Self Assessment Form

Appendix B – Self-Assessment Form

We carry out an annual review of our complaints process against the Housing Ombudsman Code. This is to ensure our complaint handling remains in line with requirements, and that we are providing the best possible service for residents.

This self-assessment form is 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.

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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	Talk2Us process for expressions of dissatisfaction with a 48 hour response time.
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	We deal with negative feedback and expressions of dissatisfaction as complaints of needed and will log as formal where necessary
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	We would log as stage 1 formal complaint as a follow on from Talk2Us
1.7	A landlord must accept a complaint unless there is a valid reason not to do so.	Yes	Policy will contain exemptions, which will be stated within policy document.

Section 1 - Definition of a complaint

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	As above
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	Included in the new policy.

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	This is done at the point of receiving any negative feedback from our residents, but will still be logged on the correct manner
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	We receive feedback via our Rant and Rave platform and any negative feedback is followed up with a contact and this will be explained at that point.

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	Residents can complain via website, social media, face to face, phone call, written letter and text.
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	Policy and procedure is on our website and various formats are available on request.
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	As above
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	Equality Impact assessment completed
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.	No	We have a link on our current website to request the new policy and aim to advertise this in the future following migration to MCC website.

2.7	Landlords must provide residents with contact information for the Ombudsman as part of its regular correspondence with residents.	Yes	Always added to response following complaint.
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	Info always included within correspondence sent and advertised on website.

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

We can respond however tenant has requested, but case or Talk2Us contact must be updated on central complaints data base .

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 Experience Manager and Customer Experience Officer lead on complaints.
3.2	…the complaint handler appointed must have appropriate complaint handling skills and no conflicts of interest.	Yes

Section 3 - Complaint handling personnel Mandatory ‘must’ requirements

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 resident shave access to staff at all levels to facilitate quick resolution of complaint shave the authority and autonomy to act to resolve disputes quickly and fairly.	Yes	All Managers and senior team members will have had the appropriate training and autonomy to resolve disputes quickly.

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	All Talk2Us processes and formal complaints cases are logged on our QL system and updated accordingly, within specified time scales.

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	Automated response sent out via our system when formal complaint received.
4.6	A complaint investigation must be conducted in an impartial manner.	Yes	This will always be investigated by another employee or Manager
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	This is in the complaints policy
4.11	Landlords must adhere to any reasonable arrangements agreed with residents in terms of frequency and method of communication	Yes	They will respond as suitable for the tnt as possible
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,	This will be investigated by line Manager and decision discussed
4.13	A landlord must include in its complaints policy its timescales for a resident to request escalation of a complaint	Yes	This is within the policy and 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	All complaints are dealt with in line with complaints policy

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 recorded within our QL system and reported on if needed
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	This would be part of our ASB policy

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	As above
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	We will always try and deal with complaints or dissatisfaction at Talk2Us stage and if unable to this will be directed to our formal complaints policy.
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	We will always give residents the opportunity to give authority to a 3rd party
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	As above

4.9	Communication with the resident should not generally identify individual members of staff or contractors.	Yes	This will always be in line with the GDPR policy
4.10	Landlords should keep residents regularly updated about the progress of the investigation.	Yes	We will always aim to keep residents updated where necessary
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	This data is collected via a post closure 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	Support given where needed and training available on request
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	We have contact alerts used for the benefit of residents and staff safety.

Section 5 - Complaint 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

This is part of our policy and if not reached we will add an additional 10 working days extension that the resident will be notified of

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 would only respond formally when full investigations carried out.

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

This will be drafted in to a response to the resident and they will be given 28 working days to respond if unhappy

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

All included in to response sent

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	This is part of our current 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	This will always be covered within our response to the resident
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	As part of our policy a complaint cannot go straight to stage 2

5.12

The person considering the complaint at stage two, must not be the same person that considered the complaint at stage one.

Yes

Stage 2 will always be dealt with at a higher level of leadership

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

Our policy is currently at 10 working days in line with the Manchester City Council policy

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

This is completed within our response and residents are always informed of next stages and appeals process.

Stage 3

Code section	Code requirement	Comply: Yes/No	Evidence, commentary and any 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.	Yes	Our complaints procedure has formal stage 1 and 2 and failing this the complainant is directed to a 3rd party such as the Ombudsman.

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

Yes

As above

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	Communication will always be provided and explained to the resident
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	Details of the Housing Ombudsman website is included in to complaints responses
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	Complaints cases can be linked or re-opened, this will be done during investigation stage.
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 would always add any additional info regarding previous complaint to case – but any new complaints would be added as new case for reporting purposes

Best practice ‘should’ requirements Stage 1

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	This is part of our current policy and procedure
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	We would always communicate with the resident and if unhappy they will be directed to a 3rd party for additional support.

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.	NA	No third stage
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.	NA

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	Collect data from complaints cases and discuss learning from following this.
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	We will collate issues and resolutions and publish on website and annual report. Also training to reflect difficult conversations in line with what we can and cannot offer as a result of service failure.
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	Any long term resolution would be referred to the relevant department or Manager to follow up and complete then update relevant systems
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	This would be calculated at the time of investigating the complaint resident notified and amount agreed.

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

Lessons Learnt investigated by Senior Leadership 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

Any legal cases would be referred and dealt with by our legal disrepair Team and solicitors

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

‘You say we did’ page on our website and newsletters to staff and Residents.

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

Housing Advisory Board Members will discuss complaints outcomes, responses, performance and lessons learnt.

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

As above and our figures and KPI’s will be fed into the performance reviews collated by the Manchester City Council Central complaints Team.

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

As above;

Lessons Learnt investigated by Senior Leadership Team

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

Customer Experience training with all staff completed, issues identified such as culture, communication, workload and resident feedback all addressed.

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
8.2	Landlords must also carry out a self-assessment following a significant restructure and/or change in procedures.	Yes
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	We can send published document on request of information.