Camden Council (202219932)

REPORT

COMPLAINT 202219932

Camden Council

29 January 2025

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 handling of the resident’s:
1. Reports of water ingress which caused damp and mould and damage to the bedroom carpet.
2. Reports of subsidence affecting the kitchen floor.
3. Reports of a rodent infestation.
4. Request to be moved to another property.
5. Reports of antisocial behaviour (ASB).
This investigation will also consider the landlord’s handling of the associated complaint.

Background

The resident is a secure tenant of the landlord which is a local authority. She has lived in the property (a 1-bed ground floor flat within a converted house) since January 2020. A leaseholder lives in the flat above.
The landlord states that the resident has not disclosed any disabilities or vulnerabilities but that she is “elderly”.
The records provided by the landlord show that the resident first reported ASB from her neighbour in August 2021. The resident however states she started reporting the issue shortly after moving into the property in 2020.
On 10 September 2021 the resident contacted the landlord and reported noise nuisance and said her neighbour had been racially abusive. She asked it to log a complaint regarding the issue (Complaint 1). We have not seen evidence that a formal complaint was logged or a formal response provided.
On 7 December 2022 the resident raised a further complaint in relation to several repair issues not explored as part of this investigation (Complaint 2). The landlord provided its stage 1 complaint response on 30 January 2023.
This Service wrote to the landlord on 17 April 2023 and asked it to provide a response to Complaint 1 including its handling of her reports of ASB. The landlord responded and provided a copy of the stage 1 complaint response to Complaint 2 which addressed complaints relating to repairs. It did not address the reports of ASB.
On 9 May 2023 the resident contacted this Service. She said she had tried to escalate her complaint regarding several issues including the landlord’s handling of her ASB reports to stage 2 of the complaint process in April and May 2023 but had received no response.
On 18 May 2023 the landlord provided its stage 2 response to Complaint 2. The response focussed on pest control issues. In relation to her reports of ASB it said:
1. She had “mentioned issues” with her neighbour and that she would report these to her housing officer as she had been racially abused.
2. It had contacted the housing officer and their manager who would contact her to discuss her concerns.
This Service wrote to the landlord on 17 July 2023. We advised the resident had informed us that she had requested an escalation of Complaint 2 in April 2023 but had not received a response. We asked it to provide a stage 2 response by 31 July 2023.
On 27 September 2023 we again wrote to the landlord and advised that the resident had not received a stage 2 complaint response. The landlord responded on 3 October 2023 and provided its stage 2 response to Complaint 2 and said it would raise a new complaint in relation to “new issues not previously raised”.
We replied to the landlord on 5 October 2023 to explain that we disagreed that the ASB issues had not previously been raised. We stated that the landlord should provide a stage 2 response addressing its handling of reports of ASB as its previous response had not formally addressed the issue.
The landlord provided a further stage 2 complaint response on 18 October 2023. In relation to its ASB handling it said:
1. The resident’s complaint regarding ASB from her neighbour had been “thoroughly investigated”.
2. She had been “unable to offer sufficient evidence of any alleged excessive noise or any racial discrimination”.
3. Her neighbour had disputed all “allegations” and had made “counter allegations” against her.
4. She had not reported the racial abuse to the police as a hate crime.
5. It was unable to uphold the complaint due to a lack of evidence.

The legal and policy framework

The landlord’s noise and nuisance guidelines published in May 2019 states that it deals with ASB on a case-by-case basis but may:
1. Visit the property to witness the noise. It notes this may be “helpful where the problem may be due to the structure of the building”.
2. Issue diary sheets to help the resident record the dates and times of the noise to help assess the extent of the nuisance.
3. Ascertain if there are “any imaginative solutions, certain repairs or improvements that might help”.
4. Recommend using the Noise App to evidence the issue.
At the time of the complaint the landlord operated a 2 stage corporate complaints policy. It said it would respond to stage 1 complaints within 10 working days and stage 2 complaints within 25 working days.

Assessment and findings

Jurisdiction

What the Ombudsman can and cannot consider is called the Ombudsman’s jurisdiction. This is governed by the Scheme. When a complaint is brought to this Service, the Ombudsman must consider all the circumstances of the case, as there are sometimes reasons why a complaint will not be investigated.
After carefully considering all the evidence, the following complaints are outside of the Ombudsman’s jurisdiction:
1. The landlord’s handling of reports of water ingress which caused damp and mould and damage to the bedroom carpet.
2. The landlord’s handling of reports of subsidence affecting the kitchen floor.
3. The landlord’s handling of reports of a rodent infestation.
4. The landlord’s handling of the resident’s request to be moved to another property.

Damp and mould, structural concerns, rodent infestation

While the serious nature of the resident’s concerns are acknowledged, paragraph 41.c of the Scheme states that the Ombudsman cannot consider complaints which, in the Ombudsman’s opinion concern matters that are the subject of court proceedings.
The Ombudsman’s view is that proceedings have been commenced once a claim form and Particulars of Claim, have been filed at court. In this case the resident’s solicitor submitted a claim form in September 2023. The particulars of the civil claim, as stated on the claim form, relate to disrepair including water ingress, damp and mould, structural concerns, and a mouse and rat infestation. The landlord has submitted a defence and the case is listed to be heard at court in early 2025.
The resident’s dissatisfaction with the landlord and its response to her concerns is noted. However, the repair issues raised in the complaint are included in the ongoing civil claim. It therefore follows that based on the evidence that has been provided to this Service, the repair and pest control elements of the complaint falls outside of our jurisdiction.

Request to be moved to another property

Paragraph 42.a of the Scheme states the Ombudsman may not consider complaints which, in the Ombudsman’s opinion are made prior to having exhausted a member’s complaints procedure, unless there is evidence of a complaint-handling failure and the Ombudsman is satisfied that the member has not taken action within a reasonable timescale.
It is accepted that the resident asked the landlord for a transfer and that the matter was considered at stage 1 of the landlord’s complaint process; we have not however seen evidence that she asked the landlord to escalate this element of her complaint to stage 2 of its process. While the Ombudsman empathises with the resident’s situation, in the interest of fairness, the scope of this investigation is limited to the issues considered by the landlord at stage 2 of its process. This is because the landlord should be given the opportunity to fully investigate and respond to the resident’s concerns.
If the resident remains dissatisfied with the landlord’s handling of her request for a transfer she should address this directly with the landlord and progress through the formal complaint process if required. If the resident remains unhappy after exhausting the landlord’s complaints procedure, she may refer the matter back to Ombudsman as a new complaint.

Scope of the investigation

Some actions in this case were taken by the environmental health department (EHD) which the landlord operates in its capacity as a local authority. This Service will only consider complaints which concern matters in respect of local authorities which relate to their provision or management of social housing. This means we will consider the actions of the housing management team but not the actions of the EHD whose actions fall under the jurisdiction of the Local Government and Social Care Ombudsman (LGSCO).

Handling of the resident’s reports of antisocial behaviour (ASB).

It is acknowledged that the resident reports being extremely distressed by the ASB that she has reported to the landlord. In cases concerning ASB it is not the Ombudsman’s role to ascertain whether the ASB occurred. Rather, it is the responsibility of this Service to assess how the landlord responded to the reports of ASB and whether its response was reasonable and proportionate in all circumstances of the case. This Service has also considered whether the landlord’s management of the ASB case was in accordance with its policies and procedures.
Between January 2020 and June 2020 the landlord contacted the resident’s neighbour several times in response to reports of noise nuisance from the resident. We have not been provided with details of the resident’s initial ASB reports. As such, it is not clear what specific reports the resident had made and whether the landlord’s actions were proportionate in the circumstances. However, it was reasonable, and good practice that the landlord discussed the reports with the neighbour.
A landlord should have systems in place to maintain accurate records so it can satisfy itself, the resident (and ultimately the Ombudsman) that it took all reasonable steps to meet its obligations. As a minimum we would reasonably expect the landlord to keep records of reports of ASB and its response.
In February 2020 both the resident and the neighbour reported ASB from each other. The landlord offered mediation but both parties refused.
That the landlord offered mediation promptly was positive. Mediation can be an extremely effective method of conflict resolution, especially in cases involving lower-level nuisance and lifestyle differences. The process can help to bring together all parties and can prevent a dispute from escalating into a more serious disturbance. It is most effective when offered early in disputes. As such, the landlord’s decision to offer mediation soon after receiving reports and counter-reports was appropriate.
The resident’s neighbour reported further ASB from the resident in August 2020. It is not clear from the records whether these reports were addressed with the resident. It would have been reasonable for the landlord to have discussed the reports with the resident so that it could obtain her comments and consider the situation further. That it didn’t was a shortcoming in its handling of the matter.
In December 2020 the resident’s neighbour reported that the resident was banging on her ceiling. She said she had first noticed it when she accidentally dropped something in the kitchen but noted that the resident responded this way to all “normal noise”.
In August 2021 the resident complained to the landlord that her upstairs neighbour was making a “deliberate noise nuisance” by banging on their floor and moving furniture. The landlord spoke to the upstairs neighbour who “[denied] all allegations” and reported that the resident was harassing her. It was reasonable that the landlord spoke to the resident’s neighbour to make her aware of the reports. This gave the neighbour the opportunity to consider whether she needed to modify her behaviour. The landlord also asked the resident to provide audio evidence of the noise nuisance.
Landlords must ensure that any actions it takes in ASB cases is reasonable and proportionate. It should also ensure that any reports of ASB can be corroborated by evidence. It was therefore appropriate for the landlord to ask for supporting evidence. The landlord failed, however, to offer any assistance to the resident in gathering such evidence. There is no mention within the contemporaneous notes that it discussed the use of the Noise App or similar with her in line with its guidance. This was a missed opportunity to support the resident and to try to resolve the ongoing ASB.
In September 2021 the resident reported further noise nuisance and said her neighbour had been racially abusive towards her. Following the report the landlord noted in internal communications that while she had previously stated that she felt her neighbour’s behaviour was racially motivated, she had not provided any “proof” of this or reported any incidents of racial abuse to the landlord or the police. It also said that it had repeatedly requested that she provide evidence of noise nuisance to enable enforcement action but she had “failed to do so”.
On 21 September 2021 the landlord telephoned the resident to discuss her report of racial abuse from her neighbour. She stated that her neighbour had told her that if she did not like noise she should move back to where she had lived previously as this was “where black people are”. She said she continued to experience noise from banging and that this stopped her from sleeping at night. The resident said she felt the noise was a deliberate attempt to “force her out of the property”. The landlord said it would speak to her neighbour and asked the resident to report the incident to the police.
It is noted that racial abuse is a hate crime and it was therefore reasonable that the landlord advised the resident to report the incident to the police. Partnership working is an important part of ASB management, we do not however consider that a resident choosing not to make a police report should in prevent the landlord from carrying out its own investigations. The police are held to a criminal burden of proof whereas landlord’s civil ASB action requires a lower threshold of proof.
The landlord did however put the report to the neighbour. This therefore suggests that it had taken some action to investigate the resident’s concerns.
The landlord visited the neighbour on 27 September 2021 to carry out an inspection of the flooring in the property. The neighbour refuted that she had made a racist comment and that she was making excessive noise. She said that the resident was making “false” claims about her. The landlord inspected the neighbour’s property and reported that it was mainly carpeted but the living room had hard flooring with rugs. It said that while the neighbour was disabled and would therefore accidentally drop object this did not happen frequently.
It was positive that the landlord carried out an inspection of the neighbour’s property to ascertain whether it had adequate floor coverings to reduce noise transmission. The Ombudsman’s Spotlight report on noise (published in October 2022 during the events considered by this investigation) highlighted that a lack of carpet and underlay in upper-floor properties contributed to noise transference. That the landlord was clearly aware of this and carried out reasonable investigations to satisfy itself that this was not the case was good practice.
The property in this case is a flat within a converted 2-storey house built (according to reports provided by the landlord) between 1880 and 1930. It is unknown when the building was converted into flats but as the landlord has referenced the neighbour having lived there for over 21 years it was likely completed before Part E of the Building Regulations came into force in the UK in 2003. These regulations prescribe acoustic insulation levels for residential buildings (including conversions) and sets decibel levels for airborne and impact noise.
Conversions such as the one in this case are not subject to these regulations, as they do apply retrospectively, and sound insulation is often poor which can lead to excessive sound transference. It is accepted that the landlord is not legally obliged to install additional insulation to this property. Its ASB guidance does however state that it will consider “imaginative solutions” such as repairs or improvements which may help. We consider that it would have been reasonable and proportionate for the landlord to investigate whether sound insulation would have been an effective solution in this case. With this being said, this Service appreciates that its lack of consideration of this was not in itself a failure since there was no obligation to do so in the first instance.
The day after the inspection of the neighbour’s property the landlord telephoned the resident. She said that there had been a reduction in the noise nuisance which she believed was due to the pre-arranged inspection. It discussed the reported racist incident and she stated that she could not remember the day and time it had taken place but that it had happened the year before and that her daughter had witnessed it. The records state that there was “very little” it could do due to the length of time since the incident happened and a lack of evidence. It asked the resident to report any further noise nuisance.
It is noted that the resident has stated that she did report the incident to the landlord at the time but we have not seen contemporaneous records of this.
It is accepted that the passage of time since the reported incident along with uncertainty about the specifics of the event would have restricted the actions available to the landlord. The resident reported however that her daughter had witnessed the incident. It would therefore have been reasonable for the landlord to attempt to contact her to verify the report and take a witness statement. That we have not seen evidence that it did so was a failing. It is noted the landlord explained that it requested the daughter’s contact details from the resident; however, she refused to provide the information. Having reviewed the evidence, this Service cannot see evidence to support the landlord’s account.
The resident reported further noise nuisance 3 months later in early December 2021. She said there was banging coming from the bedroom of the neighbour’s adult son in the early hours of the morning. The landlord contacted the neighbour who denied making any noise and stated that the resident had been banging on her wall “repeatedly”. She said that “any noise [or] vibration whatsoever [disturbed the resident] even if it [was] mild or inaudible to anyone else”.
It is important to note that people have different tolerances in relation to noise and what would constitute a nuisance to some may be acceptable to others. Whether or not a behaviour is unreasonable is dependent on many factors including: how frequent it is; at what time it is occurring; whether it is intentional; and the vulnerability or circumstances of the victim.
The landlord’s ASB guidance does not refer to agreeing an action plan with the victim, which is commonly accepted as best practice in the industry. An action plan is an agreement about what actions the victim and landlord will take next. Its failure to complete an action plan was a missed opportunity to manage the resident’s expectations.
In assessing the vulnerability of a resident and the impact of the reported ASB on them landlord’s often use a risk assessment tool. The landlord’s ASB guidance does not refer to a risk assessment. Statutory guidance issued alongside the Antisocial Behaviour Crime and Policing Act 2014 however states that landlords should assess the risk of harm to a victim, and any potential vulnerabilities, when they receive a complaint about antisocial behaviour. We have been provided with no evidence that such an assessment has been completed in this case. This was unreasonable, particularly as the resident is elderly and reported racial abuse.
We have not seen evidence of further reports of ASB from the resident until 9 months later in September 2022 when she reported that her neighbour had intentionally locked her out of the building. Following the report the landlord contacted the neighbour who said that neither she nor her son would deliberately lock the resident out and that the lock was old. She asked it to “stop blaming [her] for the door’s various dilapidations”.
It was reasonable that the landlord contacted the resident’s neighbour to put the resident’s report to her. As it did not have any evidence that the neighbour was responsible for the incident it was not unreasonable that no further action was taken. We have not however seen that the landlord explained this to the resident, this was a failing and would understandably have left the resident with the impression that no action was taken in response to her report.
In October 2022 the resident again reported noise from her neighbour and stated that she was racist. The landlord’s notes state that there was no evidence to support action and that it offered mediation which the resident declined. As the landlord had not received any evidence corroborating the report it could not consider any further measures or enforcement action. Offering mediation again was proportionate in the circumstances.
On 12 December 2022 the records show that the resident contacted the EHD out of hours team in relation to the noise. She reported that her neighbour intentionally dropped things on the floor “to upset her”. The EHD advised her to keep a log of any noise.
The resident made a further report to the EHD out of hours team on 16 December 2022. The EHD attended and stated it “could hear some footsteps but nothing excessive or unreasonable”. This information was passed on to the housing officer by the EHD.
The landlord met with the resident following her reports to the EHD. Communications following the meeting show she had asked to be moved to sheltered accommodation and the landlord had agreed to support her in her application. This was reasonable and demonstrates that the landlord was attempting to support the resident.
On 26 January 2023 the resident reported further noise nuisance from her neighbour banging. She stated that others on the road were aware of the issue and the landlord asked her to provide details of witnesses so it could contact them to verify the reports. The resident was unable to provide any details.
It would have been reasonable at this time for the landlord to speak informally to other tenants on the street to see if they were aware of any noise issues in the area. We have not seen evidence that it did so and this was a missed opportunity.
The following day the resident’s neighbour reported that the resident had been “hitting the wall, floor or ceiling” every time the neighbour used the kitchen. She said she tried to use the kitchen as little as possible as “normal activities like walking, using the sink or cupboards [resulted] in a flurry of knocks on the wall”. She also reported that the resident had sworn at her son in the communal hallway that morning. We have not seen evidence that the landlord put these reports to the resident. We would reasonably have expected it to do so to give her the opportunity to put across her account.
We have seen evidence of internal landlord discussion that suggests it was influenced by issues relating to the resident’s previous tenancy. While it is understandable that the landlord wanted to give regard to historic factors and patterns in behaviour, it was not appropriate for the landlord to be influenced by this. It should have ensured that it was considering the reports on their own merits.
In late March 2023 the landlord was contacted by a support worker who was assisting the resident with her housing issues. The support worker said the resident wished to be moved and asked what the landlord was doing to resolve the ASB issues she had reported. The landlord replied to the support worker and stated:
1. The resident had not provided any evidence of excessive noise from her neighbour’s property.
2. Her neighbour had lived in the property for over 21 years “without a single complaint” until the resident moved in.
3. The neighbour had been “horrified to be accused of racism” and had stated that the resident had “harassed” her with her “continued, groundless allegations of noise complaints and unsubstantiated allegations”.
4. The resident had not reported the racist incident to the police despite being advised to do so.
5. She had a “history of making unsubstantiated accusations” and there was “no conclusive proof” that her neighbour was a nuisance.
6. It had a “strict policy for managed transfers” due to the small number of properties it let. It was therefore “unable to provide tenants with alternative housing due to unfounded claims of racism or noise nuisance”.
7. It recommended that she consider a mutual exchange or sheltered housing, both of which she could arrange herself.
It is noted that the language used by the landlord in this communication indicates that it had determined that the resident’s reports were “groundless” and that it had again based this conclusion on historic factors. This was not appropriate, nor was it appropriate that it communicated this opinion to another organisation.
On 24 March 2023 the landlord received a telephone call from a tenant who lived on the street where the resident and her neighbour lived. They said that they had not witnessed any noise issues but that the resident had told her about “banging happening at night”.
The resident made 2 further reports to the EHD in October 2023. She described her neighbour as “dangerous and racist” and had told her “no blacks here”. The EHD replied and asked the resident to contact it when the noise was happening so it could witness the nuisance and complete an assessment.
In January 2024 a representative for the resident contacted the landlord regarding the ASB. They said they had “diaries containing a record of discrimination, bullying and verbal abuse as well as intimidation” towards the resident.
Based on the evidence we have received; it does not appear that the landlord was in possession of a copy of the diaries referenced by the representative. It would have been reasonable for the landlord to request a copy to assist its investigations. That it did not was unreasonable.
The landlord replied to the representative and asked whether the resident had reported the discrimination and abuse to the police. It also agreed to meet the resident and her representative to discuss the issue. This was reasonable. The resident cancelled the meeting due to a medical appointment. The landlord contacted her representative twice in the following weeks asking if she wanted to book a further meeting but the representative declined stating that she would be making a formal complaint as the housing officer’s behaviour was “gross misconduct and unprofessional”.
The landlord replied to the representative and said it had repeatedly explained that it was “unable to carry out any enforcement action in the absence of proof of the alleged discrimination and harassment”. It said the neighbour denied the reports and that the resident had not reported the incident to the police as advised.
In April 2024 the resident reported that she had been unable to sleep due to tapping and banging from her neighbour. The landlord replied and asked to meet with her to discuss the issue. We have not seen evidence that the resident replied.
It should be noted that the landlord did carry out many positive actions in this case. Overall however it did not:
1. Demonstrate that it kept thorough records of the resident’s reports of ASB and the actions it took in response.
2. Provide support to the resident in relation to recording the reported noise nuisance.
3. Contact the resident’s daughter who may have witnessed the racist incident she reported.
4. Ascertain whether there were other witnesses to the reported noise nuisance.
5. Act in line with statutory guidance to complete a risk assessment which would have assisted it in identifying the harm caused to the resident.
6. Agree an action plan thereby missing an opportunity to better manage the resident’s expectations.
7. Base its assessment and actions only on the merits of the case and not on historic factors.

We have therefore found maladministration in the landlord’s handling of the resident’s reports of ASB.

Handling of the associated complaint.

The resident explicitly asked the landlord to raise a formal complaint (Complaint 1) in relation to its handling of her ASB reports in September 2021.
The records demonstrate that while a complaint was logged it was closed down without a response being provided. This was because the local housing management team considered that the matter was not a complaint and was being handled by the housing officer. This was inappropriate and a departure from the Ombudsman’s Complaint Handling Code (the Code).
Internal landlord communications of April 2023 show that it was aware that it had closed Complaint 1 regarding its handling of her ASB reports without proving a formal response. It stated that in future if a resident raised a complaint regarding its handling of their reports a formal response should be provided.
We would reasonably have expected the landlord to have apologised to the resident when it became aware of its failing. That it did not do so was inappropriate.
This Service asked the landlord on 3 occasions to provide a formal response to all aspects of the resident’s complaint including the ASB handling. The landlord did not address the ASB issue until its stage 2 complaint response of 18 October 2023. This was more than 2 years after the resident complained about the issue and with considerable intervention from this Service. This far exceeded the timescales set out in the landlord’s complaints policy and in the Code.
In its final complaint response the landlord stated that the resident’s ASB reports had been “thoroughly investigated”. It did not however provide any detail outlining what investigations had been carried out. This was a missed opportunity to demonstrate that it had fully considered the resident’s complaint and carried out a reasonably detailed review of its handling of her ASB case.
Overall, the landlord failed to respond to the resident’s complaint in relation to its handling of her reports of ASB for over 2 years which caused her to invest unnecessary time and trouble chasing the matter. A resident should not have to escalate their complaint to this Service in order to receive a response. The landlord’s final response did not demonstrate that it had carried out a thorough review of its ASB handling and contained no detail of any of the actions it had taken. This would have caused the resident further distress as she felt further overlooked. We consider that there was maladministration in the landlord’s complaint handling.

Determination

In accordance with paragraph 42.e of the Housing Ombudsman Scheme the following complaints are outside the Ombudsman’s jurisdiction:
1. Handling of the resident’s reports of water ingress which caused damp and mould and damage to the bedroom carpet.
2. Handling of the resident’s reports of subsidence affecting the kitchen floor.
3. Handling of the resident’s reports of a rodent infestation.
In accordance with paragraph 42.a of the Housing Ombudsman Scheme the following complaint is outside the Ombudsman’s jurisdiction:
1. Handling of the resident’s request to be moved to another property.
In accordance with paragraph 52 of the Housing Ombudsman Scheme there was:
1. Maladministration in the landlord’s handling of the resident’s reports of ASB.
2. Maladministration in the landlord’s handling of the associated complaint.

Orders and recommendations

Orders

Within 4 weeks of the date of this report:
1. A senior officer of the landlord to apologise to the resident in accordance with the Ombudsman’s remedies guidance.
2. Pay the resident £1,100 compensation which comprises:
  1. £500 for time and trouble, distress and inconvenience in relation to its handling of her reports of ASB.
  2. £600 for time and trouble, distress and inconvenience in relation to its handling of the associated complaint.
In accordance with paragraph 54.g of the Scheme the landlord is to provide the Ombudsman with a review conducted by a senior manager to ensure:
1. It keeps thorough records in all ASB cases.
2. It provides sufficient support to complainants in ASB cases in gathering audio recordings.
3. Risk assessments are completed and regularly updated in all cases in line with statutory guidance.
4. It completes sufficiently detailed action plans in agreement with the complainant to ensure that expectations are appropriately managed.
5. Staff base their assessments and actions on the merits of the case at hand and not on historic factors.

The landlord is to confirm compliance with this order within 10 weeks of the date of this report.

Within 6 weeks of the date of this report the landlord to conduct staff training to all staff involved in complaint handling. The training should cover the requirements of the Code. It should also make clear that all complaints should be formally logged and responded to within the timescales outlined in the Code and its own policy.