Customer Feedback Policy

The purpose of this policy is to set out the Group’s approach to dealing with customer feedback reported to YHG.

The Transparency, Influence and Accountability Standard, set by the Regulator of Social Housing, specifies that registered providers must: 

• Ensure their approach to handling complaints is simple, accessible and publicised
• Provide accessible information to tenants about:   
  a) how tenants can make a complaint about their registered provider  
  b) the registered provider’s complaints policy and complaints handling process  
  c) what tenants can do if they are dissatisfied with the outcome of a complaint or how a complaint was handled, and   d) the type of complaints received and how they have learnt from complaints to continuously improve services. 

The Housing Ombudsman Service (HOS) have outlined 3 guiding principles when dealing with complaints:

1. Be Fair
2. Put things right
3. Learn from outcomes.

The Housing Act 1996 stipulates all social landlords have a duty to be a member of the Housing Ombudsman Scheme, which allows for the provision of an independent who can investigate complaints made to them when unhappy with the service they have received from their housing association. 

Aims of the Policy

• Record and address customer complaints and compliments, offering several different ways for customers to contact us.
• To ensure all complaints are treated fairly, efficiently, and as confidentially as possible, only disclosing information if necessary to properly investigate.
• Ensure customers are aware of how to raise a complaint with YHG and to ensure that customers are regularly kept updated of the progress of their investigation or outstanding actions in plain language.
• Record all feedback, communications, and investigations to allow for analysis and recommended service improvement.
• Identify learning from complaints. 

The policy covers all customers including tenants, leaseholders and freeholders (or an advocate authorised to act on their behalf), who have experienced a service delivered by YHG, or one of its approved partners. This also includes MP’s; Councillors or any other advocate service authorised to act on the customer’s behalf. Non-customers may also use the policy should they have been impacted by any decisions or actions taken by YHG and its contractors, when acting on their behalf. It should be noted that as detailed in Part 2 Section 25 of the Housing Ombudsman Scheme – Who can make a complaint, the Housing Ombudsman only accepts cases from  a person who is or has been in a landlord/tenant relationship with a member, therefore non-customers are unable to refer their complaint to the Housing Ombudsman.

6.1. Compliments, Comments & Suggestions: 

A compliment is a polite expression of praise, admiration or gratitude about a service, contractor or member of staff. It’s great when customers let us know what we are doing well, as we can learn and share best practice across YHG. 

A comment or suggestion is a remark expressing an opinion, reaction or an idea for consideration, or negative feedback following an interaction. We have a strong reputation around us, involving our customers in shaping services and improving neighbourhoods. We value customer views and understand; our customers are at the heart of everything we do. 

6.2. Complaints 

The Housing Ombudsman defines a complaint as: 
‘An expression of dissatisfaction, however made, about the standard of service, actions or lack of action by us, our staff, or those acting on our behalf, affecting an individual resident or group of residents.’ 

We will consider the individual circumstances of each complaint, however, instances where complaints will not be considered include: 

• A first-time request for a service, or query to YHG
• Issues raised more than 12 months after the issue occurred or the customer becoming aware of the issue
• Matters that have previously been considered under this policy
• Cases where legal proceedings have started (defined as details of the claim, such as the Claim Form and Particulars of Claim having been filed at court), or a final legal decision has been made
• An appeal against a decision to commence legal proceedings
• Housing Benefit issues
• Reports of Anti-Social Behaviour (unless regarding an alleged breach of ASB policy or process)
• Complaints regarding serious allegations against staff which would be more appropriate to be investigated through the Group’s disciplinary procedure. Such outcomes would not be shared with the complainant under GDPR
• Allegations of Data Breaches or issues relating to Subject Access Requests are managed through GDPR and investigated by YHG’s Data Protection Lead and reported where necessary to the ICO.
• This list is not exhaustive. 

Should YHG decide not to accept or escalate a complaint, a written 
explanation will be provided setting out the reasons why the matter is not suitable for the complaints process and the customers right to take that decision to the Housing Ombudsman Service.

We have a variety of ways to enable customers to provide us with their views or feedback.

• Online – through our website or via the Your Home HUB customer portal and completing the online form.
• Letter – by writing to us at: Your Housing Group Complaints Department, Youggle House, 130 Birchwood Boulevard, Birchwood, WA3 7QH.
• Telephone - By calling Your Response on 0345 345 0272.
• Face to face – e.g. in person, to a member of staff or at of our offices if you need assistance in raising your complaints.
• Email – [email protected]
• YHG Social media channels – These will be directed through to the Complaints Department to be recorded and actioned accordingly. 

We will make our customers aware of our Customer Feedback Policy by publicising them in our newsletters and other campaigns, to ensure that customers know how to make a complaint, compliment or raise a query with us. 

7.1. Service Requests 

A Service Request is a request from a customer to the landlord, requiring action to be taken to put something right. Service Requests are not complaints, but must be recorded, monitored, and reviewed regularly. 

When a customer makes a Service Request, they will be contacted within 5 working days to agree on how this will be managed. Should a customer express dissatisfaction with a response to their Service Request, a complaint will be raised. However, this does not stop the efforts to address the Service Request swiftly and efficiently.

Formal Stage 1 

A complaint is recorded at Stage 1, should a formal written response be required. A full investigation will be conducted, and we will aim to provide a written response within 10 working days of the complaint being recorded. On occasion, it may not be possible to provide our response within this time and as such, we will write to the customer to advise of the delay. We will ensure our response is no later than an additional 10 working days unless there is good reason for which we will advise the customer, (as per the complaint handling code). 

Upon receipt of a Stage 1 complaint, we will:

• Acknowledge receipt within 5 working days, providing a unique reference number and date for when a response will be received by.
• Make contact with the customer via the phone, or their chosen method of communication, to discuss the complaint and desired outcome.
• Treat customers fairly, empathetically and by the relevant staff member that has authority and autonomy to resolve the dispute quickly.
• Investigate in an impartial manner, seeking sufficient, reliable information from all parties, making appropriate recommendations to resolve the complaint, providing realistic timescales and to manage customers’ expectations.
• Contact you to discuss the outcome of our investigation.
• Confirm in writing the outcome of your complaint as soon as possible and within 10 working days. Along with any proposed actions, a clear definition of the complaint will be provided, referencing relevant policy, law and good practice, where appropriate. Any offers of remedy to put things right and details of how to escalate the matter to the next stage, should you not be happy with the outcome.
• Should a complaint be complex and more time is required to provide a response, customers will be contacted in writing to advise of an extension of no more than an additional 10 working days, save for when with good reason longer is required and the Ombudsman contact details will be provided. 
  Intervals at which updates will be provided will be agreed with the customer.
• Customers can raise additional complaints to be incorporated into their Stage 1 complaint before the response is issued. Should new issues arise which are not related to the initial complaint, these will be logged as a new complaint. 

Should any action remain outstanding after the complaint is closed, regular contact will be maintained to ensure these are completed in the timescales we have set. 

Once a complaint has been closed at Stage 1, the customer has a maximum of 6 months to escalate their complaint to the next stage of the complaints process. 

8.2 Formal Stage 2 

If a customer is not happy with the outcome of their complaint, they can ask for it to be reviewed at Stage 2 within 6 months of the Stage 1 complaint response. 

The customer is not required to explain their reasons for a Stage 2 to be considered. Upon receipt of a Stage 2 complaint, we will:

• Acknowledge receipt within 5 working days, providing a unique reference number and date for when a response will be received by.
• Assign your complaint to an appropriate member of staff who did not review the complaint at Stage 1. 
• Complete a full review of the initial complaint and how the Stage 1 was addressed.
• Treat customers fairly, empathetically and by the relevant staff member that has authority and autonomy to resolve the dispute quickly.
• Investigate in an impartial manner, seeking sufficient, reliable information from all parties, making appropriate recommendations to resolve the complaint, providing realistic timescales and manage customers’ expectations.
• Provide a formal response as soon as possible and within 20 working days, which could be by letter or email. Along with any proposed actions, a clear definition of the complaint will be provided, referencing relevant policy, law and good practice, where appropriate. The outcome, which may include outstanding actions, will also include any offers of remedy to 
  put things right and details of how to escalate the complaint to the Housing Ombudsman.
• On occasion, it may not be possible to provide our response within this time and as such, we will write to the customer to advise of the delay and reasons why.  Intervals at which updates will be provided will be agreed with the customer. We will ensure our response is no later than an additional 20 working days.

All correspondence sent to YHG Executives including Non-Executive Directors will be redirected to the appropriate team to provide a response. Where the communication relates to dissatisfaction, this will be investigated as part of a new complaint or will be included as part of an existing complaint which we are already investigating, in line with this policy. 

10.1. Petitions/Group complaints

Complaints raised by a group of people where there is no nominated lead representative will be recorded and responded to within 10 working days and all signatories where a name and address is provided will receive acknowledgment and response. This will be recorded as a petition and not a formal complaint. 

Where a complaint is raised by group of people with a nominated lead, a Stage 1 complaint will be recorded and will follow the formal complaints process. 

This is in line with the Housing Ombudsman’s Guidance on Group Complaints in accordance with paragraph 19 which states there is no provision to consider complaints from groups of customers however a complaint will be accepted should a group complaint have a lead complainant and clearly representing named individuals. 

10.2. Anonymous complaints

Anonymous complaints will always be considered where the complainant provides sufficient information to identify the issue of concern. All anonymous complaints by nature preclude any response to the complainant. Anonymous complaints about our service should be sent to the Customer Resolution Team who will record these and liaise with the relevant Service Manager to 
determine the most appropriate way to consider the point(s) of complaint. In some instances, we may deal with these under separate policies, e.g. YHG’s Whistleblowing, Safeguarding, Anti-Fraud or Bribery Policies. 

This decision is made on a case-by-case basis, taking into account individual circumstances and if it is still possible to be able to provide a full investigation. 

A complaint will only be considered if it is made within 12 months of the initial incident taking place. This is to ensure a thorough investigation can be completed with all relevant notes and documentation. 

Customers can contact the Housing Ombudsman at any stage of their complaint to receive impartial advice. 

Should a customer remain dissatisfied with the outcome of their complaint, they can escalate the matter to the Housing Ombudsman.

The Housing Ombudsman can be contacted via:

• Their website, https://www.housing-ombudsman.org.uk/contact-us/
• By email [email protected]
• Writing to: Housing Ombudsman Service, PO Box 1484, Unit D, Preston, PR2 0ET or contact them on telephone number 0300 111 3000. 

Our aim is to deal with comments, suggestions, complaints or general contacts in an open, fair and impartial way. Staff will respond professionally and sympathetically to all customers and work positively with them to resolve issues and explain the reason for their outcome. There are occasions when there is nothing further that can reasonably be done to rectify a perceived problem, or 
further assist, and recognise that this or other distressing circumstances can cause a customer to act out of character.

However, if a customer, because of their actions and behaviour, or nature and frequency of their contacts with us, hinders their or other people’s interactions with us, or delays our ability to investigate the 
complaint, we will consider such behaviour to be unreasonable. 

13.1 Examples of unreasonable behaviour or demands may include:

This list is not exhaustive.

• Raising the same issue, complaint or similar complaint many times when this is already being managed through YHG Complaints or other procedure which has already concluded
• Contentiously raising an issue or complaint without having sufficient grounds, refusing to specify the grounds or having no grounds
• Constantly introducing new information whilst a complaint is being investigated, which is not significant or relevant
• Refusing to accept the response that has been provided, continuing to raise the same subject matter without providing any new evidence, continuously adding to or changing the subject matter of the complaint
• Refusing to accept the outcome of the complaint process after its conclusion (although you may have recourse to the Housing Ombudsman)
• Making persistent and unreasonable demands of staff, or the complaints process, or persistent or unreasonable contact by any means for example out of hours telephone calls, overload of letters, calls, emails or contact via social media
• Verbal abuse, inappropriate language in any format, inclusive of harassment, aggression, violence, this is not just limited to actual physical or verbal abuse but can include derogatory remarks, rudeness, inflammatory allegations and threats of violence
• Electronically record meetings without prior consent of the other party
• Social media ‘trolling’. Posting inflammatory, offensive, abusive or confidential comments or information online. 

13.2 How we will deal with unreasonable behaviour or demands.

We have to act when unreasonable behaviour impairs the functioning of YHG. 

We aim to do this in a way that allows a customer to progress through our processes. We will try to ensure that any action we take is the minimum required to solve the problem, considering relevant personal circumstances including the seriousness of the issue or complaint and the needs of the individual. The threat or use of physical violence, verbal abuse, or harassment towards our staff 
is likely to result in the termination of all direct contact with the customer. 

Incidents may be reported to the police. This will always be the case if physical violence is used or threatened. We will not accept any correspondence that is abusive to staff or contains allegations that lack substantive evidence. We will tell the customer that we consider their language offensive, unnecessary and unhelpful and ask them to stop using such language. We will state that we will not respond to their correspondence if the action or behaviour continues. 

13.3 Actions we may take include:

• Limit contact via telephone calls at set times on set days
• Request a suitable advocate to be nominated to act on behalf of the customer
• Restrict contact to a nominated member of staff who will deal with future calls or correspondence from the customer or their nominated advocate
• Restrict contact from the customer to writing only.
• Return any documents to the customer or, file them and not respond
• Take any other action that we consider appropriate
• Where we consider continued correspondence on a wide range of issues to be excessive, we will tell the customer that only those matters within our remit will be considered
• In exceptional cases, we reserve the right to refuse to consider a complaint or future complaints from an individual
• We will always formally write to the customer to tell them what actions we are taking and why’
• When and where applicable, we will ensure that all appropriate referrals have been made, and correct support is in place for individuals who we propose action against for unreasonable behaviours
• Any restrictions or actions put in place will be reviewed every 3 months. 

The Director of Housing and Customer is the responsible Policy Author. The Policy Owner is the Executive Director of Housing & Customer Service. All YHG staff have personal responsibility for their own behaviour in relation to this policy and are responsible for ensuring that their conduct is in line with the standards set out in 
this policy. 

There are reputational risks to the business in relation to managing complaints effectively. This policy will operate alongside our Governance, Risk & Assurance Policies in providing a consistent approach to addressing those risks. 

Complaint data is reviewed and analysed on a regular basis and actions are taken to address any issues arising. YHG is also committed to learning from our complaints process, and we will ensure that appropriate processes are in place in order to do this. 

Any complaints reported under this policy will be managed via our housing management systems, Orchard, and CRM. These systems are GDPR compliant. 

This policy considers any issues of data protection in relation to the processing of personal data under GDPR and is compliant with the Data Protection policy. 

Complaints relating directly to Data Protection or the potential mishandling of customer data are excluded from this policy and are investigated by the Data Protection Lead in line with YHGs Data Protection Policy and in line with the requirements of Information Commissioners Office. 

YHG operates an Equality, Diversity and Inclusion policy, and this applies to all aspects of its services. We will ensure that no customer, customer or service user is treated less favourably on the grounds of age, ethnicity, religion or belief, disability, gender, gender reassignment, sexual orientation, pregnancy or maternity, marriage or civil partnership status. 

This policy, and all related information, can be made available in different formats and languages on request. This policy complies with the requirements of the Equality Act 2010 and has been Equality Impact Assessed. 

This policy, along with the Customer Feedback Service Standard, is also published on our website, www.yourhousinggroup.co.uk. 

This policy is published on our intranet ‘Youggle’ for internal staff and is a mandatory read for all staff who manage complaints. 

We will publish annual results on the website in line with the regulatory Transparency, Influence and Accountability Standard. This will include the number and nature of complaints and how we have performed against our key performance indicators. 

This policy has been written to ensure compliance with the Housing Ombudsman Complaint Handling Code, and we are committed to completing annual self assessments, or earlier should there be any major changes, to ensure we remain so. Self-assessments may also be carried out should the Ombudsman request us to do so following an investigation. 

Should YHG not be able to comply with the Code due to exceptional circumstances, such as a cyber incident, we will inform the Ombudsman at the earliest opportunity, provide information to customers who may be affected, and publish this on our website, providing a timescale for returning to compliance with the code. 

This policy along with the ‘Compensation Policy’ will form part of the induction process for any new staff who manage complaints and compensation claims. They are also briefed on any changes made following the bi-annual review. 

Complaints key performance indicators, including number of complaints, complaints responded to in time, complaint trends and lessons learnt will be reported through management teams and YHG Governance Groups including Customer Services Committee and Board.  Complaints performance will also be reported through annual Tenant Satisfaction Measures returns to the Regulator of Social Housing. 

This policy will be reviewed every two years, or sooner if required by statutory, regulatory, best practice, emerging developments, or circumstances arising from reviews of other YHG wide policies.