Hightown Housing Association Limited (202101957)

REPORT

COMPLAINT 202101957

Hightown Housing Association Limited

19 June 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

The complaint is regarding the landlord’s response to concerns the resident raised about the temperature within his property.
This investigation has also considered the landlord’s handling of the resident’s complaint.

Background and summary of events

Background

The resident is an assured tenant of the landlord, a housing association. He has resided at the property, a two-bedroom first floor flat, since 2015. The property is a new build block, located within a conservation area.
The tenant is deaf and uses British Sign Language (BSL) as his first language. The landlord has advised it was made aware of this at the beginning of the resident’s tenancy.
An appendix to the resident’s tenancy agreement (“Estate Regulations – Flats”) states that he would require permission in advance for “any alterations or improvements to your home”. It advises that permission “will be granted where reasonable – regulations and restrictions apply”.
The Department for Communities and Local Government (DCLG) issued guidance for landlords in 2006 regarding the Housing Health and Safety Rating System (HHSRS). Within the guidance it identified ‘excess heat’ as being a hazard and defined this as conditions which pose a threat from ‘excessively high indoor temperatures’. It noted that there was likely to be an increase in ‘thermal stress…cardio vascular strain and trauma, and…strokes’. It noted that mortality ‘increases in temperatures over 25°c’.
The landlord’s Allocations and Lettings policy notes that “in some situations it may be necessary to transfer a tenant on management grounds”. Point 8.2 of its policy notes that “all requests for a move on management grounds must be referred to the Head of Housing for consideration”.
The landlord has a two-stage complaint procedure, although this is proceeded by what it refers to as an “informal Early Resolution Stage”. It advises it will provide a response at the Early Resolution Stage within 10 working days but if a resident remains dissatisfied, it will log a “formal complaint”. This will be responded to by a Senior Manager within 15 working days. Complaints can be further escalated for consideration by either a director or the landlord’s Chief Executive, when a response will be provided within 20 working days.

Scope of investigation

In correspondence with the landlord and this service, the resident has referred to a number of health issues affecting his family and advised that he believes these are exacerbated by the reported high temperatures in his property. However, the Ombudsman cannot determine whether there is any causal link between the reported health conditions and any action, or lack thereof, of the landlord although this investigation has taken the resident’s comments into account as part of the overall assessment of the complaint.

Summary of events

On 19 July 2018, the landlord emailed the resident following a visit to his property the previous day. It noted it had discussed “the window in the front room not opening sufficiently” and advised a repair order had been raised and should be completed within 20 working days.
The resident subsequently chased the landlord for an update regarding the window. The landlord replied on 14 September 2018 to clarify that its window contractor had attended the property but had reported that the current window restrictors could not be altered due to the style and position of the window. It advised that due to Health and Safety legislation the restrictors were required to prevent children falling should they be opened further and therefore “nothing more” could be done. The resident replied on the same day to stress he understood the window could not be opened any further, but the issue was his property was “too hot even in winter”. He advised the temperature in the property sometimes reached 38°c “all day” and this was not healthy.
On 17 September 2018, the landlord emailed the resident to clarify that “the window sizes and location are part of the design of the building” and noted that these had been “approved” by the planners. Therefore, “nothing…can be done any further in this regard”. It advised the resident of other steps that could be taken to alleviate the situation other than “putting in for an exchange to another property”. These included:
1. Keeping blinds and curtains closed.
2. Using a ceiling fan.
3. Filling a mixing bowl with ice and placing this in front of a large fan.
4. Dipping his feet in a bowl of cold water or filling a hot water bottle with cold water.
5. Turning on his bathroom fans.
6. Investing in buckwheat pillows as they do not absorb heat in the same way as cotton pillows.
The resident replied the same day to state he did not feel the landlord understood just how hot his property was, and to advise the solutions offered did not “work for (him)”. He further stated that his Housing Officer had previously visited the property and conceded that it was “too hot”.
Records show that, on 9 December 2019, the local authority’s Environmental Health (EH) team emailed the landlord having been contacted by the resident three days earlier. The EH team advised the resident had reported his property was too hot and enquired whether the landlord could do anything “on his behalf”, suggesting that “even the temporary solution of providing portable air conditioning may be of use”.
On 11 December 2019, the resident submitted a complaint via the landlord’s website. He noted that his property was “constantly hot” and was “unbearable”. He advised he had complained “several times…yet I’m told nothing can be done to improve the situation”. He concluded that, as he had been told there was no way of resolving the problem, as a resolution to the complaint, he would like the landlord to grant a management transfer to a new property. This investigation has not seen evidence that the complaint was formally responded to.
Internal landlord correspondence on 12 December 2019 showed that following contact from the EH team, it discussed whether it had been determined if the property was “actually excessively hot”, whether “temperature results from this property” had been obtained, or whether it had left a “data logger in the property to see the temperature over a period of time”. It noted that readings previously taken (date unknown) had not been kept and data logging had yet to take place.
Records show the resident submitted a further complaint to the landlord on 15 July 2020. In his complaint, he raised the following concerns:
1. There had been a “lengthy and ongoing issue with the temperature in (his) flat” and, despite complaining to the landlord over “a very long period of time” the situation had not been resolved.
2. The property was “stifling” even during winter months and “unbearable” in the summer. He had recently had to leave the property and stay with a friend as the excess temperature was unhealthy and exacerbating his eldest son’s mental health issues and his younger son’s eczema. He alleged that his son’s social worker had advised the property was “too hot for him” a few years ago.
3. It was not easy to keep calling the landlord to report the issue or chase a solution as he was deaf.
4. He listed a number of occasions that the landlord or contractors had attended between July 2018 and July 2020, including several occasions when he stated the landlord attended to inspect the window, despite already having established that it could not be altered.
5. He stated that in February and March 2020, contractors had visited to assess the ventilation system in the property, but any further action had not been progressed due to restrictions imposed by the COVID-19 pandemic. This was until 7 July 2020 when a further contractor advised that the boost function on the ventilation system was broken, but reportedly advised that this would likely not improve the situation anyway as the system was designed to filter the air, rather than control temperature.
6. He advised that he did not feel the landlord appreciated how difficult it was, as a deaf person, to communicate with the multiple people attending the property and being expected to use the phone. He would be staying away from the property until September 2020.
On 29 July 2020, the landlord provided a response to the resident’s complaint. It stated it understood the complaint to be about the fact the resident’s property was “consistently hot” and that he had reported the matter “over a long period of time”, but the landlord had taken “no action to resolve this (matter)”. It made the following observations and findings:
1. Its records indicated the resident had first reported an “issue in respect of the windows” in the property in July 2018, regarding the fact they “could only be opened slightly” and requesting an inspection to see if this could be altered. It advised there had been “multiple contractor visits” and noted that the resident acknowledged he had been advised “these could not be adjusted any further” and that he had been given an “explanation as to why this was the case”.
2. Its first recorded contact in relation to “heat and ventilation unrelated to windows” was February 2019. It advised that, following this, it requested a specialist company to “look into” the matter and subsequently an order was raised in May 2019 for a specialist contractor to “establish if additional extraction (a vent) could be fitted in respect of your concerns”. It clarified that “as this (the location around the resident’s property) is a conservation area this would not be feasible”. It stated that “further contractors” attended to establish if any amendments could be made to the windows but “again unfortunately this does not seem feasible”.
3. In February 2020, an order was raised for a further specialist contractor to attend and investigate “the possibility of installing a system that would aid you in this matter” but this was delayed due to the COVID-19 pandemic. It apologised for the delay but noted the resident confirmed a contractor had attended in July 2020 “to investigate the feasibility of installing additional ventilation”. It noted the resident’s complaint email had advised the contractor told him there was an issue with the boost function on his current extractor fan and, following this, an order was raised for a contractor to carry out a repair.
4. Following the resident’s complaint, it had discussed the actions taken so far and chased its contractor for their “report into your property” and their “findings and recommendations”. It advised it was also considering “another device from a different company as an alternative solution” and would contact him again within two weeks with an update. However, it clarified that it considered the property to be habitable.
5. It concluded that it had “actioned your requests on multiple occasions” but acknowledged that, due to COVID-19, “the time taken on this matter is longer than (it) would normally expect”. It apologised for the delay and inconvenience this had caused. It also provided a number the resident could call if he remained unhappy with its response and wished to escalate the complaint.
The resident responded to the landlord on 8 September 2020. He made the following comments:
1. The contact dates/dates of reports the landlord had referred to were “not complete” and he had intended to report issues with the temperature of the property in 2016 but had been unable to do so due to personal circumstances.
2. He reiterated he always had to chase the landlord for updates following visits and inspections, rather than it getting back to him. This included the landlord advising him on 20 August 2020 that it would be in touch the following week but to date he had not received further contact.
3. Each visit from a contractor “leads nowhere” and he did not consider that there was a solution to the issue. He acknowledged the landlord had investigated the boost function on his ventilation system but reiterated that this would not help with regulating the temperature, especially in hot weather.
4. He disagreed with the landlord’s conclusion that the property was habitable and considered that the landlord’s citation of COVID-19 as the reason for the delay in addressing the issue was an “excuse” as the situation had been “going on a long time” before the pandemic.
5. It was “insulting and disruptive” for the landlord to keep sending different contractors and he felt it was not listening to him or properly considering to his complaints. He requested a “satisfactory solution” be found by 30 October 2020 or the landlord should provide alternative accommodation.
The resident emailed the landlord regarding the issue again on 23 March 2021. He advised the overheating in his property was caused by the sun shining on the living room “for most of the day” and as a result the property stayed warm due to a lack of adequate ventilation. He proposed three potential solutions: for the landlord to repair the extraction fan in his kitchen as this had yet to be done (despite an operative attending in November 2020 and the landlord subsequently advising it would “be in touch”); to fit shutters or a canopy to the outside of the living room window to reduce the amount of sunlight, and subsequently heat, entering the property, or; installation of an air conditioning unit in the living room. The resident advised that, as a single parent in receipt of benefits, he was unable to personally fund any of the options set out and requested the landlord consider providing some, or all, of the measures listed.
On 23 April 2022, the resident referred his complaint to this service. He advised that temperatures in his property can reach “up to 40 degrees…from morning to evening” and that the excessive heat affected the mental and physical health of him and his family. He stated that he believed his situation was being “overlooked” by the landlord because he was deaf. In order to resolve the complaint, he reiterated the three options he had given the landlord in his email of 23 March 2021 but noted that he was unable to afford these options himself.

Assessment and findings

The landlord’s response to concerns the resident raised about the temperature within his property

Although the complaint response sent by the landlord in July 2020 advised it first became aware of concerns regarding the temperature of the resident’s property in February 2019, records seen by this investigation show the resident raised the issue directly with the landlord at least as early as September 2018. On 14 September 2018, the resident advised the “problem is this home is too hot even in winter” and noted the internal temperature could reach 38°c. Following further correspondence with the landlord, he emailed again 3 days later to advise the suggestions it had made to address the issue were “not working” and queried whether the landlord understood “how…’HOT’ my home is?”, stressing it was “very very hot” and referring to a visit from his Housing Officer who had apparently confirmed this.
Landlord records indicate that, following the resident’s latter email, it advised him “there is nothing further we can do in this regard other than what has been suggested”. These suggestions included keeping blinds closed, installing a ceiling fan, placing a bowl of cold water in front of a fan, the resident placing his feet in a bowl of cold water, using bathroom extraction fans and purchasing a different type of pillow that did not absorb the heat as much. While in isolation these were not unreasonable suggestions for the landlord to make, and its position that the building’s design had been signed off by the developers was not unreasonable, its records do not make clear exactly what enquiries it had made at this stage before concluding there was “nothing further” it could do. There is also no indication that the landlord considered whether it would be appropriate to assist the resident with the installation of a ceiling fan, or the purchase of another type of fan. This is not appropriate and means the landlord is not able to evidence that it took reasonable steps to address the concerns the resident raised at this time. The suggestions made also did not appear to indicate that the landlord appreciated the seriousness of the situation the resident was describing and, in the Ombudsman’s opinion, could not be expected to reasonably provide effective remedies or relief from the kind of temperatures the resident had reported.
Following further communication from the local authority’s Environmental Health team, internal landlord correspondence shows it sought to establish whether the resident’s property was “actually excessively hot” and whether it had obtained temperature results from a data logger which would show “the temperature (in the property) over a period of time”. Records show an Estates Quality Inspector advised they did not have “the temperature readings from the first time I went out anymore” and no data logger had been left. The correspondence seen by this service does not make clear when the landlord first took temperature readings from the property and its repair records do not make any reference to such an attendance. This raises concerns regarding the landlord’s record keeping and the level of detail they contained, and it was not appropriate that the temperature readings taken from this first visit were apparently not retained. This means the landlord is unable to fully evidence whether it took reasonable steps to respond to the issue at this time or that it made appropriate enquiries to try and establish whether the property was, in its own words, “actually excessively hot”.
Following this, records indicate the landlord did carry out a data logging exercise at the resident’s property in February 2020. Records seen by this investigation indicate that, between 6 and 12 February 2020, the average temperature in the resident’s property (while his heating was not in use) was 23.7°c, with a low of 21°c and a high of between 25 and 26°c. This indicates that, while the average temperature logged was in the low 20s, the landlord had established that even during Winter/Spring, the temperature in the property could reach over 25°c, which would be defined as a hazard to the resident’s health under the HHSRS. Having established this, the Ombudsman would have expected the landlord to, at a minimum, carry out further data logging exercises at regular intervals over a longer period of time, particularly during the summer months when the resident reported the property became much warmer. It should also have carried out a formal hazard assessment, in line with the HHSRS, either by itself or in conjunction with the local authority’s Environmental Health team. That it did not do either was, in the Ombudsman’s opinion, a significant failing.
The Ombudsman is careful to stress that it is not within this service’s remit to determine whether the property is habitable or not. However, it remains the case that, having apparently carried out no further tests or enquiries regarding the internal temperature of the property, it is unclear how the landlord satisfied itself the property was habitable, as it advised the resident in July 2020, and what evidence this conclusion was based on.
While the evidence available shows that the landlord did consider at various stages whether it could make alterations to the property such as installing an additional ventilation system, a cooling system or fixed air conditioning unit or external shutters, it ultimately decided these solutions were impracticable due to a combination of cost and planning restrictions related to the conservation area. Internal communication following the resident’s complaint shows it also considered whether it could provide the resident with a portable air conditioning unit as a goodwill gesture but again decided not to do so.
While cost and planning implications were considerations it had to take into account, given the conditions the resident was reporting and the length of time he had been reporting them, in the Ombudsman’s opinion the landlord should have given further thought as to what could improve the situation. Having noted that portable air conditioning units were “relatively cheap” and could provide a temporary solution, and having been advised by the resident that he was on benefits, it could have chosen to use its discretion to provide one. It could also have considered alternative measures such as contributing towards the purchase of internal blinds and/or blackout curtains if it considered that installing shutters or blinds to the exterior of the building was not possible due to planning issues.
From the information available, other than the advice given in September 2018, the sole action taken by the landlord to address the conditions within the resident’s property was to raise an order to repair a broken boost function on the kitchen ventilation system. This is despite the fact the resident raised concerns – which were acknowledged by the landlord in internal correspondence – that this would not improve the situation much as it merely extracted air, rather than cooled it. It is also noted that, in correspondence with the resident in August 2020, the landlord advised that, once the boost function had been repaired “(with) regards a more permanent solution, we are looking into other options”. This demonstrates that the landlord accepted the repair would not resolve the issue to the resident’s satisfaction and a more permanent solution would still be necessary. However, the landlord then later advised the resident that other alternative solutions were not possible, meaning it was prepared to leave the resident without a final resolution.
Regardless of this, having raised an order to repair the broken booster function in July 2020, this was not completed. While it is acknowledged that at this time there were restrictions and limitations caused by the ongoing COVID-19 pandemic, there is no explanation for the delay in the landlord’s records or correspondence. This again raises concerns regarding its records and handling of the repair. Records show a further order was raised in April 2021 and indicate the boost function was fixed in May 2021. This is some 10 months after the original order was raised, which amounts to an unreasonable delay.
It is also noted that the resident, in his original complaint of December 2019, requested the landlord arrange a management transfer to a different property if there was “no way of resolving the problem”. There is no evidence that the landlord ever gave the resident a formal response to this request. After he raised the possibility again in his subsequent complaint, internal landlord correspondence on 15 and 22 July 2020 variously notes that one department was “unaware of the management transfer” and that “it (the request) may have gone to housing if we were even made aware”. However, evidence shows the resident had clearly asked the landlord to consider a management move some 7 months earlier. Regardless of which department the request had been passed to, or if it had only been submitted as part of his complaint, the landlord should have given it due consideration and provided a formal response, either within its complaint response or separate to this. The records available indicate the landlord only gave brief consideration to the request in an internal email sent on 22 July 2020 when the complaints team asked if “we (are) able to offer him a management transfer”. Although it is not clear what the response to the question was, it is clear the landlord decided this was not something it would offer the resident, although it then failed to refer to this decision within its subsequent complaint response. This was not appropriate and meant the landlord did not treat the resident fairly.
The Ombudsman is not offering an opinion on whether the resident would meet the criteria for a management move, however it is noted that there is scope within the landlord’s Allocations and Lettings policy (“in some situations it may be necessary to transfer a tenant on management grounds”) for it to have considered this as a potential resolution and there is no evidence it properly did so. It also did not act in line with its policy which states that “all requests for a move on management grounds must be referred to the Head of Housing for consideration”. Again, there is no evidence that this happened which is a failing.
In the Ombudsman’s opinion, while it is evident that orders were raised and multiple contractors visited the property at various times to inspect the window and ventilation system, and to assess whether other appliances could be installed, the landlord has not demonstrated it did all it could to properly investigate the issue and seek to either improve or resolve the situation. Although in correspondence with this service in September 2021 it highlighted it had carried out temperature and humidity checks in the property, from the evidence available the Ombudsman does not consider these enquiries were proportionate to the concerns raised regarding the alleged extreme temperature in the property. It should also have given further consideration as to other steps it could take, at reasonably little cost, to improve the situation in the property, rather than solely agreeing to repair the ventilation boost function and providing advice such as buying a fan and placing cold water in front of it or buying buckwheat pillows.
It is noted that within its correspondence with this service noted above, the landlord advised installing shutters or a canopy outside the property would not be classed as a “repair” and would therefore be down to the resident to arrange, if planning permission was obtained. It also suggested the resident could purchase black out blinds. However, while the landlord was entitled to advise these would have been classed as improvements rather than repairs, in the Ombudsman’s opinion it should have shown greater understanding for the resident’s situation and done more to consider whether it could come up with a workable solution or provide further assistance to a tenant with acknowledged vulnerabilities.
It is appreciated that the landlord may have been limited in some of the steps it could take, and it was of course unable to make changes to the window or alter the fact that the property was south facing. However, its overall failure to properly investigate and address the concerns raised by the resident or come up with a workable solution to the reported high temperatures within his home amounts to maladministration. From the information seen by this investigation, the landlord has not been able to evidence that it acted in the best interests of the resident and sought to enable him and his family to make the best use of his property.
It is noted that in his complaint, the resident advised he believed that the landlord failed to appropriately respond to and address his concerns because he was deaf, and he was therefore being “overlooked”. The Ombudsman has found fault with how the landlord responded to the concerns he raised regarding the temperature in his property. Also, as noted below, this investigation has identified that some of the landlord’s communication with the resident did not take his condition into account. However, this investigation has not seen evidence that the landlord’s failure to respond appropriately was due to the fact resident is deaf.

The landlord’s handling of the resident’s complaint

Records show the resident first made a complaint to the landlord via its website in December 2019. However, there is no evidence that the landlord formally responded to this at all. Although the landlord’s complaints policy indicates that some complaints are dealt with at an Early Resolution Stage, there is no evidence that this was the case here. As such, this was a failure by the landlord and meant that the resident’s concerns were not properly addressed at the time. The resident was not treated fairly as a result and the landlord missed an opportunity to investigate matters at an earlier stage.
Following his second complaint in June 2020, the landlord issued its stage one response the following month. However, in the Ombudsman’s opinion, its response was vague and non-specific when addressing some of the resident’s concerns, particularly regarding the repeated attendances by contractors and the impact this had on the resident given his acknowledged communication difficulties. While the landlord advised that it had responded to the resident’s reports on each occasion and could not identify any failings in this regard, it did not outline the actions that had been taken each time and it did not fully address the fact raised by the resident that multiple attendances had not so far resolved or improved the situation. Confusingly, the landlord then partly upheld the resident’s complaint as it acknowledged the situation regarding the temperature in his property remained unresolved.
It is also noted that some of the information provided within the landlord’s response was inaccurate. Its response advised it had been unaware of any reported issues with the temperature in the property until February 2019. This is despite its own records containing correspondence from the resident on the matter from September 2018, some 6 months earlier, when he had advised the temperature in his home reached 38°c. It is concerning the landlord was unable to establish an accurate chronology of events from its own records and raises concerns over the quality of investigation it carried out into the complaint.
Furthermore, it was not appropriate that the landlord advised the resident, who it knew was deaf and primarily communicated via BSL, that he should call it to discuss the complaint further if he remained dissatisfied with the response. Despite the resident highlighting this in a response sent in September 2020, there is no evidence the landlord acknowledged this error or provided an apology.
Following its stage one response, the resident wrote in September 2020 to advise he remained dissatisfied. However, the landlord did not escalate the complaint to stage two and its July 2020 stage one letter appears to remain its final response to the complaint. While the landlord remained in correspondence with the resident regarding the issue after this time, it has advised this service that the resident failed to request an escalation within 20 working days, as per its policy. However, it is unclear whether the resident was advised of this decision at the time. Although the landlord did act in line with its stated policy, the Ombudsman considers it would have been best practice to exercise its discretion and escalate the complaint. Given the resident’s evident dissatisfaction and the fact the landlord had acknowledged the situation remained unresolved, escalating the complaint would have ensured the resident was treated fairly and demonstrated the landlord remained committed to finding a resolution. However, having decided not to escalate the resident’s complaint as his request had been made out of time, it should have clarified its position and done so in writing as per its policy. This would have managed the resident’s expectations and ensured he knew where he stood regarding the status of his complaint.

Determination (decision)

In accordance with paragraph 52 of the Housing Ombudsman scheme, there was maladministration regarding the landlord’s:
1. Response to concerns the resident raised about the temperature within his property.
2. Handling of the resident’s complaint.

Reasons

While the landlord did carry out some investigation into temperature within the property, these were insufficient and would not have allowed it to reasonably establish the property was habitable. The repair order it did raise was then not completed for an unreasonable length of time and it remains unclear why this happened. It should also have given further consideration to other potential solutions, or whether it could have contributed towards the purchase of, or installation of, alternative remedies. It should also have given proper consideration to the resident’s request for a management transfer if alternative solutions were not possible, which the landlord determined was the case.
The landlord failed to provide a response to the resident’s initial complaint. While it responded within a reasonable timeframe to his subsequent complaint, its reply was vague, did not address all of his concerns and contained factual errors. It failed to acknowledge its error when asking him to use an inappropriate method of communication and there is no evidence that it formally advised him that it had declined to escalate his complaint to stage two of its procedure when his request came through out of time.

Orders and recommendations

Orders

The landlord is ordered to, within four weeks of this determination, pay the resident £700 compensation consisting of:
1. £500 for the failings identified in its response to the resident’s concerns regarding the temperature within his property.
2. £200 for the failings identified in its complaint handling.
The landlord is also ordered to, within eight weeks of this determination:
1. Carry out further data logging exercises to record the temperature in the resident’s property during two separate weeks in June and/or July 2023 and provide the resident and this service with the results. If the results indicate that temperatures within the property would be classed as a hazard under the HSSRS, the landlord should draw up an action plan regarding the steps it will take to address the situation and share this with the resident and this service.
2. Consider the resident’s request for a management move and provide him with a formal decision. This should include providing the resident with assistance, if required, regarding the submission of any formal application or supporting evidence.
The landlord should provide evidence to the Ombudsman regarding its compliance with the above orders within the timeframes set out above.

Recommendations

Considering the concerns noted over the quality of its repair records, the landlord should review how it logs repair related data consider the recommendations made within the Ombudsman’s spotlight report on Knowledge and Information Management (KIM), published in May 2023 and available here: www.housing-ombudsman.org.uk/wp-content/uploads/2023/05/KIM-report-v2-100523.pdf