Managed behaviour policy

3. Policy statement

This policy aims to:

• clearly set out the types of behaviours we consider unacceptable and/or unreasonable
• give clarity on how unacceptable or unreasonable behaviour will be assessed, managed and communicated to customers
• when customers can ask for a reconsideration of a managed behaviour restriction and how reconsideration is undertaken

3.1. Reasonable adjustments

Some people that contact us have a mental or physical impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities (such as a disability). Where this applies, we may put in place reasonable adjustments to change the way we interact with the customer.

To ensure customers receive the help they need to access our service, we will check whether a reasonable adjustment is required when you first contact us. At any stage where it is determined that a reasonable adjustment is required, it will be recorded on our case management system. Further information on reasonable adjustments can be found in our Reasonable Adjustment Policy.

We will always consider how any restrictions may impact a reasonable adjustment that has been put in place for a particular customer.

Sometimes we may put a contact restriction in place which impacts a reasonable adjustment. This is because the behaviour we are experiencing means the adjustment is longer reasonable where the person has shown unacceptable or unreasonable behaviour towards our employees. This could be because that adjustment is no longer effective or practical. Where possible, we will prioritise selecting contact restriction(s) that provide an alternative way to access to our service.

We will consider contact restrictions on a case-by-case basis and will always let the customer know of a decision to impose a contact restriction in writing.

The policy below sets out what types of behaviour we consider unacceptable or unreasonable, how this will be managed, and what customers can do if they believe a restriction should be reconsidered.

3.2. Behaviours that are unacceptable or unreasonable

Unacceptable behaviour

Sometimes people may be upset, angry, or anxious about the issues they have raised in their complaint. We will always try to help but we will not accept aggressive, abusive or harassing behaviour towards our employees.

Examples of this type of behaviour can include:

• behaviour or language (verbal or written) that may cause employees to feel offended, afraid, threatened, or abused
• derogatory or discriminatory remarks; including racist, sexist, disablist, homophobic, or transphobic comments
• using insulting or degrading language
• making serious allegations against us or others without any evidence
• publishing information about employees online including social media
• recording and publishing telephone discussions with employees that are taken without their consent
• contacting employees using their personal details or social media presence such as Facebook, Instagram, X or LinkedIn

Unreasonable demands

Demands on our service can be unreasonable if they impact our ability to provide a consistent service, or if involves an excessive amount of employee time.

Examples of these type of demands can include:

• repeatedly demanding a response within a timescale outside of normal timescale agreements
• insisting on, or refusing to speak to employees when that is not possible
• repeatedly changing the substance of a complaint or raising unrelated concerns
• refusing to accept a decision where explanations for the decision have been given
• refusing to co-operate by not providing information we request to allow us to help resolve the issue

Unreasonable levels of contact

Levels of contact become unreasonable when the amount of time spent managing it impacts our ability to process the complaint or limits the service we can give to other people.

Examples of this type of contact can include:

• repeated contact whilst a complaint is being progressed or after it is closed
• lengthy telephone calls repeating the same points for discussion
• high volumes of information provided by email, webform, or post where the information repeats what has already been given
• copying our employees into emails with other parties where this is not necessary

3.3. How we will manage unacceptable or unreasonable behaviour

Where our employees experience unacceptable behaviour on a telephone call they may take immediate action to terminate the call where it is appropriate in the circumstances. Where possible, the employee member will inform the customer why their behaviour is unacceptable before deciding to terminate the call.

The following list sets out the contact restrictions we can impose to manage unacceptable or unreasonable behaviour:

• requesting communication only in writing or through a representative
• deciding not to investigate a complaint on the basis that it has been pursued in an unacceptable or unreasonable way
• stopping all communication with someone
• restricting or limiting contact with us

The following list sets out additional actions we can take to manage unacceptable behaviour which threatens the immediate safety of our employees or other persons:

• notifying the emergency services and/or the landlord
• reporting information shared on social media to platform moderators

If we consider someone’s behaviour is unreasonable (due to the demands made or levels of contact) or unacceptable, we will first try to fix the issue. We will explain why the behaviour is unreasonable or unacceptable and will give the person an opportunity to stop the behaviour so we can continue to progress the case.

If we are unable to resolve the issue and decide there is a need to manage behaviour in line with our policy, this decision will be made by a senior colleague, of manager level or above. The contact restriction conditions and reasons for the contact restriction will be communicated to the customer in writing.

A managed behaviour restriction will usually be in place for 12 months.

If behaviour threatens the immediate safety of our employees, other individuals, or an organisation, we will report the matter to the police. We will contact the landlord or local authority where the threat is directed towards the landlord or local authority.

We aim to let the customer know that we have reported their behaviour to police, landlord or local authority. There are some circumstances where this is not possible, such as a call being terminated before we have the opportunity to inform the person, or where informing the person could impact a criminal investigation.

A record of any managed behaviour restriction imposed will be kept on our case management system for the duration of a customer’s case or cases if there is more than one, for the duration of the contact restriction. Once the case or cases are closed or the contact restriction expires, we will remove the information relating to the managed behaviour restriction in line with data protection rules.

Where a managed behaviour restriction is in place for longer than 12 months, a manager will review the restriction. As part of the review information will be checked, updated or deleted if it is no longer correct.

3.3. Reconsideration of a managed behaviour restriction

A customer can ask for a managed restriction to be reconsidered in any of the following circumstances:

• where there is a change in circumstances which mean the managed behaviour restriction is no longer appropriate
• where there is evidence the restriction impacts the customer’s ability to access our service
• a factual error was made by our service when making the decision to apply the restriction

A senior colleague, of manager level or above will consider the reconsideration request and decide if any changes will be made the managed behaviour restriction. The outcome of this will be communicated to the customer within 15 working days of their reconsideration request.