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West Northamptonshire Council (202207385)

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REPORT

COMPLAINT 202207385

West Northamptonshire Council

12 February 2023


Our approach

The Housing Ombudsman’s approach to investigating and determining complaints is to decide what is fair in all the circumstances of the case. This is set out in the Housing Act 1996 and the Housing Ombudsman Scheme (the Scheme). The Ombudsman considers the evidence and looks to see if there has been any ‘maladministration’, for example whether the landlord has failed to keep to the law, followed proper procedure, followed good practice or behaved in a reasonable and competent manner.

Both the resident and the landlord have submitted information to the Ombudsman and this has been carefully considered. Their accounts of what has happened are summarised below. This report is not an exhaustive description of all the events that have occurred in relation to this case, but an outline of the key issues as a background to the investigation’s findings.

The complaint

  1. The complaint is about the landlord’s:
    1. Handling of an infestation of bedbugs.
    2. Communication with the resident.
    3. Complaint handling.

Background

  1. The property is a one-bedroom flat located on the fourth floor of a block of 53 flats. The resident’s direct downstairs neighbour reported bedbugs at their property on 13 August 2020. On 9 October 2021, the resident discovered bedbugs at her own property and moved out on the same day. On Monday 11 October 2021, the resident reported this to the landlord.
  2. On 11 November 2021, both properties were visited by the pest controller (PC) and monitors were placed. Treatment began at the neighbouring property and recommendations were made to dispose of infested furniture items.
  3. On 30 November 2021, a treatment plan was agreed between the landlord and contractors. The resident’s property was not included in the plan, as the contractor advised that there was “no issue”. On 3 December 2021, the PC visited both flats. Monitors confirmed bedbugs to be present at the resident’s property. Both properties were treated. PC continued to attend both properties regularly throughout December 2021.
  4. On 21 January 2022, the resident complained that the landlord had “allowed the neighbouring resident, in breach of their tenancy agreement, to leave bedbugs untreated for over a year, which has now impacted me”. She was unhappy at the length of time the treatment had being going on for and that she had been forced to dispose of her furniture, incurring costs. The resident raised concerns again about the contractor the landlord had employed, citing the opinion of an independent PC contractor to highlight what she believed were shortcomings in the landlord’s own contractor’s performance. The resident was unhappy with the landlord’s communication and that other residents in the block had begun “dumping furniture” in the communal areas as the infestation spread throughout the block. The resident wanted to be able to move back into her flat, compensation for her furniture and a rent refund for the entire period.
  5. On 25 January 2022, PC attended the property and found no evidence of bedbug activity. The resident again disputed elements of the report in an email to the landlord on 26 January 2021. Further visits to the property on 11 February 2022 and 1 March 2022 revealed no change.
  6. On 17 February 2022, the landlord informed the resident that her property appeared to be bedbug free, and that a follow up visit with the neighbour was scheduled. It said that it would contact the resident with an update following the visit, which took place on 21 February 2022; all monitors were clear and final fog treatment was applied.
  7. On 22 June 2022, bedbug activity was reported at the neighbouring property. The landlord attended on 4 July 2022 but was unable to get access. The visit was rescheduled for 20 July.
  8. On 10 July 2022 the resident chased the landlord for an update. On 11 July 2022, the resident contacted this service. She wanted help in obtaining a final complaint response letter from the landlord, dealing with several of the concerns she had raised previously. The resident’s main points of dissatisfaction were the landlord’s ineffective treatment of the infestation to date at both properties, the resident’s view that the property was not habitable, and that she was obliged to pay rent while she was not living at the property. The resident wanted action to be taken against the neighbour for a perceived lack of cooperation with the landlord’s PC activities, for the infestation to be resolved, and to receive appropriate compensation.
  9. On 19 July 2022, the landlord issued a complaint response. The landlord detailed the treatments it had carried out at the property, which resulted in its understanding that pests had been eradicated. It explained that treatments were scheduled at both properties. It accepted that it had not kept the resident adequately up to date, apologised for this failing, and pledged to improve communication. The resident replied that she never believed the property to be free of bedbugs, again asserting that the landlord had been provided inaccurate reports by its contractor. She explained she could not move back into the property without assurances the block was free of pests, because she could not take the financial risk of replacing her furniture for it to potentially need replacing again. The resident asked the landlord to escalate the complaint, but the landlord declined.
  10. From 20 July 2022 onwards, the landlord continued to attend properties in the block to carry out pest treatments. On 1 September 2022, PC attended the resident’s property and deemed it to be pest-free. The resident began redecorating, but felt she could not yet move back in, because pests remained at the neighbouring property.
  11. On 8 December 2022, the resident returned to the property. She reported bedbug activity the following day and vacated the property. The landlord cleared the neighbouring flat on 17 December 2022 and carried out block-wide pest monitoring activities, in consultation with all residents, on 16 and 22 December 2022.
  12. The landlord continued to attend both properties, along with a number of other properties in the block, from December 2022 to 20 October 2023. The resident’s flat was deemed pest-free on 24 March 2023, but the resident did not move back in.
  13. On 19 July 2023, the resident visited the property to check the traps, after hearing from a neighbour that pests were still present elsewhere in the block. She found bedbug activity, which she again reported to the landlord. The resident complained again, and in the following days, the resident and landlord had a lengthy email exchange, points of which are referenced throughout this report. Although this was not a formal complaint response, the landlord responded thoroughly to the concerns the resident had raised, and offered £250 compensation as a goodwill gesture, in respect of distress and anxiety experienced. The landlord carried out a fog treatment on 25 July 2023.
  14. The landlord carried out final treatments at other properties in the block on 27 September 2023 and 20 October 2023. It is understood that the landlord has had no reports of bedbugs at the block since prior to 27 September 2023.

Assessment and findings

The landlord’s handling of reports of bedbugs

  1. The Ombudsman’s Dispute Resolution Principles are to ‘be fair’, ‘put things right’ and to ‘learn from outcomes’.
  2. This investigation spans the entire period for which pests were said to have been present in the block. This means that the Ombudsman has considered events over a period of more than 3 years. Including a written assessment of all of these events is not necessary; this report focuses on addressing any remaining areas of contention between the resident and landlord. For most periods of time not assessed in this section, the landlord was generally attending to carry out pest control activities in line with expert advice; the general handling for these periods may be described as “good”. As a result of this case, the landlord has advised that it has made the decision to introduce a policy to guide its future handling of bedbug cases. The Ombudsman agrees that this is the most appropriate way to consolidate its learning from this case. This report therefore also highlights, and draws recommendations from, events that demonstrate where the landlord could have perhaps performed better; though, these do not necessarily represent failings. This is because it is understood that the nature of bedbug infestations means that even where an infestation has been dealt with “perfectly”, there is no guarantee it will not recur.
  3. A core element of the resident’s complaint has been that the landlord’s failure to deal with her neighbour’s infestation from 13 August 2020 onwards, ultimately led to the resident’s own property becoming infested on 11 October 2021. The landlord confirmed that the source of the infestation was the neighbouring property in question, stating that due to “the structure of the block the bedbugs were able to migrate to the property above through the cavities in the building.” The landlord’s policy states that “in limited circumstances we offer a free pest control service, delivered by an approved contractor. This service is only available where the pest problem affects a shared communal area for properties such as flats... We do not provide a pest control service… where the pest problem is confined to an individual flat...”. When the neighbour reported bedbugs in the property therefore, it was right to signpost them to pest control services, and outline their responsibilities.
  4. The landlord however did not proactively monitor the neighbouring infestation during this period, or seek expert advice on the risk of leaving the infestation untreated; it’s policy did not require it to. The resident later commented that “it was obvious was what going to happen”. In hindsight, the resident appears correct, however in consideration of the landlord’s position at the time, its inaction was not unreasonable. The neighbour in question also gave the landlord reason to believe that treatment was being undertaken, though ultimately this was neither timely nor effective. However, it is the Ombudsman’s view that in light of the landlord’s recent experience, the part of the landlord’s current policy which does not require it to take action where an infestation is confined to an individual flat, is not fit for purpose; recommendations are made below.
  5. The resident expressed dissatisfaction that the landlord had not taken action against the neighbour, who in the resident’s view, had breached their tenancy by not dealing with the pests. This remained a theme of complaint throughout the various phases of the infestation and reinfestation, as the landlord frequently told both the resident and this service that the “greatest challenge in treating the bedbug infestation was the failure of the [neighbour] to engage with PC contractors.” The evidence supports this, and shows that the landlord had taken a number of steps to support the neighbour. Ultimately, it made the decision to move them in December 2022, following advice from PC contractors. It sought to move the neighbour by consent, rather than take enforcement action against their tenancy. The Ombudsman has seen evidence which demonstrates that this was an appropriate step to take, due to outside circumstances which required consideration. This was time consuming. It should also be recognised that to take action against the neighbour’s tenancy in the way the resident would have liked to see (to seek possession of the property), would also have been time consuming and potentially unsuccessful. The infestation would likely have continued to spread in the interim.
  6. The resident later complained that advice she had forwarded to the landlord from her own contractor at the beginning of October 2021, had advised that “consecutive treatment” (of both properties on the same day) would be required. The resident was also unhappy that the landlord had used “a cheap and shoddy contractor”, and suspected that this formed part of the reason that consecutive treatments had not been carried out. The landlord explained that it had tried to perform consecutive treatments, but had often been prevented by access and engagement issues at the neighbouring property, which the evidence supports. This meant that many treatments at the resident’s property ended up being ineffective. It also caused delays. During this time, the landlord also took steps to prepare the resident’s flat for heat treatment. There is no indication that these challenges would have been overcome by using an alternative contractor.
  7. When the resident reported in October 2021 that the infestation had spread, the landlord initially advised the resident that she was responsible for dealing with the infestation. Soon after, the landlord appeared to reassess the situation, and took responsibility for all treatments in the block going forward. This was an appropriate change of approach, and served as the first of multiple examples seen by this investigation of the landlord ‘being fair’ in its decision making, though at times this came at the second time of asking. The landlord also consistently demonstrated its ability to adapt to changing situations and to ‘learn from outcomes’ in its practices. For example, when the resident reported that the infestation had recurred on 16 December 2022, it appeared to shift from a reactive to a proactive strategy. It started by writing to all residents of the block and carrying out block-wide monitoring exercises. It provided information leaflets to all residents. The landlord later told this service that it mapped the block at this time, in order that when a report of bedbugs was received, all properties above, below and adjacent would be contacted to arrange consecutive treatment. This suggests that it had reviewed its previous approach and drew appropriate conclusions; through trial and error, the landlord began to devise a holistic strategy for dealing with the infestation. The risk going forward is that this experience currently rests with a core group of staff members. It is right therefore that the landlord has recognised the need for this experience to be consolidated in writing, to form the basis of landlord’s bedbug policy.
  8. The resident also raised concerns about the actions of her neighbours, which may have exacerbated the infestation. For example, by discarding furniture in the communal areas and spending time in one another’s properties. It is unclear if the landlord’s advice leaflets addressed these issues. The evidence shows that the landlord took responsibility for the “wrapping, packing and removing” of infested furniture, in line with expert advice, from the properties that were subject to this investigation. However, it is clear from the resident’s account that this may not have been done comprehensively across the block. From the evidence, it appears likely that the landlord may have suspected some residents of the block were experiencing bedbug infestations, but had failed to report this to the landlord. This may have influenced the landlord’s decisions which led to the proactive monitoring of other properties in the block in December 2022. It is unclear therefore if the residents who were disposing of the infested furniture, had first reported the infestation to the landlord. Recommendations are made below.
  9. In 2022, the landlord began carrying out heat treatments at the block. It treated the resident’s property on 9 August 2022, however the neighbour did not provide access for treatment on the same day. This was rearranged and took place on 26 August 2022, but the resident’s property was not consecutively retreated. Although the landlord performed inspections after this date at the resident’s property, finding no evidence of pests, it should have followed the advice it had previously been following to ensure both properties were successfully reattended on the same date. There is no evidence however that this oversight affected the outcome of the resident’s own infestation however, because the neighbouring property continued to experience infestation until February 2023. The resident reported a recurrence in December, however the inspection of 16 December 2022 found no bedbugs. The PC contractor did not appear to treat the property. The PC contractor inspected the resident’s property again on 26 January 2023. It found no bedbugs, and so did not treat the property then, either. It may have been prudent, in light of the pests still being present at the neighbouring property, to carry out a precautionary treatment at the resident’s property around this time, although it is unclear what advice the landlord received from the PC contractor in respect of this. It is again unclear if the landlord’s decision not to treat the property in response to the resident’s report of a bedbug sighting in December 2022, directly led to the reinfestation in July 2023. It attended again on 25 July 2023, found dead insects at the property and carried out a fog treatment. The landlord later chose to complete additional treatments at different properties in the block in September and October 2023, even after inspections revealed no bedbug activity. This suggests the landlord may have recognised this missed opportunity and undertaken further learning from its experience.
  10. The evidence shows that the PC contractors relied primarily on the use of traps and monitors to inform the effectiveness of treatment at the resident’s property. The resident however raised concerns that some of the contractor’s reports were “inaccurate”, often overstating the number of traps which had been left, or including comments such as “resident reports no bites”, even though she was not living at the property at the time. The reports also stated that certain rooms in the property had been “pest free”, but the resident stated these rooms were not actually checked. This investigation has been unable to determine the accuracy of these reports. It was also reasonable for the landlord to state in later correspondence that it had “assumed these reports to be accurate”, because the resident had signed them. The resident alleged that infestations recurred in part because the PC contractor had wrongly declared properties to be pest free. She felt that the contractor could not be trusted, because it had a “financial interest” that infestations remained ongoing. There is no evidence to support that this influenced the contractor’s handling of the infestation. The landlord’s investigation into this was inconclusive, because many explanations for the repeated investigations were possible. For example, bedbugs are known to cling to clothing, which could have occurred when walking past infested furniture left in the communal areas. They may also lie dormant in walls for “up to 18 months or longer”, in the absence of a host (person living at the property full time), or spread through cavities as already mentioned. This demonstrates the additional challenge present at the resident’s property, caused by it being vacant throughout this period. The evidence suggests however that in the absence of a host, any inspection which failed to identify bedbug activity would be ultimately unreliable. The landlord advised the resident of this on multiple occasions, but the resident chose to remain absent from the property. Therefore there was no failing in this regard. The landlord however was not able to rule out any merit to the resident’s concerns about the contractor; recommendations are made below.
  11. When the resident reported pests in October 2021, the landlord initially opted to place monitors at the resident’s property. After inspecting the monitors on 11 November 2021 and finding no bedbug activity, it opted not to include the resident’s flat in the treatment plan. At the time, this approach was reasonable, because the landlord understandably took the result of the inspection to mean that no treatment was required. It learned only later that monitoring is less effective where the resident is not living at the property full time. In future, the landlord should consider that a report of bedbugs by the resident should not be discounted, just because monitors could not confirm the presence of pests. The landlord also failed to carry out treatment in response to her sighting in December 2022, instead opting to place traps and monitors. As remarked above however, there is no evidence that this impacted the overall situation. Recommendations are made below.
  12. The Ombudsman understands that the resident reported having experienced high levels distress, anxiety and inconvenience, for a significant period of time, as a result of the bedbug infestation at her property. This understandably led the resident to feel that she had to move out. The resident acknowledges that moving out of the property was her choice, and that the financial obligations associated with maintaining her tenancy remained in place during this period. It is understood that there is no expectation for the landlord to refund rents paid. The Ombudsman’s investigation has found no failing which warrants a reconsideration of the landlord’s position in this regard. This may have been different in the event that the property was found to be unfit for human habitation. There is no indication that, despite the presence of pests, the property was at any point unfit for human habitation, as set out in the relevant legislation. The landlord also explained that, due to a pre-existing agreement with itself and the local authority, there would have been little tangible benefit to reporting the infestation to the local authority. This investigation can identify no clear way in which the outcome of this case may have been different, if the landlord chose to do so. Yet, it is noted that local authorities may have additional powers to address infestations, where they are identified as a hazard under the Housing Health and Safety Rating System. The landlord remained responsible for making such a report in the event that the pest issue became prejudicial to public health. This service cannot make assertions about whether or not the infestation at this block warranted such a report. However, there is no evidence that the landlord made an inspection to determine if the infestation was prejudicial to the health of the resident or her neighbours, or if the properties affected were fit for human habitation. The photographs seen from other properties in the block as part of this investigation, suggest that some infestations did progress to a point whereby it would have been reasonable to carry out such an inspection, in order to protect all residents of the block.
  13. In later correspondence with the landlord, the Ombudsman asked the landlord for an assessment of what had been done to tackle the potential for bedbugs to remain lying dormant in the resident’s wall. The landlord explained that it had considered this, having “hacked off the plaster” from the walls before commencing heat treatments in August 2022. The evidence supports this. The landlord has since fog treated the property on 25 July 2023. The subsequent inspection of 8 August 2023, revealed no pest activity. As above however, this inspection cannot be relied upon in the absence of a host. The resident remains reluctant to make plans to move back in, in part because of the financial risk of furnishing the property, to later need to dispose of the furniture should an infestation reoccur. The landlord on the other hand appears hesitant to continue to treat the property, because it has no way to know if further treatment is required, or to conclusively assess that any further treatment it carries out is effective, until the resident returns to act as a host. The position of both parties is entirely reasonable. This “double bind” situation reflects the complex and persistent nature of dealing with bedbugs. However, the records show that since the end of August 2022, there have been two bedbug sightings at the property, and only one treatment carried out. It is reasonable therefore to recommend that the landlord carry out a final, precautionary treatment at the property. The decision to move back in would then rest with the resident.
  14. The Ombudsman also notes that the landlord was required to approach its contractors, in order to access PC records for individual properties. It is unclear if the landlord retained its own copies of this information. There is no indication that any failings arose as a result of this practice with regard to the landlord’s handling of the infestation at the block. However, in order to retain effective control and oversight of infestations, and to prevent any losses of data about its own properties and residents when stored by outside organisations, it should consider collecting and maintaining its own records in future. Recommendations are made below.
  15. In conclusion, the landlord’s inability to effectively treat the infestation was due largely to factors outside its control. The landlord displayed excellent commitment to ‘being fair’ and ‘learning from outcomes’. The landlord offered the resident a temporary decant in August 2023, which was declined. This, alongside both the offer of compensation and the landlord’s decision to take responsibility for all PC works at the resident’s property, demonstrates that the landlord had done what was reasonable in order to ‘put things right’. There was no maladministration in the landlord’s handling of an infestation of bedbugs.

Communication with the resident

  1. The resident complained frequently to the landlord about inadequate communication throughout the period assessed by this investigation, often citing long periods where she “heard nothing” from her housing officer. For example, in her complaint of 11 July 2022, the resident stated that “the last time I heard from [the landlord] was February, it has now been 5 months and you haven’t contacted me”. The landlord upheld this complaint on 19 July 2022, offering “a sincere apology” that its records showed that it “did not keep [the resident] updated after her initial report”. However, there is no evidence that the resident followed up in that time either. The last contact the resident had was with the PC contractor on 1 March 2022, where the PC contractor reports that it “advised the tenant to monitor” pest activity using the monitors provided. The evidence shows that the resident was often, but not always, forwarded a copy of the PC report after each visit. All the PC reports seen by this investigation contain a copy of the resident’s signature. The resident at some points has disputed that she signed these reports, though in July 2023, when the landlord forwarded copies of these reports, she stated that she “honestly can’t remember signing the report, but I’m not saying I didn’t”. It must therefore be concluded that in the absence of any evidence to the contrary, it is most likely resident did have sight of the PC reports at the time they were produced. It was reasonable, given the resident’s signature, that no further reports from the resident could be interpreted by the landlord as no further bedbug activity being observed at the property.
  2. The landlord was aware that the resident was not living at the property. It could therefore have done more to ensure that it was checking in with the resident and that she was complying with PC advice by checking traps. However, it appears that it did not, because there was confusion over how often the resident was attending the property. In July 2023, the landlord and resident corresponded, in which the resident acknowledged that she had not been checking the traps on her visits to the property. Given that the landlord had understood from the PC report, which the resident had signed, that the resident would be checking the traps and reporting any further activity, it is reasonable that the landlord did not contact the resident about her property during this time.
  3. The resident had made it clear to the landlord on a number of occasions that in order to feel safe to move back into the property, she would need assurances that the entire block was clear of pests. It was reasonable therefore to expect that, while the landlord may not have been able to give information about specific properties, it should have given the resident frequent updates about the general situation at the block. The evidence shows this rarely happened, or that when it did, it was usually in response to an enquiry made by the resident. While the landlord had assumed that the a lack of contact by the resident had meant no bedbugs were at the property, the resident had assumed that no contact from the landlord had meant the infestation continued elsewhere in the block. As it transpired, the resident’s assumption was correct, as the block continued to experience recurring infestations until 27 September 2023, at which point the final property was declared to be free from pests. The landlord treated anyway and reattended on 20 October 2023, confirming the block was clear. The resident however was not informed. The resident reported instead that on or around 26 October 2023, the landlord called the resident to advise that pests remained at the block. It told this service that its records indicated the same thing, until this investigation requested up to date information on 9 November 2023. It was at this point that the landlord contacted the PC contractor, to learn that the block had been effectively pest free since September. It is clear therefore that the landlord did not retain proper oversight of the situation for the purposes of appropriately updating the resident. It is unclear if the resident would have moved back in on 27 September 2023, if she had been informed that the block was pest-free. However, she had the right to be updated by the landlord.
  4. The resident described the lack of contact by the landlord as highly distressing, stating that the entire situation caused her to experience anxiety. This would account for the lack of frequent contact made to the landlord by the resident during this period. It is likely that this could have been somewhat reduced, had the landlord kept the resident updated about the condition of the block. It acknowledged this in its complaint response in July 2022, but failed to offer compensation in order to put things right. As a result of these two failings, there was a service failure in the landlord’s communication with the resident. Orders are made below to ‘put things right’.

Complaint Handling

  1. The Ombudsman’s Complaint Handling Code (the Code), by which the landlord is bound, states that a complaint is defined as “an expression of dissatisfaction, however made”. The landlord should recognise such complaints and raise them formally through the internal complaints process (ICP). The evidence shows that the resident complained on a number of occasions, but the landlord did not raise this formally. The landlord however did demonstrate that when the resident raised complaints, it appropriately addressed her concerns by way of an informal response. In July 2023, the resident complained again. The landlord sent a number of comprehensive responses as part of this correspondence and offered compensation as part of this.
  2. One of the key concerns of this service, when a landlord is not using the ICP where it is appropriate to do so, is that the landlord’s obligations under the Code are often not adhered to. However, the thoroughness of the landlord’s July 2023 responses, and it’s decision to pay compensation at this point, has appropriately addressed that concern in this case. The landlord’s decision not to use the ICP, meant that this service was obliged to request a formal response, resulting in a short delay in the resident being able to seek a resolution via this service. The delay however was negligible, and mitigated by the landlord’s decision not to escalate the complaint when the resident requested, resulting in the resident acquiring the final response letter she required in roughly the same amount of time as if the initial delay had not occurred. There was therefore no maladministration in the landlord’s complaint handling, though recommendations are made below.

Determination

  1. In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was no maladministration in respect of its handling of an infestation of bedbugs.
  2. In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was a service failure in the landlord’s communication with the resident.
  3. In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was no maladministration in the landlord’s complaint handling.

Orders

  1. The landlord must, within 4 weeks of the date of this determination, pay £250 compensation to the resident in relation to the impact of communication failings.

Recommendations

  1. That the landlord introduce bedbug policy. It should consider:
    1. That it is favourable to prevent the spread of a confined infestation, than to treat an infestation which has spread to multiple properties.
    2. Implementing a strategy for dealing with infestations which arise in blocks containing multiple properties. It may also wish to consider other properties in its stock, and any possible challenges they may pose.
    3. Strategies for dealing with vulnerable residents who report bedbugs.
    4. Strategies for dealing with infestations where the resident does not engage.
    5. Its response to infested belongings that are disposed of in communal areas.
    6. Updating its literature to advise residents of actions they should and should not take, when experiencing a bedbug infestation.
    7. Introducing a threshold to identify when a second expert opinion may be required, in the event of repeated or stubborn infestations.
    8. How it might address the possibility of a “statutory nuisance” under the Environmental Protection Act 1990, or a Hazard under the Housing Health and Safety Rating System. This may be most easily dealt with by introducing a requirement to notify the local authority of any bedbug infestations, as a matter of course.
    9. Processes to ensure that all contractor records are also stored locally.
    10. Strategies for dealing with infestations where monitoring activities may not be relied upon, such as where a host is absent from the affected property.
  2. The landlord should take any steps it feels appropriate to ensure it is consistently and more regularly raising expressions of dissatisfaction, however made, through the internal complaints process.