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North Kesteven District Council (202317892)

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REPORT

COMPLAINT 202317892

North Kesteven District Council

19 December 2024


Our approach

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

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

The complaint

  1. The complaint is about the landlord’s handling of:
    1. Reports of damp and mould and the associated remedial repairs.
    2. Repairs carried out to the driveway following reports of a trip hazard.
    3. Reports of disability discrimination under the Equality Act 2010.
  2. The Service has also investigated the landlord’s complaint handling.

Background

  1. The resident is a secure tenant of the landlord. The tenancy started on 5 August 2013. The property is a 3 bedroom house. The resident has physical disabilities, her husband has Parkinson’s disease, and her son is autistic.
  2. The resident has been reporting black mould to the landlord since at least July 2021, when she reported black mould in the kitchen. She told the landlord that the mould had ruined the flooring under the washing machine. The landlord raised a job for a contractor to attend the resident’s property on 27 July 2021 to look at the mould. The resident reported further issues with black mould in her bathroom, at the top of the stairs, and in her living room on 31 October 2022. In response, the landlord arranged for a survey to be carried out and for follow up works to be completed.
  3. The resident has told this Service that they reported issues to the landlord relating to a potential trip hazard on the driveway to their property on an unknown date. The landlord visited the property on 24 May 2023 and noted the potential trip hazard. The landlord’s contractors visited the resident’s property on 8 June 2023 to inspect the driveway and to arrange to carry out the repair.
  4. The resident’s husband raised a formal complaint on 14 June 2023. He said the work relating to the damp and mould had not been completed. He also said that the landlord was aware of a trip hazard outside the property. He told the landlord that he had Parkinson’s disease and he had already tripped over the area on two occasions. He also told the landlord that he believed he had been discriminated against due to his disability.
  5. The work to the driveway was completed on 21 June 2023.
  6. The landlord sent the resident a stage 1 complaint response on 5 July 2023. It said it had undertaken a considerable amount of work to the resident’s property over the past few months. It said it had completed damp proofing works and additional works to the kitchen. It had also removed a potential trip hazard to the driveway. It also said it could find no evidence to substantiate the resident’s claim of discrimination under the Equality Act 2010. However, to provide further reassurance on the condition of the property it had asked for a full HHSRS (Housing Health and Safety Rating System) survey to be carried out. It told the resident that an appointment would be arranged.
  7. Following escalation to stage 2 the landlord sent the resident a stage 2 complaint response on 27 July 2023. It said the mould issue was reported on 13 June 2022, and since then works had been undertaken. It said the mould report completed on 3 July 2023 showed only minor mould issues. It said it had seen photographic evidence of the trip hazard. Although it acknowledged that the work needed to be undertaken, it felt that there was a sufficient area adjacent to the trip hazard that allowed safe access to and from the property. It also re-iterated that it could find no evidence of discrimination under the Equality Act 2010. It apologised for the delays to the repairs, and it said it would reimburse the resident for the cost of paint once it had received a copy of the receipt. However, it could find no evidence of any further reimbursements due or compensation to be awarded.
  8. The resident was dissatisfied with the landlord’s response, so referred her complaint to the Ombudsman.

Assessment and findings

Scope of investigation

  1. The resident has expressed concerns regarding the impact the situation has had on the health of her family. This Service is unable to draw conclusions on the causation of, or liability for, impact on health and wellbeing. Claims for personal injury must be decided by a court, who can consider medical evidence and make legally binding findings. Where there has been a failing by the landlord, this Service may consider any general distress and inconvenience which the situation may have caused the resident.
  2. The resident has also expressed concerns that the landlord has discriminated against her family because of their disabilities. The Equality Act 2010 (the Act) provides a legislative framework to protect the rights of individuals with protected characteristics from unfair treatment. The landlord has a duty under the Act not to unlawfully discriminate against a person based on their protected characteristics. The Act prohibits direct discrimination, which occurs where a person treats another person less favourably because of a protected characteristic.
  3. It is outside the Ombudsman’s remit to establish whether the actions, or inaction, of the landlord’s staff amounted to discrimination. Allegations of discrimination are legal issues better suited to a court of law to decide. However, the Ombudsman can assess whether the landlord’s overall communication with and response to the resident was appropriate, fair and reasonable.
  4. In addition, under the Act, the landlord has a legal duty to make reasonable adjustments where there is a provision, criterion or practice which puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled. Although this Service cannot find that a landlord has breached the Equality Act 2010, we can decide whether a landlord has properly considered its duties under the Act.

Reports of damp and mould and the associated remedial repairs

  1. The evidence shows that the resident has been reporting mould from at least 19 July 2021, when she reported black mould under the washing machine in the kitchen. The landlord told the resident that its contractor would attend her property on 27 July 2021 to look at the mould. It is unclear from the evidence provided what happened as a result of the contractor’s visit.
  2. The resident reported further mould in the bathroom on 13 June 2022. It would be reasonable to conclude from the evidence provided that the landlord agreed to investigate whether the bathroom extractor fan was sufficient as a means to prevent mould forming.
  3. The resident reported further issues with mould on 31 October 2022. The resident said the mould was present throughout the bathroom ceiling, at the top of the stairs, and in the living room behind a cabinet. It is unclear from the evidence provided when the landlord inspected the resident’s property. It is also unclear whether it took any immediate action, such as completing a mould wash to the property. However, on 8 December 2022 it arranged to carry out a full damp survey of the property. The survey took place on 5 January 2023.
  4. The survey report dated 6 January 2024 found areas of perished mortar joint pointing, spalled (damaged) brickwork, stepped cracking, and leaking/blocked gutters. It also found evidence of condensation and mould growth located internally on the walls. The mould growth was consistent with high humidity levels within the property. It was noted that the external walls to the rear of the property were colder than the internal walls and walls to the front of the property. The survey also noted that there was damage and cracking to the plasterboard in the living room. There was visual evidence of penetrating damp through the external wall into the kitchen behind the washing machine. There was also evidence of mould growth and condensation on the wall surfaces. The temperature in the bathroom area in the extension was also considerably lower than other areas of the property.
  5. The survey made recommendations for the landlord to install a positive input ventilation unit (PIV) in the loft area. This was to control the condensation and mould problems within the property. The survey also made recommendations for the landlord to fit an intelligent humidity tracking extractor fan in the bathroom. In addition, the survey recommended that the landlord source its own contractor to check, clear, and repair/renew the gutters, downpipes, roof coverings, external rendering, and joinery timbers as necessary.
  6. The landlord raised some of the repairs on 12 January 2023. These were to clean and clear the guttering and downpipes to all three elevations, including the single storey bathroom, test all joints and unions for leaks, and ensure a free flow of water through the system. The landlord also raised a repair on 16 February 2023 to renew the bathroom extractor fan. It is unclear from the evidence provided why the other repairs recommended by the surveyors reported were not raised.
  7. The resident contacted the landlord again on 13 April 2023, due to ongoing issues with black mould. This was 10 months from the date the resident reported mould in her bathroom, and over 5 months from the date the resident reported mould in other areas of the property. Yet the mould issues were still apparent and the recommended repairs had not been fully completed.
  8. The landlord’s repairs priorities say that routine repairs will be completed within 20 days of being reported. It had been at least 5 months at this point since the landlord became aware of the issues with mould. It had also been over 3 months since the survey report had been completed. Therefore, as there were remedial repairs that remained outstanding, the landlord had not acted in accordance with the timeframes set. Its actions were therefore inappropriate in the circumstances.
  9. The landlord introduced a damp and mould policy on 31 March 2023. This meant that, following reports of damp and mould, the landlord would visit a property to carry out a full damp, mould, and property defect assessment within 10 working days. The assessment would be undertaken in accordance with HHSRS guidance for Hazard 1 – Damp and Mould. However, there is no evidence to show that the landlord’s approach changed to become compliant with its new policy following further reports of damp and mould by the resident on 13 April 2023. This was inappropriate in the circumstances as it meant that the resident was not given the level of response required within the policy. This also meant that the resident was not afforded the same response as other residents reporting damp and mould around the same time.
  10. It is unclear from the evidence provided exactly when the works to the kitchen and living room were carried out, although this appears to be sometime during May and June 2023. The resident has told this Service that during the works her family were without access to a kitchen for a week. She also said that they had to provide a new sink, tiles, oven, hob, extractor fan, and floors at their own expense. The resident has also told this Service that her family were without access to the living room for 2 weeks. She said they had to live in the upstairs of the property even though the bedrooms and bathroom also had mould present. The resident said it was stressful, upsetting, and exhausting. The resident said the family cat had to be placed in a cattery, whilst the works were being completed, at her own expense. She also said that her family had to move all the furniture into a storage unit without any help, even though they had disabilities which meant it was very difficult for them to do so. The resident said that the landlord did not offer to decant them on a temporary basis whilst the work was being carried out. The landlord has confirmed through the complaints process that it did not believe a decant was required in the circumstances.
  11. Under the Equality Act 2010 (the Act), the landlord has a legal duty to make reasonable adjustments where there is a provision, criterion or practice which puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled. As the resident, her husband, and her son have disabilities, the landlord should have recognised the need to make reasonable adjustments to its usual processes. However, there is no evidence to show that it considered the family’s protected characteristics when making the decision not to decant the family. It did not demonstrate that it considered the additional detrimental effect on the family living in the property without access to a kitchen or living room whilst the work was carried out. Therefore, the landlord has not demonstrated that it properly considered its duties under the Act, and its actions were inappropriate in the circumstances.
  12. The resident’s husband raised a formal complaint with the landlord on 14 June 2023. He told the landlord that the damp work was not yet finished.
  13. The landlord sent the resident a stage 1 complaint response on 5 July 2023. It said it had undertaken a considerable amount of work to the property over the past few months. It said it had:
    1. Completed damp proofing works to the kitchen, with additional works carried out free of charge.
    2. Fitted a positive pressure fan to alleviate condensation issues within the property.
    3. Replastered the lounge with insulated plasterboard to external walls to improve thermal efficiency and plaster finishes. This included alterations to blinds to adapt to the new window profile.
    4. Removed a small area of mould and completed re-decoration to the hall, stairs and landing as a gesture of goodwill.
  14. The landlord said its damp and mould officer had visited the resident on 3 July 2023 following the continuing issues with black mould. It said a strategy for improvement was being prepared but it was happy that the measures already discussed would lead to a resolution. It said it had undertaken a borescope survey to establish whether there was any cavity wall insulation in the bathroom extension. Following the results it had agreed to undertake an external insulation scheme to be completed before the end of September 2023. It said the original contractor had declined to complete the work due to the excessive amount of phone calls and contact from the resident whilst undertaking other repairs. Therefore, the work had been passed to another contractor for a quote. The landlord confirmed that there had been some delays due to resourcing issues with its contractor. However, it was confident that the works had been completed to a high standard. The landlord said, to provide further assurance to the resident, it had asked for a full HHSRS survey to be carried out at the resident’s property.
  15. Although the stage 1 response confirms that the landlord had completed some of the required work, it did not fully acknowledge or apologise for the delays. It also placed an element of blame on the resident for contacting the contractors, rather than looking at why the resident may have felt the need to contact the contractors so often.
  16. The resident escalated the complaint to stage 2. She said she had purchased everything that was replaced in the kitchen, apart from the unit. This included the lining paper and paint. She said she had also paid £40 for the living room paint. The resident told the landlord that this was not in line with her tenancy agreement which said the landlord would “leave the decoration as close as possible to how it was before the work was done”. She also said that, during a meeting with the landlord’s surveyor, compensation had been discussed. The resident said it was agreed that compensation would be paid but the landlord said it would not be “a trip to the Maldives”.
  17. The landlord sent the resident a stage 2 complaint response on 27 July 2023. It said it understood that the resident chose to purchase her own worktop when the works to the kitchen were undertaken. It said the contractor had fitted the worktop and completed the decoration. It said it had acknowledged that there were delays to the works due to resourcing issues with one of its contractors. It apologised for the frustrations this caused. It said there had been a delay to fitting the positive pressure fan as the resident did not want a particular contractor to attend. As another contractor had to be sourced, there was an additional delay. It said, in relation to the paintwork, it would have been completed as part of the work undertaken by the contractor. However, it understood that the resident chose the colour and purchased the paint herself. It asked the resident to provide the receipts for the paint so that it could arrange re-imbursement.
  18. The landlord confirmed that the mould had been reported on 13 June 2022. It said it had undertaken works since then. It said a mould report conducted on 3 July 2023 showed very minor mould issues. It said it was satisfied that it had continued to work to resolve the mould. It said it was obtaining a quote to carry out external insulation to the downstairs bathroom to improve the thermal efficiency. It said it did not deny that the resident had been frustrated at times during the works. It acknowledged that there had been a short period of time when the family were unable to access downstairs rooms. It said this was inevitable due to the level of work required. It said it did not feel that the scale of work warranted decanting the family to alternative accommodation for such a short period of time. It also said it could find no evidence of any other reimbursement or compensation that should be awarded as a result of the works undertaken.
  19. Although the landlord apologised for the delay and agreed to reimburse the resident for the paint, the stage 2 response showed no empathy or understanding of the resident’s situation. It did not show any consideration of the family’s disabilities or make any reference to its obligations under the Equality Act 2010. The response also placed an element of blame on the contractor’s resourcing issues rather than the landlord accepting full responsibility for the delays. There was also no mention of, or apology for, the surveyor’s inappropriate comment that compensation would not be “a trip to the Maldives”.

Events following the stage 2 response

  1. The resident continued to have issues with mould in the bathroom for some time. All work was eventually completed to rectify the defects, although it is unclear from the evidence provided exactly when the work was finished. The landlord agreed to pay the resident £1,000 compensation on 22 March 2024 for the inconvenience and the reduction in the useable area of her home during the renovation and repair works.
  2. In summary, there were significant delays in the landlord completing the remedial works related to the damp and mould issues within the resident’s property. The landlord did not follow its damp and mould policy, once it had been implemented, to manage the damp and mould in the resident’s property. It did not properly consider its obligations under the Equality Act 2010 in relation to reasonable adjustments, it was unempathetic, and it spoke to the resident in an inappropriate way at times.
  3. The landlord did review its decision in relation to compensation and offered the resident £1,000 on 22 March 2024. However, the landlord did not utilise its internal complaints process to address these matters at the time the complaint was made. Had the landlord made the current offer at the time of the final response, this Service would have likely determined that its offer was satisfactory in resolving the complaint alongside the completion of the required repairs. As a result of this failure, and the level of detriment caused to the resident and her family, the Ombudsman finds that there was maladministration by the landlord in this case.

Repairs carried out to the driveway following reports of a trip hazard

  1. It should be noted that the landlord was asked by the Ombudsman to provide evidence around its handling of the resident’s concerns in relation to the repairs carried out to the driveway following reports of a trip hazard. It was also asked to provide copies of emails and information in relation to specific dates. However, the landlord has provided minimal information to show how it dealt with the resident’s concerns to this Service. It is important that landlords keep detailed, robust and accurate records relating to residents so that it can provide an effective level of service. The landlord’s poor record keeping in this case has not only affected its service provision to the resident, but it has also affected our investigation as it has been difficult to draw conclusions on certain aspects of this case. A finding of poor record keeping has been made in the circumstances.
  2. The resident reported issues to the landlord relating to a potential trip hazard on the driveway to their property on an unknown date. The landlord visited the property on 24 May 2023 and noted a potential trip hazard. The landlord said that it discussed the issue with the resident and it was agreed that the trip hazard was not an immediate risk and could be avoided until it was repaired. The landlord’s contractors visited the resident’s property on 8 June 2023 to inspect the driveway and to arrange to carry out the repair. The repair was booked in for 21 June 2023.
  3. The resident’s husband raised a formal complaint on 16 June 2023. He said there was a trip hazard outside his property, which the landlord was aware of. He said the landlord was also aware that he had Parkinson’s disease, which affected his mobility. He said he had received an email from the landlord telling him to avoid the area, although the trip hazard was directly outside the front door. He said the landlord had been aware of the trip hazard for a long time and he had already tripped over it on 2 occasions.
  4. The landlord completed the work to the pathway on 21 June 2023. This was 4 weeks (28 days) from the date the landlord visited the property to inspect the trip hazard. Although it was likely that the landlord had been made aware of the trip hazard by the resident prior to this date. Due to the lack of evidence provided by the landlord, this Service has been unable to establish the exact date of report. However, regardless of when the trip hazard was reported, the landlord’s repairs priorities say it will complete urgent repairs within 5 days and routine repairs within 20 days. As the landlord took at least 28 days to complete the repair, it did not act in accordance with the timeframes set for the completion of repairs. Its actions were therefore inappropriate in the circumstances. This was unreasonable and unfair to the resident’s husband, particularly as he has a disability that could make him more prone to falls.
  5. There is also no evidence to show that it properly considered this as part of its obligations under the Equality Act 2010, to make reasonable adjustments where there is a provision, criterion or practice which puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled. This was inappropriate. It would have been reasonable in the circumstances, taking into account the resident’s disabilities, for the landlord to have categorised the repair as urgent and completed the repairs within the relevant timeframe.
  6. The landlord sent the resident a stage 1 complaint response on 5 July 2023. It confirmed that it had visited the resident on 24 May 2023 and it had noted the potential trip hazard. However, it said the area concerned was on the main driveway and not on the footpath area, leaving a hazard free route. It said it had been agreed that the trip hazard was not an immediate risk and it could be avoided until repaired. It said that the resident had not mentioned a fall to the contractor.
  7. The resident escalated the complaint to stage 2 on 6 July 2023. She said the trip hazard was not on the main driveway. It was a small area outside the front door. The resident asked the landlord to explain why it had commented that she had not told the contractor about her husband’s fall. She said it was not relevant to the contractors. She said they had contacted the landlord when her husband had fallen, and within a few hours they received an email telling them not to walk on the area. She said they would not have been able to get in or out of the property if they had avoided the area as suggested. She said it had not been agreed with the landlord that the trip hazard was not an immediate risk.
  8. The landlord sent the resident a stage 2 complaint response on 27 July 2023. It said it had seen photographic evidence of the trip hazard. Whilst it acknowledged that work needed to be undertaken to the area, it felt that there was a sufficient area adjacent to the trip hazard that allowed safe access to and from the property.
  9. The stage 2 response was unempathetic and showed no understanding of the resident’s disability. It did not make any reference to the delay in completing the repair and it made no reference to its obligations under the Equality Act 2010. It made no meaningful attempt to resolve the issue or learn from the complaint in line with the Ombudsman’s Dispute Resolution Principles to be fair, put things right, and learn from outcomes.
  10. In summary, our investigation was hindered by the landlord’s poor record keeping and lack of evidence provided. There was a delay by the landlord in completing repairs to a trip hazard outside the resident’s property. The landlord did not demonstrate that it properly considered its obligations under the Equality Act 2010. It was unempathetic towards the resident and her family at times and it showed no understanding of her husband’s disabilities. As a result of this failure, the Ombudsman finds that there was maladministration by the landlord in this case.

Reports of disability discrimination under the Equality Act 2010

  1. The resident’s husband first raised concerns of disability discrimination under the Equality Act 2010 in the stage 1 complaint dated 14 June 2023. He said he believed he had been discriminated against by the landlord due to his disability.
  2. In the stage 1 response dated 5 July 2023 the landlord said it could find no evidence to substantiate the claim of discrimination under the Equality Act 2010. However, there is no evidence to suggest that the landlord spoke to the resident to obtain further information in relation to the matter.
  3. The resident escalated the complaint to stage 2 on 6 July 2023. She said she felt that there was a lot to discuss on the matter in relation to the way the family had been treated and spoken to by the landlord. She said it was far too much to write in an email and she said she would welcome a call from the landlord to discuss it further.
  4. The landlord sent the stage 2 complaint response on 27 July 2023. It re-iterated its findings within the stage 1 response. It said it could find no evidence to substantiate the resident’s claim of discrimination under the Equality Act 2010.
  5. There is no evidence to suggest that the landlord conducted any sort of investigation into the resident’s reports of disability discrimination before coming to a conclusion in its stage 2 response. There is no evidence to suggest that the landlord contacted the resident, as suggested in her escalation email dated 6 July 2023, to discuss their concerns.
  6. The landlord has a duty under the Equality Act 2010 (the Act) not to unlawfully discriminate against a person based on their protected characteristics. As such, following allegations of discrimination, this Service would expect the landlord to conduct a full and thorough investigation before providing the resident with a full response as part of its complaints process. This would include discussing the matter directly with the person/s concerned. As the landlord cannot evidence that it did this, it would be reasonable to conclude that it did not properly consider its obligations under the Act. This was inappropriate and unfair to the resident.
  7. In summary, the landlord did not demonstrate that it properly considered its obligations under the Equality Act 2010. It did not conduct a full investigation into the resident’s reports of disability discrimination or provide rationale to support its position that it did not discriminate against the resident and his family. As a result of this failure, and the detriment caused to the resident and her family, the Ombudsman finds that there was maladministration by the landlord in this case.

Complaint handling

  1. The landlord operates a 2 stage complaints process. Its complaints policy says it will respond to stage 1 complaints in 10 working days and stage 2 complaints in 15 working days.
  2. The resident’s husband raised a formal complaint with the landlord on 14 June 2023. The landlord provided a stage 1 response on 5 July 2023. This was 15 working days from the date the resident raised the complaint and outside of the timeframe of 10 working days set within the landlord’s complaints policy.
  3. The resident escalated the complaint on 6 July 2023. The landlord sent the resident a stage 2 response letter on 27 July 2023. This was within the timeframe of 15 working days set within the landlord’s complaints policy. However, the landlord did not recognise or acknowledge the delay in providing a response at stage 1 in either of its complaint responses.
  4. In summary, the landlord failed to act in accordance with the timeframes set within its complaints policy at stage 1 of the complaints process and it did not acknowledge the failing within its complaint responses. As a result of these failings the resident will have sustained inconvenience through the delays and mishandling of her complaint and the Ombudsman finds that there was service failure by the landlord in this case.

Determination

  1. In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration by the landlord in its handling of reports of damp and mould and the associated remedial repairs.
  2. In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration by the landlord in its handling of repairs carried out to the driveway following reports of a trip hazard.
  3. In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration by the landlord in its handling of reports of disability discrimination under the Equality Act 2010.
  4. In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was service failure by the landlord in its complaint handling.

Orders and recommendations

Orders

  1. Within four weeks of the date of the report, the landlord must:
    1. Apologise to the resident in writing for the failings identified in this report.
    2. Pay the resident total compensation of £1,900 (the landlord may deduct from the total any amount it has already paid). This is made up of
      1. £1,000 in recognition of the delays, distress and inconvenience caused to the resident and her family by its handling of reports of damp and mould and the associated remedial repairs.
      2. £350 in recognition of the delays, distress and inconvenience caused to the resident and her family by its handling of repairs carried out to the driveway following reports of a trip hazard.
      3. £500 in recognition of the distress and inconvenience caused to the resident and her family by its handling of reports of disability discrimination under the Equality Act 2010.
      4. £50 in recognition of the complaint handling failures and the time, trouble, and inconvenience caused to the resident.
    3. Refund the resident for the costs associated with placing the cat in a cattery for the duration of the works to rectify the damp and mould issues.
    4. If it has not already done so, refund the resident for the cost of the paint used to redecorate the kitchen and living room following the works to rectify the damp and mould issues.
  2. In accordance with paragraph 54(g) of the Housing Ombudsman Scheme, the landlord is ordered to carry out a senior management review of this case to determine how it will prevent a recurrence of the failings identified in this report in future. The landlord must complete the review within 8 weeks of the date of this report and provide the Ombudsman with a copy of its review and resulting action plan. The review must include (but is not limited to) consideration of the following:
    1. Understand why the landlord was unable to demonstrate it factored the resident’s disability into its decision making and why it was unable to fulfil its obligations under the Equality Act 2010. The landlord should consider what actions it needs to take to change its processes and may wish to consider whether the implementation of a reasonable adjustments policy is required.
    2. How it will ensure its staff are sufficiently trained to implement the necessary changes.
  3. The landlord should reply to this Service with evidence of compliance with these orders within the timescales set out above.