Section 5 - The complaint handling process
Code provision 5.1
Code requirement
Landlords must have a single policy in place for dealing with complaints covered by this Code. Residents must not be treated differently if they complain.
Comply
Yes.
Evidence
Housing service complaints policy.
1.1 Slough Borough Council performs a social landlord function in relation to its retained rented and leasehold housing stock. As a Registered Provider of social housing, the services are subject to the regulatory requirements of the Regulator of Social Housing as set out in the Regulatory Framework for Social Housing in England.
2.5 The Service means any service managed and delivered by the council that is funded wholly from the Housing Revenue Account.
Commentary / explanation
This is set out in the Housing Services Complaints Policy. The policy stipulates that the Council Performs a landlord function to its rented and leasehold housing stock and this policy is in relation to any service managed and delivered from the Housing Revenue Account.
Code provision 5.2
Code requirement
The early and local resolution of issues between landlords and residents is key to effective complaint handling. It is not appropriate to have extra named stages (such as ‘stage 0’ or ‘informal complaint’) as this causes unnecessary confusion.
Comply
Yes.
Evidence
Housing service complaints policy.
Commentary / explanation
We have a two-stage process.
Code provision 5.3
Code requirement
A process with more than two stages is not acceptable under any circumstances as this will make the complaint process unduly long and delay access to the Ombudsman.
Comply
Yes.
Evidence
Housing service complaints policy.
3.5 A two stage complaints process will be used to manage and respond to complaints. All complaints will be acknowledged within 2 working days of receipt and:
- responded to within 10 working days at Stage 1 of the process
- reviewed and responded to within 20 working days at Stage 2 of the process.
Commentary / explanation
This is set out under the Housing Services Policy sections 3.5, 6, 7 and 8.
Code provision 5.4
Code requirement
Where a landlord’s complaint response is handled by a third party (e.g. a contractor or independent adjudicator) at any stage, it must form part of the two stage complaints process set out in this Code. Residents must not be expected to go through two complaints processes.
Comply
Yes.
Evidence
Housing service complaints policy.
9.2 All Council officers in relevant services (including sub-contractors/partner organisations) will be aware of the complaint's procedure relating to the Council’s housing management function and be able to advise residents on how to access the process and what they can expect.
Commentary / explanation
Our compliant policy makes it clear that residents will go through Slough Borough Councils Housing Service Complaints Policy including subcontractor and partner organisations.
Code provision 5.5
Code requirement
Landlords are responsible for ensuring that any third parties handle complaints in line with the Code.
Comply
Yes.
Evidence
Housing service complaints policy.
9.2 All Council officers in relevant services (including sub-contractors/partner organisations) will be aware of the complaint's procedure relating to the Council’s housing management function and be able to advise residents on how to access the process and what they can expect.
Commentary / explanation
This is set out in 9.2 of the Housing Services Complaints Policy.
Code provision 5.6
Code requirement
When a complaint is logged at Stage 1 or escalated to Stage 2, landlords must set out their understanding of the complaint and the outcomes the resident is seeking. The Code will refer to this as “the complaint definition”. If any aspect of the complaint is unclear, the resident must be asked for clarification.
Comply
No.
Evidence
Template letters need to reflect this.
Commentary / explanation
Our template letters will be reviewed alongside the Housing Service Complaints Policy by March 2025.
Code provision 5.7
Code requirement
When a complaint is acknowledged at either stage, landlords must be clear which aspects of the complaint they are, and are not, responsible for and clarify any areas where this is not clear.
Comply
No.
Evidence
Template letters need to reflect this.
Commentary / explanation
Our template letters will be reviewed alongside the Housing Service Complaints Policy by March 2025.
Code provision 5.8
Code requirement
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.
Comply
No.
Evidence
Not stated in current policy / documentation.
Commentary / explanation
The Housing Service Complaints Policy, process and procedure will be reviewed and include this in the review which will be undertaken by March 2025.
Code provision 5.9
Code requirement
Where a response to a complaint will fall outside the timescales set out in this Code, the landlord must agree with the resident suitable intervals for keeping them informed about their complaint.
Comply
No.
Evidence
Not stated in policy / no standard process however there are pockets of good practice being delivered around this within the organisation.
Commentary / explanation
The Housing Service Complaints Policy, process and procedure will be reviewed and include this in the review which will be undertaken by March 2025.
Code provision 5.10
Code requirement
Landlords must make reasonable adjustments for residents where appropriate under the Equality Act 2010. Landlords must keep a record of any reasonable adjustments agreed, as well as a record of any disabilities a resident has disclosed. Any agreed reasonable adjustments must be kept under active review.
Comply
Yes.
Evidence
Equality and discrimination advice page.
Commentary / explanation
While we do not have a separate policy, reasonable adjustments can be requested as per the Equalities Act 2010.
An example of this is our Interpreting services via ONCALL provides all modalities of interpreting services such as Face-to-Face, telephone and video, via its in-house, technologically driven platform ‘NextGen’ as well as the website offers translation via Google translate and we also provide qualified British Sign Language (BSL) interpreters to service users who are deaf on request as well as a text relay service which offers text-to-speech and speech-to-text translation services. Any reasonable adjustments requested will be noted on our housing management system.
All staff within the council must complete Equality in the workplace mandatory training to ensure they understand what the act covers and how we ensure we include it in the workplace for residents and staff. This is an annual course for all employees.
Code provision 5.11
Code requirement
Landlords must not refuse to escalate a complaint through all stages of the complaints procedure unless it has valid reasons to do so. Landlords must clearly set out these reasons, and they must comply with the provisions set out in section 2 of this Code.
Comply
No.
Evidence
This is not set out clearly in the policy.
Commentary / explanation
The Housing Service Complaints Policy, process and procedure will be reviewed and include this in the review which will be undertaken by March 2025.
Code provision 5.12
Code requirement
A full record must be kept of the complaint, 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 relevant supporting documentation such as reports or surveys.
Comply
Yes.
Evidence
Housing service complaints policy.
2.4 Intelex is the Council’s complaints’ management system.
5.3 Details of all communication in relation to a complaint will be recorded on Intelex.
Commentary / explanation
5.3 of the Housing Service Complaints Policy sets this out.
Code provision 5.13
Code requirement
Landlords must have processes in place to ensure a complaint can be remedied at any stage of its complaints process. Landlords must ensure appropriate remedies can be provided at any stage of the complaints process without the need for escalation.
Comply
No.
Evidence
We do not have documented processes or procedures in place which clearly ensures a complaint can be remedied at any stage of its complaints process and that appropriate remedies can be provided at any stage of the complaints process without the need for escalation.
Commentary / explanation
The Housing Service Complaints Policy, process and procedure will be reviewed and include this in the review which will be undertaken by March 2025.
Code provision 5.14
Code requirement
Landlords must have policies and procedures in place for managing unacceptable behaviour from residents and/or their representatives. Landlords must be able to evidence reasons for putting any restrictions in place and must keep restrictions under regular review.
Comply
Yes.
Evidence
Management of unreasonable behaviour policy.
Commentary / explanation
Slough Borough Council have a Management of unreasonable Customer behaviour Policy. This is due for review.
Code provision 5.15
Code requirement
Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010.
Comply
Yes.
Evidence
Management of unreasonable behaviour policy.
Commentary / explanation
Please refer to the policy.