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.


 Contents

Section 1 - Definition of a complaint 

Mandatory ‘must’ requirements

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 Complaints Policy refers.
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

Officers consider what is being said by the complainant and act accordingly.

Complaints Policy refers.

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  
1.7 A landlord must accept a complaint unless there is a valid reason not to do so. Yes Complaints Policy refers.
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 Complaints Policy refers.
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 Complaints Policy refers.

Best practice 'should' requirements 

Code section Code requirement 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

Officers are experienced and understand the difference. Matters are dealt with appropriately and proportionately. Complaints Policy refers.

The standard acknowledgement letter also includes a paragraph:

Please note: It may be that upon looking into this matter further, it is more appropriate to address the issue being raised via an alternative and more proportionate route, if this is the case, we will inform you.

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

Officers would sign post to the complaints procedure where necessary and appropriate to do so.


Section 2 - Accessibility and awareness

Mandatory 'must' requirements 

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 Policy refers.
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 Complaints Policy refers.
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  
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

Complaints Policy refers.

Equality Training is routinely carried out corporately for all employees.

A new Corporate Customer Contact group for all services is being convened in the Autumn which will address this further.

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

Published on the web-site, leaflets, posters and newsletters.

Request to include in every addition on the back page of the Tenants' newsletter ‘In Touch’ magazine that goes to every household. Plus in tenant e-newsletter.

2.7

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

Yes

This has been, and will continue to be included in newsletters both electronic and paper version.

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

The Complaint Policy is provided at acknowledgement stage i.e. from the outset of the complaint, with useful sign posting including Ombudsman.

Best practice 'should' requirements 

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

Any messages received through social media channels that might constitute the need for the issue to be addressed as a formal complaint will be sign posted accordingly to the complaints policy and procedure. Communications Officers will remove any data as appropriate on social media platforms ensuring confidentiality and privacy.

Complaints Policy refers.


Section 3 - Complaint handling personnel

Mandatory 'must' requirements

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

The Council has a dedicated officer; ‘customer experience officer’ that deals with complaints.

We have a dedicated Cabinet member/portfolio holder for housing, the ‘governing body’. Complaints are reported to Overview & Scrutiny Committee annually.

3.2

The complaint handler appointed must have appropriate complaint handling skills and no conflicts of interest.

Yes

As above, the officer is experienced in complaint handling and is part of a specific tenant satisfaction housing service area.

Best practice 'should' requirements

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

 

As above, the officer is experienced in complaint handling and is part of a specific tenant satisfaction housing service area.


Section 4 - Complaint handling principles

Mandatory 'must' requirements

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

Officers are aware that by acting on the operational work that may be required to address the complaint does not mean that the complaint is completed.  Quick resolution is sought with the follow-up stage 1 complaint reply to follow where appropriate.

The procedure incudes stage 1 and 2 and acknowledged within 5 working days of receipt.
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

Where the complainant has opted for an e-mail reply, the system automates an acknowledgement letter from the complaint system which is generic. The follow-up to this is to ascertain the detail of the complaint and desired outcomes which is carried out by the Customer Experience Officer in order to manage expectations.

4.6

A complaint investigation must be conducted in an impartial manner.

Yes  
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  
4.11

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

Yes When the complaint is logged, a question is asked as to how the complainant would like to be communicated with ‘contact preference’.
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  
4.13

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

Yes

The Council is flexible on this, and on balance, will take each case on its own merits.  

Complaints Policy refers.

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  
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 Complaint records are comprehensive
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 Complaints Policy refers.

Best practice 'should' requirements

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

 

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 Complaints Policy refers.
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 Complaints Policy refers.
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 Complaints Policy refers.
4.9 Communication with the resident should not generally identify individual members of staff or contractors. Yes This point has been highlighted going forward to refer to ‘the Council’ where possible or contractor working on behalf of the Council or refer to job titles and not named officers.
4.10 Landlords should keep residents regularly updated about the progress of the investigation. Yes We do this where possible and appropriate to do so in addition to the standard correspondence.
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

From June 2023 the tenant panel complaint review group meets every 3 months to consider complaints.

In addition, from the Autumn/Winter 2023, a telephone survey is going to be carried out to ask complainants about the complaint handling process and how satisfied they were with this.

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

Staff are supported and know how to raise any concerns/issues.

A positive complaints culture is continually being encouraged through the staff newsletter and associated articles.

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

The Complaints Policy refers. One form of contact will be maintained which will take into account any reasonable adjustments required and with due regard to any protected characteristics.

 

Section 5 - Complaints stages

Mandatory 'must' requirements

Stage 1

Code section Code requirement Comply:
Yes/No
Evidence, commentary and any 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.

Yes

Refer to Policy and systems/processes.

 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

We aim to send the stage 1 reply within 10 working days as per the policy. Follow-up letters are sent where appropriate.

Letters are clear and easy to understand without being overly officious.

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.  

There is also the offer of a discussion about the content of the letter should the tenant find that useful.

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  

Stage 2

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 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

Refer to Policy.

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

Often it is sensible to refer back to the stage 1 complaint reply content, or even include a copy for ease of reference where appropriate to do so.

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

Refer to 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  
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. Yes  
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  

Stage 3

Code section Code requirement Comply:
Yes/No
Evidence, commentary and any explanations
5.17 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

The council operates a 2-stage complaints procedure.

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  

 Best practice 'should' requirements

Stage 1

Code section Code requirement Comply:
Yes/No
Evidence, commentary and any 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

 

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  
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  
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 We will normally include this as ‘supplementary’ within the complaint reply, (ie received after the initial complaint) in the first instance to seek early resolution.

Stage 2

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 landlord to respond to the complaint fully, this should be agreed by both parties. Yes

 

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  

Stage 3

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 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.
Yes

 

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

Mandatory 'must' requirements 

Code section Code requirement Comply:
Yes/No
Evidence, commentary and any 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  
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  
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  
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  

Best practice 'should' requirements 

Code section Code requirement Comply:
Yes/No
Evidence, commentary and any 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 Head of Service considers if there is wider impact.
 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

Legal advice will be sought where appropriate. 


Section 7 - Continuous learning and improvement 

Mandatory 'must' requirements 

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 Annual Report which is published on the Council web-site following its consideration at Overview & Scrutiny Committee. A new Annual report to tenants will address complaint handling and leaning from complaints together with work with Tenant satisfaction survey/measures.

Best practice 'should' requirements 

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 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 Cabinet Member for Housing/portfolio holder has routine meetings with Head of Service.  He also attends the complaint review group.
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 See above.
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  
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 Council’s staff intranet includes the standard objective of the policy:

“To provide the Council with a recognised framework for managing formal complaints. To provide residents with an accessible, fair and recognised procedure to address dissatisfaction, enabling appropriate escalation through each stage of the process.”

Head of Service is looking to include the ‘collective responsibility’ approach in all staff appraisals.

This is also referenced in the Council’s values, “Vision 2040”:

“Implementing a new ‘Customer Experience Plan’, ensuring that our residents and customers receive a good-quality, efficient and accessible service when dealing with the Council."

And;

“Embedding a positive organisational culture across the Council."


Section 8 - Self-assessment and compliance

Mandatory 'must' requirements

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

December 2020 self -assessment

October 2022 self – assessment

We have looked to amend the policy as and when required to ensure the policy and associated complaint handling remains fit for purpose.

Self-assessment is now diarised annually for the Head of Housing and Housing Complaints Officer.

8.2 Landlords must also carry out a self-assessment following a significant restructure and/or change in procedures. Yes Last significant restructure was 2019.
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

Website, formal complaints annual report, members update through ‘Members Information Bulletin’ 

Tenant satisfaction measures annual report will include data 2023/24 and will be produced in 2024.

Self-Assessment completed 1.8.23


Last Updated on Thursday, February 29, 2024