Appendix B – Self-Assessment Form
This self-assessment form should be 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.
| 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 | Included in our Customer Feedback Policy and includes video guide for customers on our website. |
| 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 | The process encourages all dissatisfaction to be logged and investigated formally. We have removed the ST0/NIP stage following HOS guidance last October. |
| 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 | The customer can escalate any service failing at any time to the Customer Feedback Team.
Training is clear to colleagues that dis-satisfaction however expressed should be referred to the team. |
| 1.7 | A landlord must accept a complaint unless there is a valid reason not to do so. | Yes | The Customer Feedback process includes a 3-5 working day period which allows the Customer Feedback colleagues to triage complaints to ensure they are logged in line with the Customer Feedback Policy and HOS code. |
| 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 | Exclusions listed within the Customer Feedback policy have an alternative process or published policy.
Examples of what is not considered a complaint include:
|
| 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 | Although we do not treat these issues as a complaint under this policy, we are committed to dealing with them in an appropriate manner. |
.
| 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 | The Customer Feedback process includes a 3-5 working day period which allows the Customer Feedback colleagues to triage complaints to ensure they are logged in line with the Customer Feedback policy and HOS code, or signposted to the relevant service and informing the customer. |
| 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 | Surveys undertaken by the customer involvement and business intelligence teams will make clear that if the customer is reporting a service request, we sign post to the HUB.
If the customer does report matters by a survey the teams will ensure these are passed onto the relevant team. As part of any customer engagement survey, we will ensure teams have the resources to follow up on matters the customer raises that are outside of the survey remit. Our Voice customer digital platform makes clear all service requests should be reported and customers are signposted to the appropriate channel. |
| 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 the potential channels, there must be more than one route of access into the complaints system. |
Yes | |
| 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 | |
| 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 | |
| 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 | The Customer Feedback policy has been subject to an Equality Impact Assessment.
The team have attended training on Mental Health Awareness, Dealing with Trauma, Neurodiversity and Participated in HOS and other webinars. |
| 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. | Yes | Our Customer Magazines, Customer Annual Report, ESG reports all cover information about how to complain and about how Great Places uses feedback to improve services.
These are a regular feature in these publications and shared on our website. Our new branding from Summer 2023 is You Said We Listened. |
| 2.7 | Landlords must provide residents with contact information for the Ombudsman as part of its regular correspondence with residents. | Yes | The HOS details are included on the website, webforms and in all letters raised relating to complaints.
Information about the HOS is also available when customers engage with Chatbot. This information is also clarified in the Customer Feedback Policy and associated digital animation. |
| 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 | We clarify the processes relating to the HOS in responses to complaints in the Customer Feedback Policy and associated digital animation found on this website. |
| 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 | The Customer Feedback Policy recognises that dissatisfaction received via social media channels will be handled the same as a complaint.
The Customer HUB have a team who deal with social media enquiries. Anything related to a complaint is referred to the Customer Feedback team through our CRM system to manage under the policy. |
| Code section | Code requirement | Comply: Yes/No |
Evidence, commentary and any explanations |
|---|---|---|---|
| 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 | Great Places has a dedicated, central Customer Feedback Team who will investigate, co-ordinate and manage customer feedback from end-to-end. |
| 3.2 | …the complaint handler appointed must have appropriate complaint handling skills and no conflicts of interest. | Yes | The entire team has attended a number of training programmes to support their role, this includes the HOS’s online e-learning programme.
This includes new starters as part of their induction into their role. |
| Code section | Code requirement | Comply: Yes/No |
Evidence, commentary and any explanations |
|---|---|---|---|
| 3.3 | Complaint handlers should:
. |
Yes | The Customer Feedback Team are empowered and supported by senior leadership to effect resolutions on behalf of Great Places customers.
Executive leadership meet with the team, this includes Board members. |
| 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 | When a customer advises Great Places of their dissatisfaction it will be logged at Stage One of the process. We have removed a previous ST0/NIP process following the HOS’s review of its code in October 2022.
The Customer Feedback Team consistently work within the five day ‘logging’ period and are currently logging and acknowledging Stage One complaints on day three of them being received. |
| 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 | We currently record case handler, case number and main theme of the complaint as well as guidance around timescales, next steps and HOS details. |
| 4.6 | A complaint investigation must be conducted in an impartial manner. | Yes | We have a separate Customer Feedback team working in the Customer Experience Directorate. |
| 4.7 | The complaint handler must:
|
Yes | This is reflected in the role profiles, training (including HOS webinars) and regular colleague reviews. |
| 4.11 | Landlords must adhere to any reasonable arrangements agreed with residents in terms of frequency and method of communication. | Yes | This is agreed with the customer at the start of our investigation. |
| 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:
|
Yes | HR advice is sought and our people policies followed for any complaints relating to colleagues |
| 4.13 | A landlord must include in its complaints policy its timescales for a resident to request escalation of a complaint. | Yes | This is included in the Customer Feedback Policy |
| 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 | We have recently received a HOS determination where we did not make the reasons for non-escalation in our final response letter clear.
This has now been clarified with the Customer Feedback Team following the HOS orders around complaint handling. |
| 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 | Complaint case details are recorded and saved on the case management system well as in case files. |
| 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 | Our new Service with Respect policy was signed off by Directors on 21 September 2023. Details are included in the Customer Feedback policy published for customers. |
| 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 | Contact made with customers, explore issue and explain remit and SLAs. |
| 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 | Colleagues are focused on resolutions. |
| 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 | Included and explained in the Customer Feedback Policy. |
| 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 | Contact made with customers, explore issue and explain remit and SLAs. |
| 4.9 | Communication with the resident should not generally identify individual members of staff or contractors. | Partially | We reviewed this element of the code on 13 September 2023 and will ensure that names of colleagues and contractors are not included in complaint responses. |
| 4.10 | Landlords should keep residents regularly updated about the progress of the investigation. | Yes | Included as part of the setting expectations with the customer. |
| 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 | Great Places uses a complaints satisfaction survey after each complaint. Tenant Satisfaction Measures are tracked by Board. |
| 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 | We have delivered a series of Customer Feedback Space to Learn sessions over the course of 2022/2023 to ensure colleagues are supported and awareness around the Customer Feedback Policy and procedures is clarified.
We have also designed a mandatory online training programme that all Great Places colleagues will participate in. This training programme was made available to colleagues in October 2023.ontact made with customers, explore issue and explain remit and SLAs. |
| 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 | Where restricted contact is agreed, customers will still be able to raise complaints in line with the Customer Feedback Policy.
The customer can also appeal any contact plan with the Head of Customer Voice or Head of Customer Contact. |
| 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 | Great Places currently reports as at end of August 2023 96% of complaints are dealt with in 10 days. This is in line with TSM. |
| 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 will respond to customer feedback within the 10 working days outlined in the policy unless the customer agrees to have their complaint response date extended.
The Customer Feedback Team has introduced a resolution action tracker to ensure agreed resolutions are followed up by the relevant services. |
| 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 | Templates set out requirements of the code and to ensure customers receive a full response to all their concerns. |
| 5.8 | Landlords must confirm the following in writing to the resident at the completion of stage one in clear, plain language:
|
Yes | This is all covered in our template/checklist response. |
| 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 | The Customer Feed Team senior co-ordinator will discuss any request for a stage 2 with the customer. |
| 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 | The Customer Feedback Team as part of the complaint handling will call the customer unless the customer declines this. |
| 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 | Included in the Customer Feedback Policy and part of colleague training. |
| 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 Two complaints are investigated independently by a senior service manager. This process is built into the Customer Feedback policy and the associated digital animation. |
| 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 | Where we have found it necessary to extend Stage Two complaint responses, we have agreed this with customers. |
| 5.16 | Landlords must confirm the following in writing to the resident at the completion of stage two in clear, plain language:
and
|
N/A | Great Places adopts a two-stage complaints process. |
| 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. | N/A | Great Places adopts a two-stage complaints process. |
| 5.20 | Landlords must confirm the following in writing to the resident at the completion of stage three in clear, plain language:
|
N/A | Great Places adopts a two-stage complaints process. |
| 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 | Agreed with the senior co-ordinator a new role introduced in December 2023. |
| 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 | We have not experienced any occasions where customers have not agreed an extension proposal. |
| 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 | The Customer Feedback Team will interrogate systems and identify any patterns / themes / trends.
These are flagged with leaders and managers of service areas. |
| 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 | Part of the Customer Feedback Policy. |
| 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 | Part of the performance of the Customer Feedback Team and is included in our complaint handling satisfaction survey. |
| 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 have not experienced any occasions where customers have not agreed an extension proposal. |
| 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. |
N/A | Great Places adopts a two-stage complaints process. |
| 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. | N/A |
| 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 | We carry out case reviews to agree actions and resolutions to resolve customer complaint and track our intentions on the resolution’s tracker. |
| 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 | New Remedies and Resolutions Policy written to ensure fairness, proportionate and appropriate redress to service failures.
This has been aligned to the HOS Remedies Guide and has been written following consultation with customers and colleagues. |
| 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 | Resolution tracker implemented to monitor this. |
| 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 | The new Remedies and Resolutions Policy considers a number of ways that we can resolve service failures and takes into account distress and inconvenience caused. |
| Code section | Code requirement | Comply: Yes/No |
Evidence, commentary and any explanations |
|---|---|---|---|
| 6.6 | 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 | We track learning and service improvements via a Service Improvement Tracker.
Learning is lifted up to service teams to ensure the necessary service improvements are made. We work with our continuous service improvement team. Two recent reviews involved our Customer HUB and Planning service following feedback from customers including complaints. |
| 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 | Should cases require legal consultation Great Places would ensure this is carried out as part of the complaint investigation. |
| 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 | We update customers through our website and customer magazines and Customer Annual Report.
Our theme is You Said We Listened to highlight where we have used complaints to improve services. |
| 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 | Currently the CEO is appointed responsibility for complaints.
Complaints and Compliments are shared with Board via their CEO report as well as quarterly reporting to Board. |
| 7.4 | As a minimum, governing bodies should receive:
|
Yes | Customer Complaints are reported to Board on a quarterly basis. This includes complaint data, trends, themes, areas of service improvement. Learning and good practice including HOS updates and Spotlight reports.
HOS cases and determinations are shared at every Board via the CEO report. This includes Audit and Assurance Committee via the Director of Business Assurance. HOS spotlight reports will going forward have a Director as their sponsor and a Head of Service/Senior Manager as the lead. They will report into the appropriate project and Directors on a to be agreed basis. Board reports are then shared via Directors and Head of Service teams across the business. Monthly reports are provided to Directors. Customers are updated on a monthly basis via our web pages and in Customer Magazines. Colleagues are updated via our new page on the intranet. This includes performance, cases studies, learning and service improvements. Our new Customer Committee will have a role, and this is to be agreed with committee members once recruited. |
| 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 | Complaints and Compliments are reported and reviewed by leaders across the business. Case studies are reviewed by Board and leaders. Case reviews including HOS determinations include a Head of Service and the Director.
Our Customer Insight group who receive regular data and can trigger a deep dive into services. Service Improvement Business partners support services to review and scope out any areas for improvement highlighted from complaints. Service Excellence Groups (SEGs) lead on dealing with policy, customer feedback, complaints for that service area. This includes support services HR and L&D. Recent training has included bespoke customer complaints mandatory for all colleagues. Redesigned induction training on customer service. Damp, mould and condensation has been a priority with tailored training being delivered across specific groups in the business. |
| 7.6 | Landlords should have a standard objective in relation to complaint handling for all employees that reflects the need to:
|
Yes | New online complaints training has been introduced in October 2023. Complaints are discussed at individual meetings with colleagues.
Case reviews have been introduced and colleagues involved attend. A review of Great Places Great Conversations introducing Great Conversations 2 and will include objectives. The Customer Experience strategy is being reviewed in 2024. . |
| 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 | Undertaken and approved at Directors and then Board. |
| 8.2 | Landlords must also carry out a self-assessment following a significant restructure and/or change in procedures. | Yes | N/A. |
| 8.3 | Following each self-assessment, a landlord must:
|
Yes | The self-assessment will be reviewed in line with our Governance structures to include Directors, Executive Leadership and Board.
The self-assessment will be reviewed in line with our governance structures to include directors, executive leadership and the board. This will be communicated to colleagues and customers through Manager Briefings, our internal colleague intranet and our new Storyboard platform that makes communication accessible to our mobile colleagues through an audio podcast. Customers will be updated via the monthly E-news, Customer Magazine and website. |
