Brighton and Hove City Council (202335014)
REPORT
COMPLAINT 202335014
Brighton and Hove City Council
13 September 2024 (amended at review)
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
- The complaint is about the landlord’s response to the resident’s:
- Reports of antisocial behaviour (ASB).
- Reports of discrimination, including a failure to make reasonable adjustments.
- Concerns about communal cleaning.
- Associated complaint.
Background
- The resident has a secure tenancy with the landlord, which is a local authority. The property is a flat in a low-rise block of 6 flats. The landlord has several physical conditions recorded for the resident including a manageable, chronic health condition and chronic pain. It also noted that he has a history of anxiety and depression, some short-term memory loss and dyslexia.
- On 19 June 2023 the resident reported the neighbour throwing urine towards his balcony and said he had reported this to the police as well. (He had reported similar incidents to the landlord in 2017 and 2019). The resident said some urine had gone on to his leg. On 30 June 2023 the resident made a formal complaint to the landlord saying it had not responded to his concerns. The landlord acknowledged the complaint on 3 July 2023.
- On the same day the landlord told the resident it was investigating his reports of ASB. It asked if it could contact him on a weekly basis about this matter and also asked how often the urine was thrown from the balcony. In response the resident told the landlord, historically, the incidents had been every one to two weeks. He explained the neighbour filled a bucket with urine over time and then threw its contents from the balcony.
- The landlord visited the neighbour with the police on 10 July 2023 and gave them a warning. On the same day the resident told the landlord there had not been any further instances and suggested that it block off his balcony. The landlord subsequently explained that it could not do so because of drainage issues. The resident asked it to reconsider this decision. He also said, despite assurances in historical ASB meetings that victims needs and rights would be put first, that was not happening in this case. He added that there were a large number of flies in the hallway and the smell was “very bad”. The resident subsequently told the landlord that it was not keeping him safe in his home because the balcony was not blocked off.
- On 20 July 2023 the resident asked the landlord to clear a blocked drain. On the following day he reported a very strong smell of urine and suggested the landlord place air fresheners in the communal area. On the following day, the landlord told the resident that it was taking a proactive approach with the neighbour, but the issue was unlikely to be solved overnight. It confirmed it would be visiting the neighbour again over the coming weeks and had ordered an air freshener for the communal space. It added the resident should continue reporting any problems.
- On 31 July 2023 the resident contested the landlord’s view (that it made to a local councillor) that the substance thrown over the balcony might have been bleach and water, rather than urine. He asked it to investigate. The resident also made a community trigger referral at that time. (This is a process available to people who are suffering ASB and feel that the organisations involved are not doing enough to resolve the problem.) The landlord turned this down as the threshold was not met. It explained this was because one of the reported incidents (‘smelling urine outside his flat’) was not classed as ASB.
- On 3 August 2023 the landlord issued its stage one complaint response and apologised for the delay in doing so. It explained that, to investigate, it had checked its records and spoken to the housing officer dealing with the case. The main points were:
- It had an open ASB case and had issued warnings to the neighbour as well as carrying out home visits including jointly with police.
- It would unblock the drain by the balcony and to inspect his balcony to see if any works could be done to protect it, without interfering with the drainage. It requested an air freshener for the shared hallway. It apologised that his email of 19 June 2023 had not been logged as a stage one complaint. On the same day the resident asked the landlord to escalate his complaint. He said it had not investigated properly what substance the neighbour had thrown from the balcony. He said he believed this was a personal attack and was due to his sexuality. He said he also believed that was why the landlord did not take a stronger stand against ASB in this instance. The resident added he believed some staff were homophobic and were not dealing with the case properly. He asked what further evidence he needed to provide.
- On 4 August 2023 the landlord asked the resident to speak to it as he had made a very serious allegation that it was discriminating against him on the grounds of his sexuality. It said it would like to meet with him to obtain the full details so that an investigation could be carried out. It asked him to attend on 9 August 2023. In response, the resident asked why this named manager was dealing with this as it was their team he was complaining about. He said this was inappropriate. A few days later the resident asked the landlord if it could test the fluid thrown by the neighbour to find out if it was urine.
- On 9 August 2023 the landlord and resident agreed that contact would be made with him every two weeks by telephone. On the same day the landlord met with the resident. It sent him an email that day confirming it did not have facilities to test substances of any sort and that its repairs team had concreted over the drain next to the balcony as it was no longer in use. It gave details of action points from the meeting which included asking its repairs team to inspect the balcony in relation to his request that it could be enclosed and that it had asked its estates team look into his complaints about the cleaning of the main entrance door and hallways.
- The landlord noted the resident felt discriminated against because other cases had had different outcomes and that he felt no action had been taken because it was not taking the situation seriously and was not protecting him as a victim. The landlord gave the resident information about the action it was taking in relation to the neighbour and said it could not agree that it was not taking the situation seriously. It said that the resident had not provided it with any information that could be used to investigate his serious allegation that it was discriminating against him on the basis of his sexuality.
- At the end of that month, the resident reported faeces on the communal door handle and said a cleaner had also cleaned faeces off the neighbour’s door handle and door frame. The landlord visited the neighbour early the following week. It subsequently wrote to him warning that, if there were further evidenced reports, it might have no choice but to serve a Notice of Seeking Possession.
- On 11 September 2023 the resident reported “quite overpowering smells” coming from the neighbour’s flat on some of the warmer days”. He said there did not appear to have been any urine thrown recently but the neighbour had shifted to leaving faeces on the door.
- On 18 September 2023 the landlord noted it had contacted the resident who confirmed a new incident the previous week (but did not give details). On the same day it acknowledged the resident’s stage 2 complaint which concerned the incidents of ASB.
- On 20 September 2023 the resident made a second community trigger referral citing the neighbour’s ASB in relation to both urine and faeces. The next day the resident chased up cleaning of the balcony. The landlord responded saying it would arrange a visit “in a week or so”.
- On 27 September 2023 the landlord told the resident that the community trigger threshold had been met.
- On 5 October 2023 the resident made a complaint to the landlord about discrimination. He set out several concerns including why an independent person did not have the meeting with him on 9 August 2023 and that he had made many references to his learning disabilities but had not been offered any alternative system method for contacting the landlord. He also asked why cleaning in the block had been withdrawn after he was given an assurance that it would be done more thoroughly.
- On 20 October 2023 the landlord wrote to the neighbour following a visit that day. It said the neighbour had agreed that he would stop throwing liquid onto his balcony and that he would not pour any urine down the kitchen sink, because both of those caused a nuisance to other people.
- On 27 October 2023 the landlord issued its stage 2 complaint response to the resident and apologised for the delay in doing so. The main points were:
- The meeting of 9 August 2023 had been arranged to gain a greater understanding of the issues and, where appropriate, address this. The landlord had asked the resident for more information about his experience of discrimination, so that she could investigate but he had not provided any specific examples of where and how he had been discriminated against.
- It asked the resident to call customer services as it had different ways to assist him in communicating with it given his dyslexia. It said it would then put a note on his account.
- Cleaning in the block stopped because of building work that was going on and had resumed on 9 September 2023. It concluded that the work did not stop because he had raised concerns.
- It explained it was legally bound to adhere to a pre-action protocol before tenancy enforcement action. It had not identified a smell of urine on the balcony. It said it was keeping an open mind as to the substance that had been thrown.
- It had not been able to establish specific incidents where unlawful discrimination had taken place. It invited the resident to provide such evidence.
- While it had explored sealing off the balcony, it was not possible to do so.
- The landlord provided a second stage two response to the resident on 21 June 2024. In this response, it offered £500 in compensation for providing misleading information to the resident regarding the cleaning that would be done in the block while works were being undertaken. This was because although the landlord had previously denied discussing the resident collecting the liquid substance the neighbour had poured over his balcony (named by the landlord as “Operation Blueberry”), it acknowledged these discussions had taken place.
- The landlord acknowledged that the resident was provided erroneous information about the communal cleaning while the windows were being replaced. However, it maintained cleaning was suspended temporarily in each of the blocks; and it was not just his block affected.
- When the resident approached the Ombudsman, he said he had been caused distress, anxiety and frustration as well as uncertainty and raised expectations due to the landlord’s handling of the ASB. He said he had a strong sense of having been treated differently to others for no apparent reason. He wanted staff reprimanded where they had not acted properly. The resident also told us that the neighbour had passed away earlier this year.
Assessment and findings
Scope of the investigation
- This report has looked at events from June 2023 – when the resident started making fresh reports of ASB against the neighbour and 21 June 2024 (when the landlord issued its second stage 2 complaint response). The Scheme explains at paragraph 42.a that the Ombudsman may only look at matters that have exhausted the landlord’s complaint procedure. In the interest of fairness, the scope of this investigation is limited to the issues raised during the resident’s formal complaint. This is because the landlord needs to be given a fair opportunity to investigate and respond to any reported dissatisfaction with its actions prior to the involvement of this Service.
- We are aware that the resident has other complaints with the landlord including about its handling of his community trigger referral. If he remains dissatisfied with the landlord’s final response to his concerns, he may be able to refer the matter to the Ombudsman as a separate complaint at that stage.
- The resident mentions that his health and mental health have been affected by the events complained about. The Ombudsman does not doubt the resident’s comments regarding their health, and we understand this has been a difficult time for him. However, this Service is unable to draw conclusions on the causation of, or liability for, impacts on health and wellbeing. Matters of personal injury or damage to health, their investigation and compensation, are not part of the complaints process, and are more appropriately addressed by way of the courts or the landlord’s liability insurer as a personal injury claim. However, we can consider any distress and inconvenience the resident may have experienced as a result of errors by the landlord as well as its response to the resident’s concerns about his health.
- This Service does not have the power to decide whether a landlord has breached the Equality Act 2010. Only the courts can make that decision as these are legal matters which sit outside the landlord’s complaints process. However, we can decide whether a landlord has properly considered its duties under the Equality Act whereby it would be expected to offer reasonable adjustments to assist disabled residents with using its properties and services.
- It is not within the Ombudsman’s remit to reprimand staff of the landlord. Issues that concern terms of employment or other personnel issues are not within our jurisdiction under paragraph 42.h of the Scheme. We will consider how any staff conduct issues affected the resident and whether the landlord did enough to put right any errors for the resident.
- To protect the privacy of the neighbour, we have not included details in this report of all the action taken by the landlord in relation to the ASB reports. However, we have commented below on whether the landlord’s overall actions regarding the ASB were reasonable in view of all the circumstances.
The landlord’s response to reports of ASB
- The council’s ASB policy applies to reports of ASB made it in its capacity as social landlord. It explains that ASB is used to describe a variety of problems which can cause nuisance, annoyance, harassment, alarm or distress. It says it will take active steps to investigate whether any antisocial act might be motivated by hate and will treat any incident as a hate crime if and where the victim perceives it as such. This is in line with its equality and inclusion policy. It says its focus is on reducing the harm caused to the victim and communities, as well as provide support where a perpetrator has vulnerabilities that cause, or contribute to, the situation.
- The policy says that the landlord will provide a service focussing on the victim by assessing the impact on people and tailoring support based on individual needs. It will keep in regular contact with victims and witnesses throughout the investigation. It will ensure they understand what action it is taking and why. It adds it will give advice, support and guidance throughout its investigation.
- There is no evidence that the landlord acted on the resident’s first report of ASB on 19 June 2023 until after contact from the police requesting a joint visit to the neighbour. We note an earlier report is referred to in the resident’s community trigger referral from 2 June 2023. The resident provided a copy of this report at review stage, and the Ombudsman notes this should have been provided by the landlord for the investigation. A recommendation for it to review its record keeping practices has been made accordingly. While the landlord’s ASB policy does not give timescales for action to be taken, the delay in this instance was not reasonable.
- It would have been appropriate for the landlord to have taken prompt action in this instance because it potentially involved a category one hazard under the Housing Health and Safety Rating System (the HHSRS). The landlord has a responsibility to keep a property free from category one hazards, including the protection from infection. Guidance for the HHSRS identifies causes include the discharge of untreated foul waste onto paths/gardens. It would have been appropriate for the landlord to have taken action as a matter of priority when this was initially reported to it. This should have been of particular importance given the landlord’s knowledge of the resident’s physical health and his likely consequent impaired immunity.
- The landlord also did not act appropriately because it did not carry out a risk assessment. It told the Ombudsman that it did not do so because, whilst the situation was deeply unpleasant, it was not requiring a risk assessment and risk mitigation to reduce the risk to a victim. The ASB policy says that ‘it will carry out an initial assessment which takes into consideration the needs of the victim to determine the most appropriate action’. The policy does not suggest any discretion, and this was therefore a failing. If the landlord had carried out a risk assessment it may have given it a greater understanding of the potential risk to the resident from possible urine thrown onto the balcony.
- In relation to the ASB itself, the landlord acted appropriately by investigating the issues in line with its policy, which says it will seek both sides of the story to get the facts of the situation. The landlord showed the neighbour the video the resident had provided. They denied that the substance thrown over the balcony was urine and said that it was a mix of bleach and water to clean pigeon droppings. The landlord noted that it had not been able to prove whether or not this was the case.
- The landlord also acted appropriately by giving the neighbour verbal and written warnings about his behaviour and he agreed to stop throwing liquid onto his balcony and that he would not pour any urine down the kitchen sink, because both of those caused a nuisance to other people. This step was in line with its ASB policy which says that it will take action which tries to resolve issues at an early stage before considering legal action.
- There was conflicting information about the substance thrown over the balcony – whether it was urine or bleach and water. Given the limited number of recent occurrences, as well as the neighbour’s undertaking to stop throwing any substances over the balcony, it was reasonable for the landlord not to take action to try to identify what had been thrown. We have seen no evidence that the landlord asked the resident to try to find that out himself.
- The evidence suggests that the neighbour had shown this type of behaviour previously and previous warnings given. In this case, the landlord’s communication with the resident about the ASB could have been more open about what was causing the odours experienced by him and other residents in the block and what action it was taking to try to prevent them from happening again (while still protecting the neighbour’s privacy in this evidently sensitive case).
- We are satisfied that the landlord’s handling of ASB in terms of the neighbour was reasonable. The evidence suggests that it carried out at least 10 visits to them in the period from June to the end of October 2023 to ascertain what had happened; encouraging the neighbour to have the property deep cleaned and use a regular cleaner; and jet‑washed their balcony. It also put air fresheners in the communal area to try to eliminate any odours. The landlord also worked with other agencies including the police to try to resolve matters. The neighbour was also vulnerable, and the landlord had an obligation to balance its obligations towards them with their obligations towards the resident under the Equality Act.
- The landlord’s ASB policy says that it will treat any incident as a hate crime if and where the victim perceives it as such. The resident made it clear in his correspondence with the landlord in early August 2023 that he believed the neighbour was carrying out ASB as a result of his sexuality. It would have been appropriate for the landlord to have confirmed it was treating these incidents as hate crimes in line with its policy. We note, however, that its policy does not set out that the handling of a hate crime is different from that of any other type of ASB.
- While similar incidents had happened previously, given the landlord focus on the victim in its ASB policy, it would have been appropriate for the landlord to have visited the resident to see what he was experiencing (in particular how it was affecting his use of his balcony) and consider what could be done to potentially lessen the impact on him. We note the landlord saw the resident on 10 July 2023 outside the property, but it was not clear that that was a planned meeting nor that the landlord went out on to the balcony. The landlord’s offer of a single point of contact was appropriate and in line with its ASB policy. It would also have been appropriate for it to have signposted the resident to further sources of help such as victim support.
- While there was communication with the resident about the action been taken in relation to his reports of ASB, given the focus on the victim in its ASB policy, more regular updates would have been appropriate particularly in August 2023 and October 2023 when the level of contact reduced.
- The landlord turned down the resident’s request for his balcony to be sealed off on the grounds that it might affect drainage. The resident asked it to reconsider, and it said it had asked its repairs team to visit and give him options to protect the balcony. We have seen no evidence that this took place and in the stage 2 complaint response said that it was not possible to seal off the balcony with no further explanation. It would have been reasonable for the landlord to have explored this further with the resident even if there were limitations on what could have been achieved and ultimately it might still decide not to seal off the balcony.
- There was a lack of urgency by the landlord in taking steps to try to reduce the evidently distressing situation for the resident. For example, in the jet washing of the neighbour’s balcony and his report that the odour was getting worse. The landlord’s response was that it would arrange a visit “in a week or so”. We understand that the balcony was jet washed on 13 October 2023. Given the nature of the ASB, it would have been reasonable for this to have happened much sooner.
- In terms of the offer of £500 made by the landlord in the stage two response of June 2024; the evidence suggests this was for providing misleading information to the resident regarding the cleaning that would be done in the block while works were being undertaken. The landlord acknowledged that the resident was provided erroneous information about the communal cleaning while the windows were being replaced. However, it maintained cleaning was suspended temporarily in each of the blocks; and it was not just his block affected. The contradictory information the resident was provided with likely exacerbated his feeling that the cleaning had been cancelled as a response to his complaint.
- It was appropriate for the landlord to apologise and compensate the resident for the failings it acknowledged in the response of 21 June 2024. Having reviewed the amount awarded by the landlord, I find this was adequate to provide redress for these failings. However, a finding of reasonable redress cannot be made, as the landlord did not offer any redress for its failure to follow up on the resident’s concern about cleaning in the block, its ASB handling failures or the impact of failing to make adequate reasonable adjustments for the resident.
- The Ombudsman’s role is to provide fair and proportionate remedies where maladministration or service failure has been identified. In considering this the Ombudsman takes into account our Dispute Resolution Principles: Be Fair, Put Things Right and Learn from Outcomes as well as our own guidance on remedies. Consideration of any aggravating factors (such as a resident’s mental or physical health condition) may justify an increased award to reflect the specific impact on the resident.
- The failings identified above have identified that the landlord did not always follow its ASB policy and demonstrated a lack of urgency, communication and support for the resident. This evidently caused him inconvenience and distress. Financial compensation of £300 is appropriate for this impact on the resident a period of over four months. This sum takes into account the vulnerabilities of the resident which meant the ASB and the landlord’s handling of it would have had a more severe effect on him compared to other residents in the same position without his vulnerabilities.
- The sums awarded in this report are in line with the Ombudsman’s Remedies Guidance (published on our website) which sets out our approach to compensation. Awards in this range include cases where there have been failings in handling reports of ASB which had an impact on the resident, causing distress and/or inconvenience.
The landlord’s response to reports of discrimination, including a failure to make reasonable adjustments
- The landlord’s guidance note on the Equalities Act 2010 and Human Rights Act 1998 says that there is a duty on it to make reasonable adjustments. The landlord told us it was aware of the resident’s dyslexia.
- We can see from the resident’s first community trigger referral that he referred to his learning disabilities and said he was struggling to fill that form in. He said the landlord was “trying to make it as difficult as possible” to report incidents. He said that this added “more stress” to the situation because he had to “struggle to do online reporting”. The evidence shows that the resident had stated he had learning difficulties in his emails to the landlord the previous year.
- The landlord did not provide a copy of any vulnerability policy or strategy to the Ombudsman, nor could we find copies on its website. A recommendation has been made for it to consider introducing these documents. In line with our Spotlight report on Attitude, Respect and Rights these should be co-produced with residents, and consider any future good practice guidance published by the Ombudsman, following engagement and consultation.
- We have seen no evidence that the landlord sought to act on the concerns raised by the resident in relation to his disabilities. In its stage 2 complaint response, the landlord put the onus on the resident to contact it. This was not reasonable. The landlord did not act appropriately by recognising and responding to the resident’s request for reasonable adjustments. Landlords need to ensure they act with empathy and respect and are proactive in offering reasonable adjustments such as offering and receiving information in different formats. A further recommendation has been made for the landlord to consider introducing a specific reasonable adjustments policy to help it to ensure similar issues do not occur in future.
- The resident also raised concerns about the meeting of 9 August 2023 which had been set up following his allegations that he was being discriminated against by both the neighbour and the landlord on the basis of his sexuality. We consider it reasonable for the named manager to have set up a meeting with him to explore this further. Although they had written the stage one complaint response, they had not been involved in the day-to-day handling of the ASB reports. However, once the resident had raised concerns about this meeting and said that his concerns were also directed at that manager’s team, it would have been good customer service for the meeting to have taken place with a different manager if possible. If this was not possible, the landlord should have explained the reasons why to the resident.
- In line with the Ombudsman’s remedies guidance as referenced above, financial compensation of £250 is appropriate for the evident frustration and distress caused to the resident by the landlord’s failure to take account of the resident’s concerns about discrimination or to make reasonable adjustments.
The landlord’s response to concerns about communal cleaning
- The landlord’s estates service cleaning standards for low-rise buildings says that the entrance lobby and all accessible glazing and paintwork will be cleaned on a weekly basis. It also says that all ledges and edges will be dust free.
- The landlord said it would contact its estates team about cleaning following its meeting with the resident on 9 August 2023. We have seen evidence that it did so the same day but have not seen any response from the team. Given that later that month the resident raised incidents involving a second potential category one hazard, it would have been appropriate for the landlord to have chased this matter up with its estates team to find out the extent of any problem and what steps it was taking to ensure the areas were kept hygienic, if appropriate. The failure to respond to this substantive issue – which was a potential risk to the resident’s health – was a failing.
- The resident was also concerned that, once this matter had been raised, the cleaning in the block stopped completely. In its complaint response, the landlord explained that cleaning in the block had stopped because of building work and had resumed in early September 2023. It concluded that the work did not stop because he had raised concerns.
- The landlord provided us with the weekly cleaning monitoring logs. The log for the week starting 14 August 2023 notes “works going on. Couldn’t clean”. For the weeks starting 21 and 28 August 2023 the logs note “works going on. Couldn’t gain entry”. These logs also evidenced that cleaning did not take place in other blocks over this period because of building works and resumed the week starting 4 September 2023. We are therefore satisfied that there is no link between the resident’s complaints and cleaning work not being completed in August 2023.
- In line with the Ombudsman’s remedies guidance as referenced above, financial compensation of £200 is appropriate for the evident frustration and distress caused to the resident by the landlord’s failure to follow up on his concern about cleaning in the block.
The landlord’s handling of the associated complaint
- The landlord has a 2 stage complaints procedure. It aims to respond at stage one within 10 working days and within 20 working days at stage 2. The policy says that, where this is not possible, in the case of particularly complex investigations for example, it will ensure the resident is kept informed of progress.
- The landlord’s handling of the complaint was not appropriate. Responses at both stages were late – 2 weeks at stage one and over 8 weeks at stage 2. Furthermore, the landlord should not have treated the report of ASB on 19 June 2023 as a formal complaint. Landlords should be able to distinguish between a service request, where a resident may be unhappy with a situation that they wish to have rectified such as ASB, in this case, and a complaint about the service they have received.
- When the resident raised complaints about discrimination in his escalation requests, the landlord should have raised a new stage one complaint at that stage, rather than deal with this issue at stage 2. Only allowing one response to a complaint will be unfair if this does not allow sufficient opportunity for residents to respond to the landlord’s position, particularly where this includes information that may be new to the resident. Having a further stage allows for a review at a more senior level, bringing a wider perspective and level of expertise to a complaint, and may ensure full consideration of both sides of a complaint. Such senior reviews also provide an opportunity for landlords to spot patterns, nip issues in the bud and to learn from outcomes.
- While the landlord apologised for its delays, it did not consider whether a remedy was appropriate for any wider impact on the resident. In line with the Ombudsman’s remedies guidance as referenced above, financial compensation of £100 is appropriate for the evident frustration and inconvenience caused to the resident by these complaint handling failings.
Determination
- In accordance with paragraph 52 of the Housing Ombudsman Scheme there was maladministration by the landlord in respect of its response to the resident’s:
- Reports of ASB.
- Reports of discrimination, including a failure to make reasonable adjustments.
- Concerns about the communal cleaning.
- Associated complaint.
Orders
- The landlord shall take the following action within 4 weeks of the date of this report:
- A senior manager to apologise to the resident. The resident should be consulted about how he would like to receive that apology – either in person or in writing.
- Pay the resident the sum of £850 made up of:
- £300 for the impact of ASB handling failures
- £250 for the impact of failing to make adequate reasonable adjustments for the resident.
- £200 for the impact of failing to follow-up on the cleaning in the communal areas of the block.
- £100 for the impact of the complaint handling failures.
Recommendations
- We recommend the landlord takes the action to introduce the following:
- A vulnerability policy and/or strategy. In line with our Spotlight report on Attitude, Respect and Rights these should be co-produced with residents, and consider any future good practice guidance published by the Ombudsman, following engagement and consultation.
- A reasonable adjustments policy.
- The landlord should also review its record keeping practices to ensure they are sufficient.