ATTITUDES, RIGHTS & RESPECT – HOUSING OMBUDSMAN SERVICE SPOTLIGHT REPORT RECOMMENDATIONS
In January 2024 the Housing Ombudsman released a Spotlight report called Attitudes, Respect and Rights: relationship of equals. This was considered necessary because of the learning that could be shared with social landlords based on the complaints that had been received by the Ombudsman that related to the approach taken to customers and what appeared to be an increase in the vulnerabilities of customers in social housing. There are a range of 23 recommendations for landlords, most of which Westward is already working toward or exploring, such as customer segmentation. The assessment, once agreed by the Executive Team, will be followed by an action plan. The Ombudsman Service confirmed in a webinar on 7 August 2024 that they expect landlords to be working on, and implementing the recommendations relevant to them, within 18 months of the release of the report. The webinar emphasised that landlords should determine the relevant recommendations for their services and that, whilst believed to be good practice, they were not mandatory.
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Recommendations |
Assessment (RAG) |
Evidence |
Landlords’ leadership |
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Culture, vision and values |
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ARR 1 |
Review your mission statement to ensure it is reflective of your current, and future, service. Consider at Board level if you are assured your current approach to vulnerabilities is working |
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Strategic plan has been reviewed and developed with customer and staff input Customer Segmentation highlights our customer needs and vulnerabilities, Board have received and discussed the segmentation information. |
ARR 2 |
Undertake a review at Board level as to whether you are currently offering a ‘human-centric’ service provision. If not, identify the barriers to this and what needs to change in order to introduce and then embed this culture and ethos |
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Customer Segmentation is the starting piece for developing a more ‘human centric’ approach, data has been shared with Board – need to establish next steps in the Engagement Strategy. To be approved at January 2025 Board. ASB process ensures there is consideration of individual needs both perpetrator and complainant. At point of let specific household needs are recorded, this can be added to at any time. Ongoing campaigns to ensure that we are aware of customer vulnerabilities. Safeguarding processes highlight specific household concerns and additional support is sought/offered.
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ARR 3 |
Consider adopting a values-based recruitment model to improve resident/landlord relationships. |
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Recruitment process asks candidates to highlight how they meet our values Interviews conducted on a competency based process In depth training delivered to all managers on recruitment Where appropriate customers included on the recruitment panel. E.g. CEO recruitment |
What does the resident need? |
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ARR 4 |
Review your vulnerability policy in conjunction with current practice. Is the policy being implemented? If not, identify where the disconnect lies |
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EDI policy in place, needs to be updated to include vulnerability and reasonable adjustments. Equality assessment undertaken on all ASB enforcement cases Employee assistance programme in place Currently no specified vulnerability policy in place. Customer Segmentation highlights need in customer base, services to be designed with this in mind. |
ARR 5 |
Implement a vulnerability strategy, including how it is defined, who assesses, and what the review process is. This must be in line with The Equality Act, the Human Rights Act and the Care Act. This should be co-produced with residents, and consider any future good practice guidance published by the Housing Ombudsman, following engagement and consultation. |
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Currently no vulnerability strategy in place however there is an EDI policy in place which will be updated to include vulnerability and reasonable adjustments. This will be an action. Follow on from segmentation work will include consideration of service flexibility based on need. |
ARR 6 |
Implement a specific reasonable adjustments policy |
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Reasonable adjustments included in Health and Sickness Policy consistency assured through the People team & H&S Disabled Adaptations Policy Safeguarding Practice Equality assessment in ASB cases |
ARR 7 |
Test the vulnerability and reasonable adjustments strategy and policy against the ‘3Rs’ on vulnerable residents – recognise, respond and record. |
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Needs to be completed. |
ARR 8 |
Introduce minimum staff training requirements such as Dementia Friends, and training on customer care, mental health, learning disabilities, and sight and hearing loss. |
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In depth training matrix developed for all roles in the business relevant training in all areas delivered at agreed intervals including mental health, customer care and a wide range of protected characteristics.
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ARR 9 |
Consider a dedicated taskforce for vulnerability. |
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Director led EDI working group in place including business wide colleagues. Group to adopt vulnerability as an additional subject matter. |
Look to the future |
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ARR 10 |
Carry out your own “Resident of the Future” forecast for the next ten years. Draw upon the available information around demographics, both locally and nationally, and identify where you foresee the gaps being. |
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Customer segmentation has given the basis to develop an understanding of the future of customer need. Older People Service (OPS) review has used local demographics and customer input to consider the future service provision. CMS can populate stored info on protected characteristics e.g. on safeguarding forms but open housing cannot do this |
ARR 11 |
Consider the ageing communities specifically in rural and coastal areas, with reference to Professor Whitty's report.[i] |
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OPS review considered the future of this service and the need with customer consultation and national and local demographics. |
ARR 12 |
Devise an action plan for what you need to start putting in place from now onwards to ensure you are ready to meet the needs of your future residents. This should include the anticipatory requirement regarding reasonable adjustments. |
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Action plan will be required following further customer segmentation work but some actions will be taken now such as assessing the need for further new resident visits after initial one. |
Complaint handling |
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ARR 13 |
Raise awareness of the complaints procedure and ensure it is accessible for residents who may face barriers to raising a complaint, as required by the Complaint Handling Code. |
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Website has accessibility options Easy read version as required by Ofsted for YP service plus info in YP guides to individual services Range of route accepted including social media Others able to complain on someone’s behalf with written consent Paper based info offered to customers in OPS who may lack access to digital options Agree customer’s preferred method of communication Service improvement as result of complaint is publicised on website and quarterly report to Exec and to customer |
ARR 14 |
Ensure the complaints policy permits complaints about staff conduct, attitudes and approach. |
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Section 1.5 clarifies complaints can be made about staff. Sections 2.6 and 2.7 confirm how complaints about staff can be made |
ARR 15 |
Establish and enforce a clear process for how complaints about bullying/discrimination will be investigated. |
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Bullying and harrassment policy in place. Complaints made by customers of these behaviours will be investigated and if seen to be proven it will be reviewed in line with the bullying and harassment policy as well as complaints and compensation policy to offer redress. |
ARR 16 |
Contact restriction policies must set out clear timescales, review and appeals process. Where there is single point of contact, this should be applied consistently. |
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Section 3 of the complaints and compensation policy discusses options for vexatious and persistent complainants including single point of contact process.
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ARR 17 |
Calls to be recorded, either a physical recording or a contemporaneous telephone record. |
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Calls to the Hub and Property Services Coordinating Team are recorded. |
Case handlers |
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ARR 18 |
Landlords need to ensure they provide clear explanations; repeat information where needed, including in different formats; offer face-to-face contact as much as possible and a named point of contact; investigate concerns and share the outcome; recognise when things have gone wrong, apologise and explain how these will be addressed; and know when to make appropriate referrals to agencies and whom to signpost to. Underpinning all of these should be a baseline of empathy and respect. |
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Customer contact preferences are recorded where expressed. For cases individuals are the lead and will be the point of contact whenever possible. Action plans are put in place for ASB and Support plans. Complaints policy ensures all areas of dissatisfaction are investigated and responded to. Referral to other agencies in place in relation to safeguarding, DA and ASB management.
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ARR 19 |
Ensure disability or language needs are routinely considered as part of the complaints process and that extra accessibility support, or accessible materials, are offered where appropriate. |
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Where disability or language barriers are known these are recorded and supporting materials are routinely offered for communication. Acknowledgement letter will need to have offer of support added. |
ARR 20 |
Identify where more specific training, guidance or support is needed to fulfil your role. For example, do you feel under confident in having what may be seen as a difficult conversation or delivering bad news? |
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Training discussed and identified with each 121 in line with training matrix. Allocated training budget and active L&D department. Training going into place on suicide ideation and self harm via safeguarding panel. Colleagues encouraged to identify areas for self development and training. Internal workshop on difficult conversation Online suite of training above mandatory required courses
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ARR 21 |
Maintain accurate records of residents’ vulnerabilities and individual circumstances. |
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CMS and Open Housing hold records of disclosed vulnerabilities and contact preferences. |
ARR 22 |
Use mandatory checks, such as annual boiler checks, as a ‘touchpoint’ opportunity to undertake welfare checks with residents. |
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All Westward staff are trained in safeguarding. WPS H&S forum includes discussion on customer engagement including welfare and processes. Offline safeguarding forms for trades teams. CLCs have customer focus for compliance visits and seek to support where any vulnerabilities are identified as an access barrier. Support touch base regularly with customers who will engage and use PEEPs and personal details updates which are created as annual tasks within CMS to ensure data accuracy |
ARR 23 |
Although it is important for landlords to know the vulnerabilities and individual circumstances of its residents and any associated legal duties, the above approach should apply to all residents as, fundamentally, it is about a high standard of customer care and a human-centric approach to service delivery. |
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Legal duties are met in terms of compliance keeping customers safe, Equality Act wherever issues are disclosed and Housing Act in relation to appropriate enforcement action. Customer Service training is delivered to all staff. Safeguarding training is delivered to all staff. The individual household/human-centric approach will be further developed following the customer segmentation work. |
[i] Chief Medical Officer’s Annual Report 2023: Health in an Ageing Society; Professor Chris Whitty