Read the text of this document (33 pages)
Housing
Complaints
Performance and
Service
Improvement
Report
June 2024
Appendix 1
Page | 1
Contents
Page
1. Introduction 2
2. Summary of Self-Assessment against Housing Ombudsman
Complaint Handling Code as last revised 17 April 2024
2
3. Analysis of Complaint Handling Performance 1st April 2023 to 31st
March 2024
4
4. Findings of non-compliance with the Code 1st April 2023 to 31st
March 2024
4
5. Learning from Complaints and Service Improvement linked to
complaints management
5
Appendix A
Hillingdon Council Self-Assessment Form: Housing Ombudsman
Complaint Handling Code – Completed June 2024
Appendix 1
Page | 2
1. Introduction
Hillingdon Council is required to comply with the Housing Ombudsman’s Complaint
Handling Code and to demonstrate compliance on at least an annual basis. This
document is our annual complaints performance and service improvement report,
which forms part of our Annual Submission to the Housing Ombudsman. The report
includes:
• Our latest self-assessment of compliance against the requirements of the
Housing Ombudsman’s Complaint Handling Code.
• An analysis of complaint handling performance in the year from 1st April 2023
to 31st March 2024.
• Findings of non-compliance with the Code by the Ombudsman between April
2023 and 2024.
• Learning from Complaints and Service improvements.
The annual complaints performance and service improvement report is reported
annually to a Senior Officer level Landlord Board, Corporate Management Team, the
two Cabinet Leads with responsibility for Housing, and Residents’ Services Select
Committee. The report is shared for feedback with our Tenant Complaints Special
Interest Group and is published on the council's website at Complaints - Hillingdon
Council. Information from the report is also shared more widely with tenants. Moving
forward, from the next submission year 2025/26, the dates of these meetings will be
aligned to maximise the potential for review and examination prior to final submission
to the Housing Ombudsman Service.
2. Summary of Self-Assessment against Housing
Ombudsman Complaint Handling Code as last revised
17 April 2024
A completed self-assessment form is included at appendix A.
Section1: Definition of a complaint - Compliant
In general terms a complaint can be considered as: “an expression of dissatisfaction,
however made, about the standard of service, actions or lack of action by the council,
its own staff, or those acting on its behalf, affecting an individual or group of
individuals.”
Section 2: Exclusions - Compliant
● although a complaint can be submitted against Council policy, please be aware
that Council policy cannot be overturned through the complaint process as this
can only be done through the statutory decision-making procedure;
● we will not deal with issues through the complaint procedure where a claim has
been made in a court such as a disrepair claim; and
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● issues relating to employment or application for employment with the Council
cannot be addressed through the complaint procedure.
Section 3: Accessibility and Awareness - Compliant
Complaints can be made quickly and easily 24 hours a day, seven days a week via
our website at www.hillingdon.gov.uk/complaints. If an adjustment is needed
complainants are asked to call the complaint team.
Section 4: Complaint Handling Staff - Compliant
All staff within the team are experienced and fully trained to deal with complaints and
any adjustments that are required. In addition, they have been provided with
additional training by a member of staff from the Local Government and Social Care
Ombudsman on 16 May 2024.
Section 5: The Complaint Handling Process - Compliant
The complaint procedure that applies to the Housing Ombudsman Service is the
Corporate complaints procedure which was revised on 1 April 2024 to fully align with
the Complaint Handling Codes by the Housing Ombudsman Service and the Local
Government and Social Care Ombudsman. Our procedure:
● allows managers to address issues of unsatisfactory service and seek
improvements in service delivery;
● ensures that customers are treated fairly and consistently;
● ensures that a proper and adequate investigation takes place before any action
is taken;
● requests for reasonable adjustments will be considered in line with the Equality
Act 2010 and appropriate training is provided for staff; and
● safeguards the integrity and good reputation of the Council.
Section 6: Complaints Stages - Compliant
As a result of the Complaint Handling Codes, we now have a Service Request step
and 2 formal complaint stages, after which the complainant can apply to the
Ombudsman.
Section 7: Putting things right - Compliant
Where we have identified injustice or hardship suffered, we will always try to put the
complainant back to the position they would have enjoyed before the situation went
wrong. Types of redress include:
● an apology;
● providing the service that should have been received at first;
● taking action or making a decision that should have been done before;
● reconsidering an incorrect decision;
● improving procedures so that similar problems do not occur again; and
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● if after an investigation by Council staff or the Ombudsman, it is concluded that
as a result of maladministration there is no practical action that would provide
a full and appropriate remedy or if the complainant has sustained loss or
suffering, financial compensation may be the most appropriate approach.
Section 8: Self-assessment reporting and compliance - Compliant
Our self-assessment will be published on the complaint page www.hillingdon.gov.uk
Section 9: Scrutiny & Oversight: continuous learning and improvement – one
area of non-compliance regarding specific wording within relevant job description.
Full compliance to be achieved by December 2024.
The Member Responsible for Complaints (MRC) will be a role performed by the
Corporate Resources & Infrastructure Select Committee.
3. Analysis of Complaint Handling Performance 1st April
2023 to 31st March 2024
Our annual reporting cycle for complaints includes a corporate complaints report to
the Corporate Resources and Infrastructure Select Committee in the Autumn. From
the 2024/25 reporting cycle an earlier report related specifically to housing services
will be considered by Residents’ Services Select Committee in advance of the
annual June submission date for the Housing Ombudsman.
In line with other housing providers complaints, a high proportion of complaints are
focused on housing repairs. Reports in this area track data monthly and are actively
reviewed and monitored by Landlord Board.
Between April 2023 and March 2024, a total of 133 complaints regarding housing
repairs were received, 101 stage 1 and 32 stage 2 complaints. There were 47
complaints regarding repairs upheld and 28 partially upheld. There were 22
complaints that were mainly about damp and mould.
In the first two months of 2024/25 there have been 86 complaints, 75 stage 1 and 11
stage 2. This is an average of 43 housing repairs complaints per month compared to
an average of 11 in 2023/24. This follows changes made to our Corporate
Complaints Policy and Procedure (see below). In the first two months of this year, 12
complaints have been upheld and a further 29 partially upheld. There have been 9
complaints that are mainly about damp and mould.
4. Findings of non-compliance with the Code 1st April 2023
to 31st March 2024
In one case (202210650) the Ombudsman expressed concern at the number of
Stages that were contained within the Corporate complaints procedure, our
application of escalation to the Ombudsman from Stage 1 and that in a few cases we
had incorrectly signposted complainants to the wrong Ombudsman. The Council’s
Appendix 1
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Corporate complaints procedure has been revised and now meets both Ombudsman
Complaint Handling Code.
5. Learning from Complaints and Service improvements
linked to complaints management
Continuous improvement is seen as a cornerstone of how we operate at Hillingdon
Council and learning from complaints is a central part of this. The receipt of any
complaint provides Hillingdon with valuable feedback, an opportunity to learn from
what has happened, to make adjustments so that it does not happen again and by
doing so improve the service we provide our residents. To this end, we have paid for
a bespoke training course on investigating complaints, the processes to follow,
appropriate redress to offer but also mechanisms they use to identify issues and
make recommendations for change/service improvement. Officers found this course
extremely helpful.
The Council has invested in new software for complaint handling. Since July 2023, we
have been using a new complaint portal to process and manage complaints. The new
portal has provided us with the opportunity to better understand feedback we are
receiving from our residents through the “Report It” data we receive, complaints,
compliments and Members Enquiries. This will enable improved a nalysis to better
understand the specific issues that residents are raising through these mediums and
identify trends whi ch in turn will help us to address systemic problems at an early
stage, without the need to escalate to the formal complaint stages or to Members. It is
envisaged that this analysis could be used to identify gaps in staff knowledge, skills or
processes and then develop training programs that could be tailored to meet a specific
need.
Going forward, a Customer Experience Contact report covering both service request
and complaint analysis will be developed, with the aim of identifying issues before they
escalate into complaints and by doing so reduce the burden on our resources and a
culture where service improvement is seen as the norm.
Our Corporate Complaint Handling Policy and Procedure has also been updated. The
adoption of the same Complaint Handling Code by both the Housing Ombudsman and
the Local Government and Social Care Ombudsman has been helpful in providing a
consistent basis for housing and corporate complaint handling. There are now only 2
stages to the process and there are no longer ‘informal complaints’, just complaints
and service requests. This has resulted in an increase in complaints activity providing
richer feedback to inform service improvement.
The Housing Management Service has comprehensively reviewed its approach to
learning from complaints and earlier this year rolled out a revised approach to
monitoring complaints and evidencing learning outcomes. Relevant service managers
and the complaints manager have been involved in developing and implementing the
approach. The stated objective of the approach is ‘to enhance the council’s approach
to handling an d monitoring complaints in a fair and transparen t manner, ensuring
continuous improvement through identified learning outcomes’. The process covers
extracting data from our new system, GOSS; organising this into a structured
spreadsheet and filtering to share with relevant service managers. An online learning
Appendix 1
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log form has been created for service managers to complete to capture learning
outcomes identified and any changes to services, policies or procedures identified as
a result.
Collectively housing managers and Landlord Board collate and review the Learning
Outcome forms and identify common themes and areas for improvement. These are
then prioritised and necessary changes to services, policies and procedures are
implemented. The effectiveness of changes is monitored and reported on.
This structured approach ensures that complaint handling is systematic, with clear
steps for extracting, filtering, and sharing data. By requiring service managers to
complete the Complaints Learning Outcome form, the process ensures that each
complaint is thoroughly reviewed and leads to actionable improvements. Continuous
monitoring and reporting uphold transparency and demonstrate the council’s
commitment to service excellence.
The Repairs and Voids Team keep a learning log from complaints and quarterly
meetings are held to review and track changes to processes and procedures. There
is a commitment to continuous learning and several changes have been made and
embedded into service provision.
Appendix 1
Appendix A: Hillingdon Council Self-Assessment Form: Housing Ombudsman Complaint
Handling Code – Completed June 2024
Section 1: Definition of a complaint
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
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 landlord, its own staff, or those
acting on its behalf, affecting a
resident or group of residents.’
Yes
The Corporate Complaints
Procedure can be downloaded from
this page
Complaints - Hillingdon Council
This definition is included in Section
1.
This precise wording is used
in Hillingdon Council’s
Corporate Complaints Policy
and Procedure
.
1.3
A resident does not have to use the word
‘complaint’ for it to be treated as such.
Whenever a resident expresses
dissatisfaction landlords must give them
the choice to make complaint. A complaint
that is submitted via a third party or
representative must be handled in line with
the landlord’s complaints policy.
Yes
Presentations were delivered
virtually to all staff involved in the
handling of complaints that the word
“complaint” did not need to be used
for us to progress by way of a
complaint but where dissatisfaction
is expressed it needs to be brought
to the attention of the complaint
team for advice.
1.4
Landlords must recognise the difference
between a service request and a
complaint. This must be set out in their
complaints policy. A service request is a
request from a resident to the landlord
requiring action to be taken to put
something right. Service requests are not
Yes
The definition of a Service Request
has been included in the Council’s
Corporate complaints procedure.
They are logged, monitored and
processed in the same way as
complaints and Officers in the
complaints team have oversight on
whether a complaint has been
The Council makes a
distinction between a service
request and a complaint.
Appendix 1
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complaints, but must be recorded,
monitored and reviewed regularly.
responded to or not. We keep
records of Service Requests
submitted and their outcome.
1.5
A complaint must be raised when the
resident expresses dissatisfaction with the
response to their service request, even if
the handling of the service request remains
ongoing. Landlords must not stop their
efforts to address the service request if the
resident complains.
Yes
This is part of the Council’s
Corporate complaints procedure
which can be accessed at
www.hillingdon.gov.uk/complaints
1.6
An expression of dissatisfaction with
services made through a survey is not
defined as a complaint, though wherever
possible, the person completing the survey
should be made aware of how they can
pursue a complaint if they wish to. Where
landlords ask for wider feedback about
their services, they also must provide
details of how residents can complain.
Yes
We will generally advise someone
responding to a survey where and
how they can submit a complaint.
The Council recognises that
survey responses may
contain a ‘complaint’. We
ensure that appropriate
signposting to the complaints
service takes place, and we
raise awareness of how to
complain while conducting
surveys.
Appendix 1
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Section 2: Exclusions
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
2.1
Landlords must accept a complaint unless
there is a valid reason not to do so. If
landlords decide not to accept a complaint,
they must be able to evidence their
reasoning. Each complaint must be
considered on its own merits
Yes
This is included in the Council’s
Corporate complaints procedure in
which we set out what complaints
we can and cannot progress and this
is also set out on the complaint web
page:
www.hillingdon.gov.uk/complaints
The Policy and Procedure
includes the following text:
“If we consider that a
complainant is unreasonable
or unreasonably persistent, we
will refer the matter to a senior
manager, who will consider
whether further investigation
of the complaint will be carried
out.”
2.2
A complaints policy must set out the
circumstances in which a matter will not be
considered as a complaint or escalated,
and these circumstances must be fair and
reasonable to residents. Acceptable
exclusions include:
• The issue giving rise to the complaint
occurred over twelve months ago.
• Legal proceedings have started. This is
defined as details of the claim, such as
the Claim Form and Particulars of
Claim, having been filed at court.
• Matters that have previously been
considered under the complaints
policy.
Yes
This is included in the Corporate
complaints procedure and contained
within the complaint page:
www.hillingdon.gov.uk/complaints
The Complaints Policy
includes the following text:
“We will not deal with issues
through the complaint
procedure where a claim has
been made in a court such as
a disrepair claim”
Appendix 1
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2.3
Landlords must accept complaints referred
to them within 12 months of the issue
occurring or the resident becoming aware
of the issue, unless they are excluded on
other grounds. Landlords must consider
whether to apply discretion to accept
complaints made outside this time limit
where there are good reasons to do so.
Yes This is contained within the
Corporate complaints procedure
It states within our policy that
“Anyone who uses our services
and is dissatisfied with the
standard of service we have
provided or our lack of action.
The Council will also accept
complaints by an advocate on
behalf of a resident, with
appropriate consent. However,
any complaint should be made
within 12 months of the
issue/incident complained of.”
2.4
If a landlord decides not to accept a
complaint, an 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. If
the Ombudsman does not agree that the
exclusion has been fairly applied, the
Ombudsman may tell the landlord to take
on the complaint.
Yes Included within the Corporate
complaint's procedure
In practice a letter is sent if a
complaint is not accepted and
the policy states
“If we do not intend to
progress your complaint, we
will inform you of this in
writing, tell you why we will do
this and give you the contact
details of the Ombudsman to
whom you may escalate your
complaint to for independent
review.”
2.5
Landlords must not take a blanket
approach to excluding complaints; they
must consider the individual circumstances
of each complaint.
Yes Each complaint received is
considered on its own merit
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Appendix 1
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Section 3: Accessibility and Awareness
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
3.1
Landlords must make it easy for residents
to complain by providing different channels
through which they can make a complaint.
Landlords must consider their duties under
the Equality Act 2010 and anticipate the
needs and reasonable adjustments of
residents who may need to access the
complaints process.
Yes This is set out within the Corporate
complaints procedure
Complaints can be made in
person, by telephone, in
writing, via our website or
email. In addition, the policy
document also states that “If
you need an adjustment to be
made, please call the
complaint team.”
3.2
Residents must be able to raise their
complaints in any way and with any
member of staff. All staff must be aware of
the complaints process and be able to
pass details of the complaint to the
appropriate person within the landlord.
Yes
Information is available on
Complaints and our handling of it is
available on the Staff portal, setting
out what they need to do and who to
contact
Handling council complaints
(sharepoint.com)
3.3
High volumes of complaints must not be
seen as a negative, as they can be
indicative of a well-publicised and
accessible complaints process. Low
complaint volumes are potentially a sign
that residents are unable to complain.
Yes
Since the introduction of the new
Complaint Handling code and the
removal of Informal complaint stage,
volumes of formal complaints have
risen significantly.
3.4
Landlords must make their complaint
policy available in a clear and accessible
format for all residents. This will detail the
two-stage process, what will happen at
each stage, and the timeframes for
Yes
Published on our website and it sets
out the 2 Stage Corporate
complaints procedure –
www.hillingdon.gov.uk/complaints
Appendix 1
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responding. The policy must also be
published on the landlord’s website.
3.5
The policy must explain how the landlord
will publicise details of the complaints
policy, including information about the
Ombudsman and this Code.
Yes
The Corporate complaints policy is
published on our website and
recently advertised in our E-
newsletter in May 2024. The policy
contains information about both
Ombudsman and the Codes are
published on our web page.
3.6
Landlords must 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.
Yes Corporate complaints procedure
sets this out
The policy states that “The
Council will also accept
complaints by an advocate on
behalf of a resident, with
appropriate consent.”
3.7
Landlords must provide residents with
information on their right to access the
Ombudsman service and how the
individual can engage with the
Ombudsman about their complaint.
Yes Included within the Corporate
complaint's procedure
Appendix 1
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Section 4: Complaint Handling Staff
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
4.1
Landlords must have a person or team
assigned to take responsibility for
complaint handling, including liaison with
the Ombudsman and ensuring complaints
are reported to the governing body (or
equivalent). This Code will refer to that
person or team as the ‘complaints officer’.
This role may be in addition to other
duties.
Yes
There is a dedicated Complaint and
Members Enquiry Team process all
complaints and the annual complaint
report is put before the Finance and
Corporate Services Select
Committee for scrutiny.
We have a corporate
complaint handling team and a
complaint manager
responsible for processing
complaints and providing
advice and guidance to staff.
An annual complaint report is
provided for the Finance and
Corporate Services Select
Committee. The report
contains information about
complaints, compliments and
Members Enquiries submitted.
From 2024/25 scrutiny will
also be provided prior to the
annual submission to the
Housing Ombudsman Service
by Residents Services Select
Committee which has a clear
focus on the Landlord Service.
4.2
The complaints officer must have access
to staff at all levels to facilitate the prompt
resolution of complaints. They must also
have the authority and autonomy to act to
resolve disputes promptly and fairly.
Yes
A centralised complaint team is
responsible for engaging with staff at
all levels and where there are
issues, they have access to senior
managers for support and resolution.
We have a Corporate
complaint handling team that
is responsible for processing
complaints, providing advice
and guidance, delivering
training sessions for officers
across the Council and in
attending management
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meetings to provide
information and advice on the
handling of complaints.
4.3
Landlords are expected to prioritise
complaint handling and a culture of
learning from complaints. All relevant staff
must be suitably trained in the importance
of complaint handling. It is important that
complaints are seen as a core service and
must be resourced to handle complaints
effectively
Yes
A centralised complaint team is in
place, where staff have been trained
to process complaints, with most
staff having worked in the team for
over 8 years. The complaint portal
has categories to capture learning,
and this is reported on in the annual
complaint report, which can be
accessed at
www.hillingdon.gov.uk/complaints
Section 5: The Complaint Handling Process
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
5.1
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.
Yes
Corporate complaints procedure is
the policy that we use, and it can be
accessed at
www.hillingdon.gov.uk/complaints
5.2
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.
Yes
The Council’s Corporate complaint
procedure complies with the
requirements set out in the
Complaint Handling Codes namely
a 2 Stage complaint process.
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5.3
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.
Yes
The Council’s Corporate complaint
procedure sets out our 2 Stage
complaint process.
5.4
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.
Yes
The Corporate complaint procedure
states that we will progress by way
of a complaint expressions of
dissatisfaction in relation to “or
those acting on its behalf”
through our own procedure.
5.5
Landlords are responsible for ensuring that
any third parties handle complaints in line
with the Code.
Yes
We will process in accordance with
the Corporate complaints
procedure.
5.6
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.
Yes Within the acknowledgment we
send to a complainant
We will acknowledge receipt
within 5 working days and
inform the complainant of the
reference number, who will be
investigating, when they can
expect a response to be sent
to them, etc. If anything is
unclear, we will always ask for
clarification before beginning
the investigation.
5.7
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.
Yes This will be set out in the
acknowledgment
We will acknowledge receipt
within 5 working days and
inform the complainant of the
reference number, who will be
investigating, when they can
expect a response to be sent
to them, etc. If anything is
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unclear, we will always ask for
clarification before beginning
the investigation.
5.8
At each stage of the complaints process,
complaint handlers must:
1. deal with complaints on their
merits, act independently, and have
an open mind;
2. give the resident a fair chance to set
out their position;
3. take measures to address any actual or
perceived conflict of interest; and
4. consider all relevant information and
evidence carefully.
Yes
This is set out within the policy
statement in the Corporate
complaints procedure
5.9
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.
Yes
In our letter of acknowledgment, we
will advise complainants the date
we aim to respond by and if this is
not going to be met, we will always
contact them again to advise them if
more time is needed.
5.10
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.
Yes
From April 2024 we keep a log of
any reasonable adjustments
requested which is held on
Sharepoint
5.11
Landlords must not refuse to escalate a
complaint through all stages of the
complaints procedure unless it has valid
Yes Set out in the Corporate complaints
procedure
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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.
5.12
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.
Yes
All complaint data is stored on our
complaint portal called GOSS
including pictures, surveys, reports,
etc
5.13
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.
Yes
Our aim is to resolve a complaint,
where we can, either at a Service
Request or formal complaint stages.
This is set out in the Corporate
complaint procedure
5.14
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.
Yes
We have our “Unreasonable or
Unreasonably Persistent
complainant” policy which can be
accessed at
www.hillingdon.gov.uk/complaints
Where restrictions are put in
place this information is held
on the Council’s Restricted
Persons Register
5.15
Any restrictions placed on contact due to
unacceptable behaviour must be
proportionate and demonstrate regard for
the provisions of the Equality Act 2010.
Yes
We are required to follow the
“Unreasonable or Unreasonably
Persistent Complainants” Policy
This is set out in the
‘Unreasonable or
Unreasonably Persistent
Complainants Policy” and
where someone is placed on
the Restricted Persons
Register (RPR), they are
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informed of the reason, how
long they are on the RPR, how
they can appeal it, etc. The
Corporate Complaints Policy
and Procedure review process
will include consideration of
specific reference to the
Equality Act 2010.
Appendix 1
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Section 6: Complaints Stages
Stage 1
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
6.1
Landlords must have processes in place to
consider which complaints can be
responded to as early as possible, and
which require further investigation.
Landlords must consider factors such as
the complexity of the complaint and
whether the resident is vulnerable or at
risk. Most stage 1 complaints can be
resolved promptly, and an explanation,
apology or resolution provided to the
resident.
Yes Corporate complaints procedure
sets this out
This is set out in the Council’s
Corporate Complaints
Procedure
6.2
Complaints must be acknowledged,
defined and logged at stage 1 of the
complaint's procedure within five working
days of the complaint being received.
Yes
Corporate complaints procedure
sets this out
6.3
Landlords must issue a full response to
stage 1 complaints within 10 working
days of the complaint being
acknowledged.
Yes
Corporate complaints procedure
sets this out
6.4
Landlords must decide whether an
extension to this timescale is needed when
considering the complexity of the complaint
and then inform the resident of the
expected timescale for response. Any
extension must be no more than 10
working days without good reason, and the
Yes
Corporate complaints procedure
sets this out
Appendix 1
Page | 14
reason(s) must be clearly explained to the
resident.
6.5
When an organisation informs a resident
about an extension to these timescales,
they must be provided with the contact
details of the Ombudsman.
Yes
Staff in the complaint handling team
ensure that an extension
communication provides the
Housing Ombudsman contact
details.
6.6
A complaint response must be provided 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 promptly
with appropriate updates provided to the
resident.
Yes
The complaint response will set out
the actions we have taken or if they
are due to be taken, when that will
happen. Services have in place
procedures to follow up on
outstanding actions
6.7
Landlords must address all points raised in
the complaint definition and provide clear
reasons for any decisions, referencing the
relevant policy, law and good practice
where appropriate.
Yes This is set out in the Corporate
complaints procedure
6.8
Where residents raise additional
complaints during the investigation, these
must be incorporated into the stage 1
response if they are related, and the stage
1 response has not been issued. Where
the stage 1 response has been issued, the
new issues are unrelated to the issues
already being investigated or it would
unreasonably delay the response, the new
issues must be logged as a new
complaint.
Yes
Where additional issues are raised
after a complaint has been
submitted, we will always add these
in and ensure that it is responded to
within the original response and if
more time is needed to do this, we
will inform a complainant of this. If
new issues are raised after a
response has been sent, we will
treat as a new complaint.
Appendix 1
Page | 15
6.9
Landlords must confirm the following in
writing to the resident at the completion of
stage 1 in clear, plain language:
a. the complaint stage;
b. the complaint definition;
c. the decision on the complaint;
d. the reasons for any decisions made;
e. the details of any remedy offered to put
things right;
f. details of any outstanding actions; and
g. details of how to escalate the matter to
stage 2 if the individual is not satisfied
with the response.
Yes This is included in the response that
we send.
Stage 2
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
6.10
If all or part of the complaint is not resolved
to the resident’s satisfaction at stage 1, it
must be progressed to stage 2 of the
landlord’s procedure. Stage 2 is the
landlord’s final response.
Yes This is set out in the Corporate
complaints procedure
6.11
Requests for stage 2 must be
acknowledged, defined and logged at stage
2 of the complaint's procedure within five
working days of the escalation request
being received.
Yes
This is set out in the Corporate
complaints procedure
6.12
Residents must not be required to explain
their reasons for requesting a stage 2
consideration. Landlords are expected to
make reasonable efforts to understand why
a resident remains unhappy as part of its
stage 2 response.
Yes
This is set out in the Corporate
complaints procedure
We will always ask a
complainant for clarification
otherwise the response that is
sent at Stage 2 will mirror that
sent at Stage 1, if we do not
Appendix 1
Page | 16
know what they are
dissatisfied with.
6.13
The person considering the complaint at
stage 2 must not be the same person that
considered the complaint at stage 1.
Yes
This is set out in the Corporate
complaints procedure
6.14
Landlords must issue a final response to
the stage 2 within 20 working days of the
complaint being acknowledged.
Yes
This is set out in the Corporate
complaints procedure
6.15
Landlords must decide whether an
extension to this timescale is needed when
considering the complexity of the complaint
and then inform the resident of the
expected timescale for response. Any
extension must be no more than 20
working days without good reason, and the
reason(s) must be clearly explained to the
resident.
Yes
This is set out in the Corporate
complaints procedure
6.16
When an organisation informs a resident
about an extension to these timescales,
they must be provided with the contact
details of the Ombudsman.
Yes
Staff in the complaint handling team
ensure that an extension
communication provides the
Housing Ombudsman contact
details
6.17
A complaint response must be provided 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 promptly
with appropriate updates provided to the
resident.
Yes
The complaint response will set out
the actions we have taken or if they
are due to be taken, when that will
happen. Services have in place
procedures to follow up on
outstanding actions
6.18
Landlords must address all points raised in
the complaint definition and provide clear
reasons for any decisions, referencing the
relevant policy, law and good practice
where appropriate.
Yes
This is included in the response that
we send.
Appendix 1
Page | 17
6.19
Landlords must confirm the following in
writing to the resident at the completion of
stage 2 in clear, plain language:
a. the complaint stage;
b. the complaint definition;
c. the decision on the complaint;
d. the reasons for any decisions
made;
e. the details of any remedy offered
to put things right;
f. details of any outstanding
actions; and
g. details of how to escalate the
matter to the Ombudsman
Service if the individual
remains dissatisfied.
Yes
The letters that we send at each
stage of the process sets out our
findings, the decision, the remedy
(where appropriate) and to whom a
complainant can request escalation
to including the Ombudsman at the
final stage.
6.20
Stage 2 is the landlord’s final response and
must involve all suitable staff members
needed to issue such a response.
Yes
The Investigating officer will collate
information from all relevant staff
before issuing our final response
Section 7: Putting things right
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
7.1
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. These can
include:
• Apologising;
• Acknowledging where things have
gone wrong;
Yes This is included in the response that
we send
Appendix 1
Page | 18
• Providing an explanation,
assistance or reasons;
• Taking action if there has been
delay;
• Reconsidering or changing a
decision;
• Amending a record or adding a
correction or addendum;
• Providing a financial remedy;
• Changing policies, procedures or
practices.
7.2
Any remedy offered must reflect the impact
on the resident as a result of any fault
identified.
Yes This is included in the response that
we send
7.3
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 This is included in the response that
we send
7.4
Landlords must take account of the
guidance issued by the Ombudsman when
deciding on appropriate remedies.
Yes
The Complaint Handling Codes are
available and key staff have
received additional training from an
officer in the Local Government and
Social Care Ombudsman.
Appendix 1
Page | 19
Section 8: Self-assessment, reporting and compliance
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
8.1
Landlords must produce an annual
complaints performance and service
improvement report for scrutiny and
challenge, which must include:
a. the annual self-assessment against
this Code to ensure their complaint
handling policy remains in line with
its requirements.
b. a qualitative and quantitative
analysis of the landlord’s complaint
handling performance. This must
also include a summary of the types
of complaints the landlord has
refused to accept;
c. any findings of non-compliance with
this Code by the Ombudsman;
d. the service improvements made as
a result of the learning from
complaints;
e. any annual report about the
landlord’s performance from the
Ombudsman; and
f. any other relevant reports or
publications produced by the
Ombudsman in relation to the work
of the landlord.
Yes
An annual complaint report is
provided for the Corporate
Resources & Infrastructure Select
Committee
8.2
The annual complaints performance and
service improvement report must be
reported to the landlord’s governing body
Yes
This is reported to the Corporate
Resources & Infrastructure Select
Committee. The report is published
From 2024/25 a separate
report will be provided to the
Residents’ Services Select
Appendix 1
Page | 20
(or equivalent) and published on the on the
section of its website relating to complaints.
The governing body’s response to the
report must be published alongside this.
on the following website: London
Borough of Hillingdon - Browse
meetings - CABINET
Committee ahead of the
annual submission to the
Housing Ombudsman Service.
8.3
Landlords must also carry out a self-
assessment following a significant
restructure, merger and/or change in
procedures.
Yes
A submission is required to Cabinet
where any changes are made to the
Corporate complaints procedure.
We will undertake self-assessments
when required.
8.4
Landlords may be asked to review and
update the self-assessment following an
Ombudsman investigation.
Yes
As a result of decisions made by the
Ombudsman, senior managers are
made aware of the decision and
actions are monitored to ensure that
they are completed. Changes made
are then noted and the self-
assessment is then changed/added
to as a result when next reviewed.
8.5
If a landlord is unable to comply with the
Code due to exceptional circumstances,
such as a cyber incident, they must inform
the Ombudsman, provide information to
residents who may be affected, and publish
this on their website Landlords must
provide a timescale for returning to
compliance with the Code.
Yes This has not happened, but is
noted.
Appendix 1
Page | 21
Section 9: Scrutiny & oversight: continuous learning and improvement
Code
provision Code requirement Comply:
Yes / No Evidence Commentary / explanation
9.1
Landlords must look beyond the
circumstances of the individual complaint
and consider whether service
improvements can be made as a result of
any learning from the complaint.
Yes Set out in the Corporate complaints
procedure
Once a complaint has been
responded to, officers will
identify any learning and set
out what has gone wrong and
what is being done to put this
right.
9.2
A positive complaint handling culture is
integral to the effectiveness with which
landlords resolve disputes. Landlords must
use complaints as a source of intelligence
to identify issues and introduce positive
changes in service delivery.
Yes Set out in the Corporate complaints
procedure
Customer Experience Contact
report covering both service
request and complaint analysis
will be developed, with the aim
of identifying issues before
they escalate into complaints
and by doing so reduce the
burden on our resources and a
culture where service
improvement is seen as the
norm.
9.3
Accountability and transparency are also
integral to a positive complaint handling
culture. Landlords must report back on
wider learning and improvements from
complaints to stakeholders, such as
residents’ panels, staff and relevant
committees.
Yes New complaint portal
Our new complaint portal has
been introduced in July 2023
and enables much more
flexible and comprehensive
reporting. This will increase
the extent to which the council
is able to learn from
complaints, share the learning
and institute improvements
9.4
Landlords must appoint a suitably senior
lead person as accountable for their
complaint handling. This person must
Yes
There is a dedicated complaint
manager at a senior level that
produces the annual complaint
Quarterly and annual
corporate reports show
themes and what action was
Appendix 1
Page | 22
assess any themes or trends to identify
potential systemic issues, serious risks, or
policies and procedures that require
revision.
report for the Select committee.
This has been enhanced by the
new role covered by the Corporate
Resources & Infrastructure Select
Committee, which will act as the
Member Responsible for
Complaints.
taken to address them.
A new IT based system for
complaints handling has been
installed which will enable
much more flexible and
comprehensive reporting. This
will increase the extent to
which the council is able to
learn from complaints, share
the learning and implement
improvements
9.5
In addition to this a member of the
governing body (or equivalent) must be
appointed to have lead responsibility for
complaints to support a positive complaint
handling culture. This person is referred to
as the Member Responsible for Complaints
(‘the MRC’).
Yes
Corporate Resources &
Infrastructure Select Committee,
which will act as the Member
Responsible for Complaints
From 2024/25 this will be
added to by a timelier report
into Residents’ Services Select
Committee ahead of the
submission to the Housing
Ombudsman Service
9.6
The MRC will be responsible for ensuring
the governing body receives regular
information on complaints that provides
insight on the landlord’s complaint handling
performance. This person must have
access to suitable information and staff to
perform this role and report on their
findings.
Yes
The intention is to provide the
Corporate Resources &
Infrastructure Select Committee,
with regular updates but this has
not yet been determined.
9.7
As a minimum, the MRC and the governing
body (or equivalent) must receive:
a. regular updates on the volume,
categories and outcomes of
complaints, alongside complaint
handling performance;
Yes This is before Cabinet on 27 June
for formal approval
The Business Manager for
complaints provides quarterly
and annual reports.
Appendix 1
Page | 23
b. regular reviews of issues and trends
arising from complaint handling;
c. regular updates on the outcomes of
the Ombudsman’s investigations
and progress made in complying
with orders related to severe
maladministration findings; and
d. annual complaints performance and
service improvement report.
9.8
Landlords must have a standard objective
in relation to complaint handling for all
relevant employees or third parties that
reflects the need to:
a. have a collaborative and co-
operative approach towards
resolving complaints, working with
colleagues across teams and
departments;
b. take collective responsibility for any
shortfalls identified through
complaints, rather than blaming
others; and
c. act within the professional
standards for engaging with
complaints as set by any relevant
professional body.
No
The central team responsible for
handling complaints, the Appeals
and Complaints Team and the
Homeless Prevention Team
dedicated to handling complaints, all
have obj ectives in relation to the
handling of complaints . However,
this is not the case for all staff that
deal with complaints across the
Council, and this is something that
we will need to work on . However,
the Council’s Corporate complaints
procedure sets out that:
“The Council is committed to putting
people at the centre of everything we
do and aims to provide the best
possible service to residents.
However, sometimes things can go
wrong and if you are not happy with
the service you have received from
the Council then please tell us so
that we can, where possible, sort out
the problem.
Full compliance to be achieved
by Dec 2024
Appendix 1
Page | 24
We will carry out enquiries fairly, deal
with your complaint as quickly and
effectively as we can while
maintaining confidentiality and
keeping you informed of progress.
We want to reassure you that the
service you get will not be affected if
you raise con cerns or make a
complaint.
The policy and procedure:
● allows managers to address
issues of unsatisfactory
service and seek
improvements in service
delivery;
● ensures that customers are
treated fairly and
consistently;
● ensures that a proper and
adequate investigation takes
place before any action is
taken;
● requests for reasonable
adjustments will be
considered in line with the
Equality Act 2010 and
appropriate training is
provided for staff; and
● safeguards the integrity and
good reputation of the
Council.”
Appendix 1
Page | 25
Governance
Effective from: 28 June 2024 Review Date: June 2025
Report Owner: Dan Kennedy, Corporate Director – Central Services
Report Author: Ian Anderson, Business Manager – Complaints and Enquiries
Approved by: Landlord Board and Corporate Management Team Housing Leads
Version Number: 1.01
Appendix 1
Text extracted automatically from the PDF, so layout, tables and images are not shown. Open the original PDF on LB Hillingdon’s website.