Housing Ombudsman self-assessment

1.8

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.

Yes

Exclusions are set out in the policy.

1.9

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.

Yes

No complaint has been excluded at this time. Information would be given to the complainant.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

1.4

Landlords should recognise the difference between a

Yes

Procedure and training is given with examples. This will also be emphasised in future training too.

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.

1.5

Survey feedback may not necessarily need to be

Yes

We pro-actively follow up dissatisfaction feedback, including advice on how to make a complaint.

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.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

2.1

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.

Yes

Complaints can be made by;

· My Wrekin App

· In writing

· By phone

· In person

· Email

· Social media

2.3

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.

Yes

On website

2.4

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.

Yes

Link on front page of website

2.5

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.

Yes

We routinely assess whether there are barriers to accessing the service or outcomes vary by protected characteristic, for example. Further training on Equality, Diversity and Inclusion is being delivered in Winter 2022.

2.6

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.

Yes

This is included on the website and on social media. During Winter 2022 we will be refreshing our leaflets and posters to include further information.

2.7

Landlords must provide residents with contact

information for the Ombudsman as part of its regular correspondence with residents.

Yes

Information of the Housing Ombudsman is on the website and details given at stage 2 of the complaints process. This will be included in future newsletters too.

2.8

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.

Yes

On website and as part of the complaints process.

Code section

Code requirement

Comply:

Yes/No

Evidence, commentary and any explanations

2.2

Where a landlord has set up channels to communicate

Yes

Private message sent to complainant and requesting different communication channel for next steps. Our process is the same regardless of channel of receipt.

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.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

3.3

Complaint handlers should:

Yes

Training is given to all complaint handlers; a user guide is also available. Toolkits available from the Housing Ombudsman Service are also used and further training through the Institute of Customer Service is currently being planned.

· 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.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

4.1

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.

Yes

3 stage process to formal complaints;

measures in place in accordance with the complaint handling code.

Complaints total – 447

Stage 2 complaints – 18

Stage 3 complaints - 2

Additional stages are not in place and our focus is on resolving at the earliest opportunity.

2021/22 97% contacted within 5 days - further work to improve this is detailed in our Complaints Action Plan.

4.2

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.

Yes

4.6

A complaint investigation must be conducted in an impartial manner.

Yes

The initial investigation is within the service and at stage 2 a completely independent Head of Service reviews the complaint.

4.7

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.

Yes

2021/22 – 96% of complaints were dealt with at stage 1 showing that the complaint handler is adept at resolving complaints.

Training is focussed on ensuring complaints are handled under these principles.

4.11

Landlords must adhere to any reasonable

arrangements agreed with residents in terms of frequency and method of communication

Yes

Complainants are asked their preferred method and frequency of contact.

4.12

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.

Yes

This forms part of the investigation process.

4.13

A landlord must include in its complaints policy its

timescales for a resident to request escalation of a complaint

Yes

A complainant has 14 days to request an escalation, included in the Policy and complaint response.

4.14

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.

Yes

Wrekin have never refused to escalate a complaint.

4.15

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.

Yes

Housing management (Cadre) system holds all of this information.

4.18

Landlords must have policies and procedures in place for managing unacceptable behaviour from residents

and/or their representatives when pursuing a complaint.

Yes

Unreasonable behaviour procedure is in place.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

4.3

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

Yes

This is completed within the initial conversation and at the face to face visits.

4.4

A complaint should be resolved at the earliest possible

Yes

Completed within the initial conversation and any repair actions logged immediately. We have resolved 96% of complaints at stage 1 in 2021/22.

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.

4.5

Landlords should give residents the opportunity to have

Yes

Supported within the policy and at the request of the complainant.

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.

4.8

Where a key issue of a complaint relates to the parties’

Yes

Wrekin have a legal team to support complaints and also manage complaints.

legal obligations landlords should clearly set out their

understanding of the obligations of both parties.

4.9

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

Yes

4.10

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

Yes

We recognise this is an area for us to strengthen in terms of the consistency of this through the process.

4.16

Landlords should seek feedback from residents in

Yes

Survey feedback started in March 2022 currently 71% satisfaction with how the complaint was handled.

relation to the landlord’s complaint handling as part of

the drive to encourage a positive complaint and

learning culture.

4.17

Landlords should recognise the impact that being

Yes

Complaints learning could be better and actions are included in the Complaints Action Plan to strengthen.

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.

4.19

Any restrictions placed on a resident’s contact due to

Yes

Demonstrated within the unreasonable behaviour procedure.

unacceptable behaviour should be appropriate to their

needs and should demonstrate regard for the

provisions of the Equality Act 2010.

5.6

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.

Yes

Training has been given, and the user guide supports this. Response templates are available in the complaints process addressing all points, sign posting if appropriate.

5.8

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

Yes

All complainants receive a letter or email with the complaint resolution and details included.

Code section

Code requirement

Comply:

Yes/No

Evidence, commentary and any explanations

5.9

If all or part of the complaint is not resolved to the resident’s

Yes

No complaints have been refused escalation to stage 2.

2021/22 – 18 stage 2 complaints

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.

5.10

On receipt of the escalation request, landlords must set out their

Yes

All stage 2 complaints are contacted within timeframes by a Senior Manager of Wrekin.

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.

5.11

Landlords must only escalate a complaint to stage two once it

Yes

Escalation would only occur following stage one and at the resident request.

has completed stage one and at the request of the resident.

5.12

The person considering the complaint at stage two, must not be

Yes

Senior Manages at stage 2 of the process are independent and not from the area of the complaint.

the same person that considered the complaint at stage one.

5.13

Landlords must respond to the stage two complaint within 20

Yes

2021/22 – 81% resolved within timeframes. Contact has been made with residents throughout this.

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.

5.16

Landlords must confirm the following in writing to the resident at

Yes

All complainants receive a letter or email with the complaint resolution.

Details of the process ending or offering a stage 3 are given in the response. How to contact the Housing Ombudsman is detailed within the correspondence.

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.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

5.17

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.

Yes

2021/22 - 2 Stage 3 complaints

2021/22 – 100%

Wrekin have a 3 Stage complaints process, this is to ensure that if necessary and the complainant wishes to they can have their complaint reviewed by one of Wrekin’s Executive Management team and also one of Wrekin’s Involved Tenants.

Timeframes are 10 working days if a mutual meeting date can be arranged.

5.18

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

Yes

Complainants receive a letter or email with the resolution and details of the Housing Ombudsman service.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

5.14

If an extension beyond 10 working days is required to enable the

Yes

Updates are given throughout the 10 working days.

landlord to respond to the complaint fully, this should be agreed

by both parties.

5.15

Where agreement over an extension period cannot be reached,

No

Wrekin have not currently had any exceeding 10 working days without mutual agreement. Any future complaints will receive Housing Ombudsman details.

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

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

5.18

Complaints should only go to a third stage if the resident has

Yes

Stage 3 complaints are completed within 10 working days and are only held at the resident’s request.

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.

5.19

Where agreement over an extension period cannot be reached,

Yes

Wrekin have not currently had any exceeding 20 working days without mutual agreement. Any future complaints will receive Housing Ombudsman details.

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.

Code section

Code requirement

Comply:

Yes/No

Evidence, commentary and any explanations

6.3

Landlords should look beyond the circumstances of the

Yes

Within the process there is a root cause and learning analysis. Further actions to evolve this are within the Complaints Action Plan.

individual complaint and consider whether anything needs to be

‘put right’ in terms of process or systems to the benefit of all

residents.

6.7

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

Yes

Inline with Wrekin’s compensation policy.

redress. The landlord should still offer a resolution where

possible, obtaining legal advice as to how any offer of resolution

should be worded.

Code section

Code requirement

Comply:

Yes/No

Evidence, commentary and any explanations

7.2

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.

Yes

We plan to strengthen this in our 2021/22 annual report. Further details on complaints have been reported to our Service Quality Committee and Customer Voice Panel.

Code section

Code requirement

Comply:

Yes/No

Evidence, commentary and any explanations

7.3

A member of the governing body should be appointed to have

No

The Director of Business Solutions is the lead for consumer regulation and at present will be the person with lead responsibility. We will review whether this should be a member of the governing body on an annual basis.

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.

7.4

As a minimum, governing bodies should receive:

Partial

Performance is reported to Customer Voice Panel and Service Quality Committee. We plan to strengthen this further in Autumn 2022 through a new report bringing together complaints and customer feedback.

· 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.

7.5

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.

Partial

There is more to do to ensure this is consistently done. An action plan is in place to take this forward.

7.6

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.

Yes

The Policy and Procedure reflects this.

Code section

Code requirement

Comply: Yes/No

Evidence, commentary and any explanations

8.1

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

requirements.

Yes

This has been done as best practice previously.

8.2

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

Yes

This would be done if relevant.

8.3

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

Yes

The self-assessment has been completed annually since 2020 and published on Wrekin’s website.

Performance of complaints is published in Wrekin’s Annual Report.

The Executive Management Team and Board will have sight of the self-assessment.