Housing Ombudsman Complaint Handling Code: Self-assessment form

This self-assessment form should be completed by the complaints officer and discussed at the landlord’s governing body annually.

Evidence should be included to support all statements with additional commentary as necessary.

Explanations must also be provided where a mandatory ‘must’ requirement is not met to set out the rationale for the alternative approach adopted and why this delivers a better outcome.

Section 1 -Definition of a complaint

Code section	Code requirement	Comply: yes/no	Evidence, commentary and any explanations
1.2	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.	Yes	Copy of complaints leaflet
1.3	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.	Yes	The word ‘complaint’ does not need to be used. We require consent to be given to accept a complaint from a third party.
1.6	… if further enquiries are needed to resolve the matter, or if the resident requests it, the issue must be logged as a complaint.	Yes	If issues are not resolved informally, a formal complaint investigation takes place.
1.7	A landlord must accept a complaint unless there is a valid reason not to do so.	Yes	We accept complaints unless there is a valid reason.
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	In the policy on our website at 2.1.9 Corporate complaints procedure
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	See 1.8 above

Code section	Code requirements	Comply: yes/no	Evidence, commentary and any explanations
1.4	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.	Yes	Cases are triaged at first contact to distinguish between these
1.5	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.	Yes	Explained in letter regarding Tenant Satisfaction Survey

Section 2 – Accessibility and awareness

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	We offer all of these channels.
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	We have an electronic leaflet, a physical leaflet and a 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	Complaints information
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	All staff have to undergo Equality and Diversity training.
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	All staff have to undergo Equality and Diversity training.
2.7	Landlords must provide residents with contact information for the Ombudsman as part of its regular correspondence with residents.	Yes	All paperwork revised from October 2022   See above
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	Added to stage 1 acknowledgement letter from October 22.

Code section	Code requirement	Comply: yes/no	Evidence, commentary and any explanations
2.2	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.	Yes	The policy is generic for all channels of complaint communication.

Section 3 – Complaint handling personnel

Code section	Code requirement	Comply: yes/no	Evidence, commentary and any explanations
3.1	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”.	Yes	Customer Relations Team deal with all complaints that come to the Council. Reports are generated quarterly to the Housing Management Team.
3.2	…the complaint handler appointed must have appropriate complaint handling skills and no conflicts of interest.	Yes	Team has undergone training conducted by the Housing Ombudsman. If a member of the team knows the complainant they hand it to another team member

Code section	Code requirement	Comply: yes/no	Evidence, commentary and any explanations
3.3	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.	Yes	Contact Centre and Customer Relations Team have training specific to handling upset residents. CRT can make recommendations to operational teams and staff at all levels re resolution of resolution.

Section 4 – Complaint handling principles

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.	Partial	RBC has a stage 0, but code includes flexibility for Local Authority Landlords to work in line with the corporate scheme.
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	Complaints team will clarify complaint in the acknowledgement and say that the investigating officer will follow up for any further issues.
4.6	A complaint investigation must be conducted in an impartial manner.	Yes	The response is checked by CRT for impartiality
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	Responses are QA by the complaints team
4.11	Landlords must adhere to any reasonable arrangements agreed with residents in terms of frequency and method of communication	Yes	Responses are QA by the complaints team
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	Responses  and investigations are QA by the complaints team
4.13	A landlord must include in its complaints policy its timescales for a resident to request escalation of a complaint	Yes	Corporate complaints procedure
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	Policy updated
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	All correspondence between all relevant parties relating to complaints is saved
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	See what we expect from you

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
4.3	Landlords should manage residents’ expectations from the outset, being clear where a desired outcome is unreasonable or unrealistic	Yes	Quality reviewed but senior managers  – regular audits will be completed
4.4	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.	Yes	Quality reviewed but senior managers  – regular audits will be completed
4.5	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.	Yes	CRT will deal with third party with consent and complainant can be accompanied to a complaint meeting if necessary.
4.8	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.	Yes	Quality reviewed but senior managers  – regular audits will be completed
4.9	Communication with the resident should not generally identify individual members of staff or contractors.	Yes	Generally, only mentioned where a specific officer is mentioned In the complaint.
4.10	Landlords should keep residents regularly updated about the progress of the investigation.	Yes	Any delays are communicated to the complainant.
4.16	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	Yes	Tenant Satisfaction Survey
4.17	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	Yes	Learning action plans in place. HCMT to do an annual review of key trends. Complaints training available on the Learning Pool. Bite size training being delivered within the Housing Service to encourage a more focus approach to responding to complaints.
4.19	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.	Yes	RBC has a policy in place to manage unacceptable behaviour from customers, this is currently being reviewed

Section 5 – Complaint stages

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
5.1	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.	No	Our complaint policy is 20 working days as it is the same corporate policy across the Council. The complaint handling IT cannot deal with 2 different timescales.
5.5	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.	Yes	Generally speaking, however sometimes the resident asks for the response to be delayed until all actions are complete.
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	Responses are checked by the CRT to ensure all points are covered.
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	This is all covered in the standard template

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
5.9	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.	Yes	We clearly explain if we are not going to escalate the complaint and provide the Ombudsman details.
5.10	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.	Yes	The investigating officer has to meet or speak to the complainant to establish the scope of the Stage 2 request
5.11	Landlords must only escalate a complaint to stage two once it has completed stage one and at the request of the resident.	Yes	This is our corporate policy
5.12	The person considering the complaint at stage two, must not be the same person that considered the complaint at stage one.	Yes	Head of Service allocates to a manager who has not been involved directly
5.13	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.	No	Our corporate policy is 30 working days as it is a Council-wide policy – code allows local authority landlords to work in line with Corporate Policies.
5.16	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.	Yes	Complainants receive the full investigation report and the adjudication letter from the Head of Service.   We do not have a third stage

Code section	Code requirement	Comply: yes/no	Evidence, commentary and 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.	N/A
5.20	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	N/A

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
5.2	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.	Yes	We communicate this with the complainant and endeavour to get their agreement. This is recorded by the complaints team.
5.3	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.	Yes	Process updated from October 2022 -complaints team will refer them back to the ombudsman details.
5.4	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.	Yes	Previous history is passed to the investigator and their IT systems would have the relevant information too.
5.7	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.	Yes	Any additional points are passed to the investigating officer for inclusion. If they are not relevant then these are logged as new complaints.

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
5.14	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.	Yes	Investigators agree any extension beyond 30 working days with complainants.
5.15	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	Yes	Paperwork updated form October 2022

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
5.18	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.	N/A
5.19	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.	N/A

Section 6 – Putting things right

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
6.1	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.	Yes	Included in the complaint response
6.2	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.	Yes	Monitored by HCMT from October 2022
6.5	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.	Yes	Monitored by HCMT from October 2022
6.6	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.	Yes	Recommendations are made by CRT if necessary.

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
6.3	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.	Yes	Learning Action Plans are completed and monitored by Housing Management Team
6.7	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.	Yes	Monitored by Complaints team.

Section 7 – Continuous learning and improvement

Code section	Code requirement	Comply: yes/no	Evidence, commentary and 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	Reports are produced quarterly and annually.

Code section	Code requirement	Comply: yes/no	Evidence, commentary and explanations
7.3	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.	Yes	We have CMT and DMT and HCT
7.4	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.	Yes	We do weekly, two weekly monitoring reports and also provide quarterly annual data to all of the above to lead member.   We continue the process of self-assessment in 22/23.   Annual report to be taken to committee.
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.	Yes	Process to be updated in October 2022
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	CRT manage all of the complaints and have oversight and work collaboratively with the service and management team to ensure customers are responded to in accordance with our complaints’ procedure.

Section 8 – Self-assessment and compliance

Code section	Code requirement	Comply: yes/no	Evidence, commentary and 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	Assessment presented to HNL committee annually
8.2	Landlords must also carry out a self-assessment following a significant restructure and/or change in procedures.	Yes	Process to be updated from October 2022
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	Assessment presented to HNL committee annually