Knowledge and Information Management (KIM) report
Ref |
Ombudsman Recommendation |
Westward Housing Group Response |
RAG rating |
Est Comp Date for Red/Amber |
Owner |
Governance and Culture
An organisation’s culture and its governance significantly impacts how, when, and why, things go wrong. Where there is poor governance, there is often a lack of accountability, unclear roles and responsibilities, as well as a lack of understanding or appreciation of the importance of both information sharing and evidence-based practice. This then informs or exacerbates a culture where KIM is not valued.
This lack of understanding of the importance of good knowledge and information management and an associated cultural acceptance of poor practice adversely affects both service delivery and complaints handling – the correlation between poor knowledge and information management and delay, poor communication, financial uncertainty and poor complaints handling, and the human consequences of that, were evident throughout our casebook. Even where the landlord has fulfilled its obligations, it cannot evidence this, leaving the landlord professionally vulnerable.
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REC1 |
Define the oversight role of governance for knowledge and information management. Governance should seek assurance that the landlord knows its products, services and residents well, and that it uses this data to inform business and financial planning.
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Governance for knowledge and information management consists of the rules we have in place to manage data, the controls we use to identify and manage issues and the reports we produce to monitor data quality. The two key principles of our digital transformation programme are: · data is everyone’s responsibility · decision by data – i.e. using data to inform business and financial planning We have an Enterprise Framework outlining all the systems and solutions we use to enable us to provide our key services. Data quality refers to data that is as accurate and up to date as possible, is relevant, and is held only for as long as necessary aligned to retention policy Westward has a comprehensive and multi-tiered approach to data security. |
GREEN |
Compliant |
Governance Manager and Company Secretary |
REC2 |
Implement a knowledge and information management strategy.
This should include:
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In 2022 we created the Data Quality and Governance Framework, which includes:
· The development and implementation of data analysis tools · Standardisation of integration linked to the Enterprise framework. · Approach to data maturity – Structured and Unstructured data · Data Quality Reporting · Data Retention · Data Security and Compliance |
GREEN |
Compliant |
Assistant Director Business, Improvements and Change |
REC3 |
Benchmark against other organisations’ good practice in knowledge and information management. This should underpin a continuous improvement approach to service delivery. |
We use the Office for National Statistics (ONS) data Maturity Model, and in 2023 achieved Data Maturity Accreditation, Mastering level |
GREEN |
Compliant |
Assistant Director Business, Improvements and Change |
REC4 |
Review safeguarding policies and procedures. To ensure data analysis forms part of a landlord’s proactive activities to satisfy their duties. |
We review safeguarding data and trends in quarterly governance meetings by our Safeguarding Panel. All internal alerts are shared with and scrutinised by the Safeguarding lead. Policy reviews re considered by the Panel and reviewed prior to sign off by our Executive Team. Quarterly updates are provided to the Executive Team with updates via our CEO to the Board. An annual report is provided to the Executive Team and Board. |
GREEN |
Compliant |
Associate Executive Director Support Services |
REC5 |
Train staff on the requirements of the Equality Act 2010 Particularly with relevance to the importance of knowledge and information management as a tool for compliance |
All staff are required to complete e-learning on a 3 yearly basis around the Equality Act. There is a competency test at the end and a required pass mark. Regular information is published on the intranet to remind staff of their responsibilities around equality and diversity |
GREEN |
Compliant |
Assistant Director People and Safety |
REC6 |
Review internal guidance around recording vulnerabilities. Particularly to ensure temporary, as well as permanent, vulnerabilities are recognised, recorded and then removed from records once no longer appropriate. |
This is currently not being considered as part of this project. However, we do have information within CMS for Supported Housing and OPS. There is information within Open Housing, but there is not guarantee this is accurate. Nevertheless, we are working with 3C and Verse One on allowing customers to update their vulnerability through MyAccount more easily with proactive prompts. |
AMBER |
July 2024 |
Customer Insight & Engagement Manager |
Device Key Recording Standards Creating a record serves a number of purposes. Good records assist housing providers to offer efficient and effective services by ensuring that decisions and actions are taken based on good quality information. Clear information is readily available to any member of staff who becomes responsible for a particular matter, easing handovers between staff. Communication with residents is improved when staff are able to access all of the relevant up to date information and get a good understanding of the issue, and what action has been taken (or not taken) and why. If a housing provider is asked to explain what happened, and why, good records will enable it to do so. Poor quality or absent records result in the landlord being unable to answer questions or being unable to provide evidence to support its explanation – this impacts negatively on its credibility and relationships with the requestor. Records should tell the full story of what happened, when, and why. A record should:
Creating a detailed record may take time, but it will save a great deal more time and trouble later when it is easily located and referred to when resolving an issue. Our call for evidence, the LSE research and our casebook clearly identifies which areas. |
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REC7 |
Develop organisational key data recording standard requirements that will ensure good records that support the business and demonstrate compliance with national standards. This should set out the minimum standard to which data must be entered in the various databases owned by the landlord. |
Through the use of Data Logic we have embedded a data dictionary which, where possible references the HACT data standard. The data dictionary defines the requirements for data entry within the Open Housing System. Non-compliance to these rules, results in an alert being produced, which is sent to the Team identified to correct or add the appropriate data. |
GREEN |
Compliant |
Assistant Director Business, Improvements and Change |
REC8 |
Make adherence to the minimum standard for knowledge and information management, part of the service level agreement with third parties. The quality of information sharing should form part of the assessment at procurement stage. |
It seems here that they are asking that we include a standard clause in our data sharing agreements and procurement tenders promising or expecting (depending which way the data is being shared) adherence to the bullet point list shown above. I have contacted the Company Secretary Forum about this to see what everyone else is doing with this, but no-one has even started working on it yet (and some didn't know about it!). One person did recommend that I contact the Housing Ombudsman for advice, which I have done. However, they don't give advice over the phone, so I had to email it to them, and they will apparently get back to me within two weeks. |
AMBER |
10th January 2023 |
Governance Manager and Company Secretary |
REC9 |
Have a clear categorisation system for ATIS/FOI requests. This allows quick identification of whether the question has previously been answered and analysis of which systems require refinement to answer questions in future. |
Currently not applicable to Housing Associations, although ATIS is being introduced as noted in the Consumer Standards consultation (Transparency, Influence and Accountability Standard). We will be preparing for this as part of our gap analysis exercise comparing the current consumer standards with the proposed new standards |
Not Applicable |
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REC10 |
Publish FAQs on websites and keep them updated. This allows for information self-service and reduces resourcing requirements.
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Wherever possible, the most common FAQs from customers are addressed through the website and MyAccount digital self-service portal. This is currently being significantly expanded to provide a transactional driven landing page in MyAccount which is enquiry focused as well as a Chat Bot which will be based on the 35 most common customer questions (to continuously review and grow) and respond with web information plus a link to more detailed information and a web form or transactional web service. Customers are consulted on these priorities as well as customer enabling advisors providing data sourced input. |
AMBER |
Dec 23 – Mar 24 |
Communications Manager |
Ensure appropriate systems are in place. Landlords also need to have contingency plans in place in the event of unforeseen critical data incidents, such as cyber-attacks. Any landlord could find itself a victim of one. Landlords should consider how systems and information can be safeguarded in such an event, with planned workarounds to minimise the disruption to service delivery. Local authority landlords who have effective knowledge and information systems in place typically also have efficient processes for dealing with Freedom of Information (FOI) requests and recognise that being transparent by publishing their requests and frequently asked questions reduces the number of further FOI requests. Housing associations who already manage their knowledge and information management well will be better equipped to deal with the forthcoming Access to Information Scheme. The research conducted by London School of Economics overwhelmingly shows that organised and efficient systems are key to managing future ATIS requests. The upfront cost of these digital tools and systems reduces the overall cost of responding. |
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REC11 |
Review existing databases for capability and capacity to record those key data requirements. To ensure databases are capable of adequately capturing information about residents – e.g. vulnerabilities. To ensure databases are capable of adequately capturing information about homes – e.g. repairs and stock condition. |
This is all held within the Open Housing management system which has a single database which is used by a series of modules within the system, including:
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GREEN |
Compliant |
Business Systems Manager |
REC12 |
Train staff on using systems. Including minimum data standards, performance measures and quality assurance processes
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We have training material available in different formats for the different systems in operation – Open Housing and CMS. In addition, we have an induction process to ensure organisational information is communicated as well as information on processes relevant to the role – the induction is moving to WMB for ease of monitoring There are agreed skills matrixes for compulsory, regulation and development learning identified for all roles We are in the process of increasing our online course offering on specific business processes. The system we have (WMB) can assign course content based on job role and also set repeat frequency. We are currently investigating the induction process and access to training to understand the current barriers and improvements that are required. |
AMBER |
March 24 |
Business Systems Manager /Assistant Director People and Safety |
REC13 |
Ensure databases are easy to interrogate, and that the data can be extracted and used. Staff should be able to easily access the information they require. This is essential for evidence-based practice and informed decision-making. Where systems can be interrogated effectively, this produces crucial insight regarding patterns, themes and potential shortfalls. |
We have a dedicated BI Team who use a variety of system query tools to extract and analyse data for reporting and performance related information, using visualisation tool to enable effective decision making |
GREEN |
Compliant |
Assistant Director Business, Improvements and Change |
REC14 |
Schedule appropriate sensitive information reviews Resident information and personal characteristics change on a regular basis. Records should be appropriately reviewed to ensure a landlord continues to know its residents – disability or illness, financial difficulties and family composition.
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Open Housing is updated as changes are provided to us. The Customer Sentiment Project will consider solutions for how customers can better update their own personal data through MyAccount, the web portal project has currently developed the ability to display vulnerabilities and person attributes which customers can then submit a form to updated, we will automate these change requests and create proactive ‘nudge’ solutions to encourage customers to review and update such details. With regard to CMS we will review customer data annually (as well as between times) and system will be able to report on reviews being completed |
AMBER |
July 2024 |
Customer Insight & Engagement Manager/Associate Executive Director Support Services/Communications Manager |
Mergers and other structural changes Landlords’ governance should be effective in identifying shortfalls before they escalate. Our call for evidence highlighted data is being lost or made inaccessible when stock is transferred, contracts with managing agents are ended, service provision is brought back in house or a merger happens. A merger or other structural change is an opportunity to carry out due diligence on the systems, their compatibility and conduct risk assessments. We have seen issues where landlords referred to systems not ‘speaking’ to each other and legacy data being inaccessible. One recently merged landlord has identified that while all staff could set tasks on the system, only certain staff could then see those tasks and action them – staff who did not have the appropriate permissions were unaware of work required. These issues should be identified with action plans to address them, long before a planned structural change happens, not subsequently. We have found from our casebook and engagement with landlords that structural change/merging is not always given sufficient planning and testing time, meaning any irregularities or issues are not identified until the point the change has occurred, by which time, data may be irretrievably lost or corrupted. We have also seen merging landlords relying on moving to a centralised database as the solution for information management issues. However, our casework has shown that the creation of a central database cannot be relied upon without addressing any cultural and training issues as the solution. Where merging landlords/organisations already have existing KIM shortfalls, there is a significant risk of those problems remaining unresolved or getting lost in a bigger organisation or becoming even bigger. |
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REC15 |
Stress test systems prior to change. To identify whether they can ‘talk’ to each other; data can be securely transferred, and staff from each landlord can access the data they need. |
Currently Westward Board is not seeking a merger or any structural changes however if we were to consider a merger all these points would be taken into account |
Not Applicable |
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REC16 |
Undertake a risk assessment regarding knowledge and information shortfalls before the change. This should be a living document with clear risks and mitigations documented, incorporating a review cycle and emerging risk identification. This document should continue beyond the date of change. |
Review whether this needs to be included in the Operational Risks maps as they are reviewed every 6 months (in respect of any changes within the business that result in presenting a risk). |
AMBER |
31 March 2024 |
Governance Manager and Company Secretary |
REC17 |
Proactively investigate incoming datasets during mergers as part of due diligence. Identify gaps in the knowledge of incoming stock and residents, and work to fill those gaps. |
Currently Westward Board is not seeking a merger or any structural changes however if we were to consider a merger all these points would be taken into account |
Not Applicable |
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REC18 |
Establish clear data exception reporting processes. This allows the new organisation to identify issues post-change quickly. |
Within data logic we are developing exception reports and have existing spreadsheets which use CSV files to identify exceptions. However, this is an ongoing process as part of the data quality and governance project. |
AMBER |
April 2024 |
Assistant Director Business, Improvements and Change |
Repairs In two-thirds of the cases we upheld about repairs, poor records or information management played a pivotal part in the maladministration. The majority of complaint handlers who responded to our call for evidence said that poor records and systems were undermining their ability to respond effectively to residents, with these problems most acute in repair complaints. When residents are not responded to, are passed to multiple departments, their repair requests are not logged, their vulnerabilities not recorded and considered, and they are blamed for missed appointments, it is easy to see why they would become frustrated and conclude they are not treated as important. It is also why they then make complaints about the service. |
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REC19 |
Set out clear requirements of operatives before they are allowed to record an appointment as missed. This should include ensuring that the appointment was notified to the resident, it was made at a time they could attend, checking that any contact requests were adhered to, guidance on what level of contact (e.g., Two door knocks, calling the resident) etc.
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All repairs have bookable appointments via the web portal My Account or through contacting the Customer Contact Centre. However, at present, through My Account, these are only indicated as preferable slots (e.g. Tuesday PMs) and not an actual available appointment.
As part of the Property Services Improvement Programme and through the development of our webservices, later this year in 2023 or early 2024 we will be offering actual appointment slots for AM, PM and avoid school run, this is as now, will be confirmed through a text message, the customer will have the ability to amend their appointment, on-line up to 48hrs prior to the visit.
In addition, all operatives/Engineers will phone ahead prior to the visit to notify they are on their way, and to check availability, if the resident is out, then a card will be left, to rebook the job.
We also store information about access for our customers such as knock loudly or slow to answer door. |
AMBER |
May 2024 |
Associate Executive Director (Property) |
REC20 |
Conduct wastage analysis on missed appointments. Use the insight generated by accurate records of missed appointments to identify efficiencies and action plans, including whether a broader time range of appointments would be of benefit. |
As above we are currently enhancing this process and will offer a better customer experience through our contact centre and on-line for all appointment booking |
AMBER |
May 2024 |
Associate Executive Director (Property) |
REC21 |
Implement an automated appointment reminder system. This could take the form of text messages the day before. |
This is already in place, for all appointments with our own workforce
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AMBER |
January 2024 |
Associate Executive Director (Property) |