agree on any extensions with the customer, and we do not exceed the Housing Ombudsman Code timescales.

Putting things right

What we are required to do

We must:

Acknowledge when something goes wrong and tell you what actions we have taken, or will take, to put things right.
Carefully manage the expectations and not promise anything that cannot be delivered or would cause unfairness to other tenants.
Clearly set out what will happen and by when, and make sure it happens.
In awarding compensation, consider:

If any statutory payments are due
If there are any quantifiable losses
A tenant's time and effort
Any distress and inconvenience caused

How we comply

We:

Train our complaint handlers in all aspects of complaints handling.
Monitor any outstanding actions or open complaint.
Have a Goodwill/Compensation Policy.

Making sure that we learn from your feedback and that we are compliant

What we are required to do

We must:

Report back on wider learning and improvements from complaints in our tenants’ annual review and more frequently to tenants and colleagues.
Carry out an annual self-assessment against the Code to ensure compliance.
Carry out a self-assessment following a significant restructure and/or procedure change.
Following each self-assessment:
- - Report the outcome of our self-assessment to our governing body.
  - Publish the outcome of our assessment on our website.
  - Include the self-assessment in our tenant annual review.

How we comply

We:

Report on self-assessment and lessons learnt to our board and our customer forums/scrutiny.
Publish our self-assessment on our website and in our annual tenant review.

Read our full Housing Ombudsman Complaint Handling Code Self Assessment