Home Group Limited (202114545)

REPORT

COMPLAINT 202114545

Home Group Limited

20 March 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 concerns:
1. The landlord’s response to the resident’s anti-social behaviour reports including concerns about the neighbours’ parking.
2. The related complaint.

Background and summary of events

The resident is an assured tenant. The property is a one-bedroom, semi-detached bungalow. The tenancy started on 9 July 2012. The property is set back with a communal front garden.
The landlord is a housing association.
The resident has disabilities and has a support worker. At the time of the complaint the resident had a broken back/shoulders and ribs.
The landlord states whilst it had no vulnerabilities recorded on its system for the resident, communications with her and the police during the course of the complaint, led it have some concerns about the resident’s wellbeing and therefore it submitted a safeguarding referral to the Council’s safeguarding team in December 2021.

Summary of events

The landlord’s system show that on 1 March 2021, the resident reported experiencing difficulties in parking outside of her property due to the tenants in the property on the opposite side of her street and their family (the neighbours) always visiting and parking their vehicles along the street.
On the same date, the landlord confirmed in writing to the resident that it had logged her report in accordance with its antisocial behaviour (ASB) procedure and that a Housing Manager (HM) would contact her to carry out an initial investigation. It reminded the resident that any acts of a criminal nature should be reported to the police.
The landlord’s HM visited the resident later that day whose notes of the visit state the resident said she felt intimidated by the family members who parked their cars along the street. The HM advised her to report any instances of intimidating behaviour from the neighbours which she agreed to do. The resident told the landlord she was applying for a disabled parking bay.
The resident contacted the landlord again on 8 March 2021. She reiterated that she needed a disabled parking bay or a parking permit as she could not walk to her car with her disability because multiple cars owned by the neighbours had been parked along the street.
The landlord’s HM called the resident’s support worker on 9 March 2021, to discuss the resident’s parking concerns. The landlord’s notes of the conversation show it explained that as the issues were on a public highway, it was a matter for the Council’s Highways team, however, it was happy to support her application for a disabled parking bay. It provided them with the Highways team phone number. The notes show the HM offered to speak to the neighbour about allegations of intimidation if the resident wanted them too. The support worker agreed for the landlord to close the case.
On 9 June 2021, the resident called the landlord reporting ASB from the neighbours. The landlord’s case notes show that its HM attempted to call the resident back on 11 June 2021, but left a voice mail message advising that a further call back attempt would be made.
On 17 June 2021, the resident reported excessive parking in front of her property. The landlord’s HM left a voicemail message for the resident.
The resident called the landlord on 22 June 2021. The HM’s notes of this call show the resident asked to speak to their line manager as she alleged they had spoken to the neighbours about the ASB case she had raised against them despite her asking them not to. The resident advised she had video footage of them speaking to the neighbours in question. The HM advised during the call that they had never been in touch with the neighbours. The resident also said she was unhappy about the closure of her previous ASB case. The HM said they previously explained to her that the landlord had no control over parking on the main street which the resident was in agreement with at the time. It was noted that the resident had been working with her support worker to get the Council to install a parking bay. They agreed to contact the Highways team regarding parking issues in the resident’s street.
On 23 June 2021,the HM’s manager called the resident and advised her that the HM had not disclose any confidential information to the neighbours. The landlord explained the parking laws which its notes indicated the resident understood.
Following a call from the resident on 7 July 2021 regarding the parking issues, the HM submitted a second enquiry form to the Highways team regarding parking issues in the resident’s street.
On 15 July 2021, the resident reported that the neighbours were beeping their horn around 9 pm outside her property causing the dog to bark. The landlord asked if she wanted it to speak to the neighbours. The resident declined.
On 20 July 2021, the resident advised the HM that an ambulance was unable to access one of her neighbours’ properties due to parking along the street. The note states the resident was “very upset” and that the HM asked the resident if she wanted him to contact the neighbours about their parking to which she said no. The HM advised the HM to keep the landlord updated and they sent a third request to the Highways team to enquire about progress with the resident’s request for a disabled parking bay.
On 22 July 2021, the HM visited the resident to check she was okay. The note of the visit states the resident told him she had not heard back from the Highways team. The HM gave their email address to the resident and advised her to contact them directly to chase up.
The HM visited the resident again on 5 August 2021 after she called the landlord. They discussed her contacting with the Highways team again regarding the progress of her disabled parking bay.
On 21 September 2021, the Highways team installed a disabled parking bay outside of the resident’s property.
On 24 September 2021, the HM spoke to the resident’s support worker who advised that the resident had experienced intimidating behaviour on the road by the neighbours. The resident alleged her car tyres had been vandalised and the police had been informed who advised they would be contacting her next week. The landlord’s case notes indicate its HM offered again to raise this with the alleged neighbours and to carry out a joint visit with her support worker to discuss her concerns. The notes indicate the support worker said she was happy to do this.
The landlord’s call records show that on 27 September 2021, the landlord’s HM discussed with the resident the incident she previously reported concerning damage to her tyres. The resident told the landlord lights had also been flashed into her infra red security system which prevented footage being recorded. The resident advised that she was going to install CCTV to prevent this happening again. The HM advised she would need to obtain permission from it to have this installed as per the General Data Protection Regulation (GDPR). The resident reiterated that she did not wish for him to speak to the neighbour about the concerns she had raised.
On the same date, the resident contacted the Ombudsman regarding the landlord’s handling of her ASB reports regarding the neighbours. She said they had five sons who had eight cars that block the street. The resident told us that the landlord discussed her reports with the neighbours which was a data protection breach. She said has been targeted and her tyres slashed. The resident advised the outcome she sought was for the neighbours to be moved.
On 27 September 2021, the Ombudsman wrote to the landlord asking it to respond to the resident’s complaint about ASB, vandalism and harassment from the neighbours.
On 28 September 2021, the resident’s support worker advised the HM that the resident did want not a joint visit. The HO said he would call the resident to clarify this.
On 1 October 2021, the resident requested consent from the landlord for CCTV installation. It is unclear from the evidence if this was granted.
On 4 October 2021, the resident reported to the landlord that the neighbours had been harassing her and damaging her car. The resident told the landlord she was unhappy that she had to replace tyres and bumpers.
On 4 October 2021, the landlord wrote to the resident acknowledging her complaint and confirmed that it would investigate the issues she had raised concerning its handling of her ASB reports concerning vandalism and harassment from the neighbours. It acknowledged the resident’s request for the neighbours to be moved to an alternative property. It said it had attached a leaflet with information regarding its complaints process.
The landlord’s internal communications show its HM contacted the Highways team on 8 October 2021, to advise the resident had told it that since her parking bay had been allocated, she was unable to use the bay due to cars parking to close to the markings. The HM asked if this was something they could look at and advise on.
On 13 October 2021, the landlord provided a stage one complaint response. Under the heading ‘ASB handling’, it acknowledged her concern raised in June 2021 that the Customer Service Centre (CSC) had informed her that the HM had spoken to the neighbours about her complaints without her permission. It said that it was confirmed at the time during a phone call to her that this was not correct. The landlord stated there had been no contact with the neighbours in question regarding concerns at her own request. However, it said it had increased the inspections of the estate to monitor the situation.
The landlord also acknowledged that she raised concerns in June 2021 regarding car parking, specifically the number of cars that the neighbours parked along the street. It said the resident had advised of the lack of road space between parked cars on either side of the road and that due to health reasons, she required a disabled parking bay. The landlord said its HM liaised with the Highways team in regards to the disabled bay and to report parking concerns, specifically in regards to the potential risk of emergency vehicles not being able to access streets, he also shared contact details for reported with her. It said the disabled bay was now in place.
It acknowledged that in September 2021, the resident reported there had been continued parking issues on the street, specifically cars parking closely to the disabled bay which prevented her from accessing it. It said its HM raised these issue with the Highways team as this fell into their remit. The Highways team had confirmed the disabled bay specification was correct however they would attend this week to check.
In regards to the resident’s report of her car tyres being slashed that she had reported to the police, her new HM made contact with the police to get an update on this incident and to asked how it could support her further. The police stated there had been no incidents logged on her street.
The landlord said going forward, her new HM would contacted her this week to introduce themselves and work to support her in agreed actions. The HM would also support her to liaise directly with police regarding alleged ASB and criminal damage if she so wished. It said it had asked the Highways team would attend to ensure specification of disabled bay and the parking issues she had raised.
On 19 October 2021, the landlord wrote to the resident referring to a call with her on 18 October 2021 wherein she asked for her complaint to be escalated to stage two as she remained dissatisfied with its response. The landlord agreed it would this within 20 working days.
The landlord’s HM arranged a joint meeting with the police for 21 October 2021, however the landlord’s case note dated 26 October 2021, state that the resident cancelled this appointment as she had a hospital appointment. A second appointment for a joint meeting was made for 26 October 2021. However, the evidence indicates this did not go ahead as the resident and not received notice of this.
The resident called the landlord on 29 October 2021 advising she believed that her car would be damaged again as it was back in the parking bay.
On 9 November 2022, the resident called the landlord reiterating her request for stage two complaint response. She referred to her tyres having been slashed by the neighbours and advised this had caused £3000.00 worth of damage that she reported to the police. She asked for the landlord to move the neighbours from the estate.
Over the next month, the resident sent the landlord various CCTV recordings and photos in support of further ASB reports. The landlord was in contact with the police during this period and tried to arrange a further joint visit to the resident on 30 November 2021, however the police cancelled the appointment on this occasion.
The landlord provided a stage two final complaint response on 9 December 2021. It confirmed its understanding of the complaint and acknowledged the photos and videos the resident had supplied to evidence her concerns of ASB from the neighbours.
It referred to its findings in its stage one complaint that its HM had not discussed her ASB reports with the neighbours against her wishes. It apologised that she was given incorrect information via the customer service centre in this regard.
The landlord said that her ASB reports had been logged and confirmed that it had an active case so she could continue to report incidents. It said its HM had made regular visits with her to ensure she was reporting these.
In relation to parking issues:
1. It had reviewed her reports made in regards to vehicle nuisance by the neighbours, mainly in relation to the manner in which they are parking their cars and use of the cars and said the evidence she had provided did not establish ASB. The landlord said it is not responsible for monitoring parking issues on his street as was for the Highways agency. It has liaised with them to manage her concerns and they advised they were unable to take action on the parking as this is not against their standards. However, to reduce the impact this was having on her ability to use her car, they had installed a disabled parking bay outside her home.
2. It staff had visited her street covertly in order to assess the parking situation on different days and at various times but have been unable to confirm the nuisance being caused.
3. The landlord also referred to various videos recordings supplied by the resident and explained why each recording did not establish behaviour that it deemed to be antisocial.
In relation to the customer’s reports of vandalism and aggressive behaviours by the neighbours, the landlord referred to three different video recordings supplied by the resident that she said showed people flashing torches at her property and into her car and showing a person pretending to hit her car. It explained why it did not consider this evidenced ASB.
Regarding damage caused to her possessions, the landlord acknowledged her submissions that her car and security items such as lights and cameras had been targeted. The landlord also said she had been in communication with the HM to report new instances of vandalism and she had also been reporting these to the police.
It said it had asked her to provide evidence of the damage which she agreed to provide. It had reviewed the photographs of the car tyre however it could not see slash marks on the tyre. It said whilst there were marks from use, it is unclear if this was damage.
The landlord said that the resident had reported other instances of vandalism or nuisance behaviour such as spitting on her car, coming up her path way, attempting to damage her security lights and cameras. However, that she had been unable to evidence this due to faults with her CCTV at the time. Its HM had attempted to arrange joint visits with the police however the most recent appointment was cancelled at short notice due to the police officer having a personal emergency. The HM had agreed to arrange a new visit however she had recently advised that she did not wish for her HM to re-enter her property.
It said it was taking her complaints very seriously however it was unable to evict the neighbours as it required to build a case with evidence in order to raise further. It had offered mediation to discuss the impact of the parking on herself and other persons in the street however she had refused this.
It reiterated that it had agreed to make no contact with those in question to discuss the ASB reports, in accordance with her wishes.
In order to continue investigating her ASB reports, it required her to continue reporting instances to the police and liaising with HM to report instances of ASB.
The landlord also stated for the customer to be aware that she was required to change the position of her camera as it was unlawful for her to record coming and going of the persons in question. Furthermore, it said it was against the terms of her tenancy to record members of the public in their daily life and failure to comply with its request would constitute a breach of the GDPR and it would take action against her tenancy.
On 10 December 2021, the landlord also made an Adult Safeguarding referral to the Council’s Safeguarding team.
On 13 December 2021, the landlord told this service that it had been awaiting information from the police on their visit to discuss the ASB and also the final videos provided by the resident before it provided its stage two response on 9 December 2021.
In her communications to the Ombudsman between 14 December 2021 and 1 February 2022, the resident advised:
1. She was dissatisfied with the landlord’s final response and believed it had “lied” as it had not done anything to help her.
2. She had installed CCTV for her own security and was unhappy with the landlord dismissing recordings showing ASB from the neighbours and challenging her about the CCTV focussing on other properties or public areas.
3. Her doctor contacted her as a result of the Safeguarding referral made by the landlord who understood the impact the ASB were “very sympathetic” and recognised the detrimental impact of the ongoing ASB on her health and wellbeing.
4. The ASB was ongoing.
The resident provided this Service with a copy of her hand written journal of ASB incidents (21 September 2021 up to 20 January 2022).

The landlord’s policies and processes

The landlord’s ASB policy defines ASB as conduct that has caused, or is likely to case, harassment, alarm or distress to any person. This also defines harassment as causing alarm or distress to another person and putting a person in fear of violence.
Its policy sets out nine standards that the landlord should follow when handling reports of ASB. Within its standards it is stated:
1. Reports of ASB are recorded on its internal management system. Where ASB is brought to its attention, it acknowledges this and ensures the complainant is kept up to date with any progress and any on going actions or investigations where appropriate.
2. The intervention it uses varied according to the type of ASB and is decided on a case by case basis. This may include using warning and Acceptable Behaviour Agreements (ABA) and where appropriate it encourages it encourages customers to resolve issues themselves through mediation.
3. It treats all reports of ASB seriously and taken swift action to protect individuals and communities.
4. It works with other agencies, such as police and local authority, to investigate and tackle ASB. The action it takes is carefully considered and staff are aware of the range of tools and powers available to them and partner organisations.
5. It takes appropriate enforcement action against neighbours where it has sufficient evidence to do so and use all the legal powers available to it including ending tenancies and evicting neighbours where appropriate.
6. It reserves the right to close cases where there is no further action it can take or where the parties involve are unwilling to engage in the support it offers.
The landlord operates a two stage complaints process which required it provide a stage one complaint response within 10 working days and a stage two review response within 20 working days.

Assessment and findings

The landlord’s response to ASB reports including concerns about the neighbours’ parking

This Service acknowledges that the resident has been caused significant distress by the situation with the neighbours about which she raised ASB reports to the landlord. Initially her reports related to difficulties with parking as the neighbours parked their multiple cars along each side of the street as well as instances of them fly tipping. However, the resident’s reports progressed to more serious allegations against the neighbours concerning vandalism and damage caused to her possessions as well as harassment.
It is not the Ombudsman’s role to determine if behaviours complained about constitute ASB, however, we consider if, based on the evidence, the landlord took action in line with its ASB policy and acted reasonably in the circumstances of the case when responding to such reports. This review found that overall, the landlord acted reasonably when responding to the resident’s ASB reports. By investigating her concerns, providing appropriate advice and support and working with third party agencies, the landlord followed its ASB policy and demonstrated it took the resident’s ASB reports seriously.
The landlord opened the first ASB case on 1 March 2021, after the resident contacted it in regards to the neighbours parking their multiples cars along the street which she said had caused access problems for emergency vehicles. The HM visited the resident to discuss the issues and notes from the visit show it explained to the resident that it did not monitor parking issues as this was the responsibility of the Council’s Highways Team.
The resident’s property is on a public road where there were no assigned parking spaces, therefore, matters concerning parking would fall within the remit of the Highways agency rather than the landlord, as such its response in this regard was appropriate. However, the landlord was aware of the resident’s vulnerabilities, therefore, in the circumstances it was reasonable to expect it to take steps to facilitate the resident’s application for a disabled parking bay. This is something the landlord told the resident’s support worker it would do. It is not clear if it assisted with this in March 2021 however, when it opened a second ASB case after the resident reported ongoing issues with parking in June 2021, the landlord contacted the Highways team on her behalf to chase up her application for a disabled parking bay. The landlord also enquired with them as to whether they could do anything about the parking issues described. The landlord’s actions in this regard were reasonable.
Following further contact from the landlord as well as the resident herself, the Highways team provided a disabled parking bay outside of the resident’s property on 22 September 2021. Therefore, by liaising with Highways team regarding the disabled bay sought and parking issues, the landlord acted in line with its ASB policy and these steps taken show it was proactive in attempting to resolve the issues raised.
However, in September 2021 the resident reported experiencing intimidating behaviour from the neighbour and she reported that her tyres had been slashed on 27 September 2021, after the disabled bay was installed. She also reported torch lights had been flashed into her security system to prevent footage being recorded and cars were parking too close to her parking bay. The landlord’s response was to offer to speak to the neighbours. This was appropriate as by putting the allegations to the neighbours for their response, this would assist the landlord in deciding what action was most appropriate.
However, the resident reiterated to the landlord that she did not wish for it to discuss her reports of ASB directly with the neighbours. This is something the resident had made clear to the landlord throughout. The landlord’s internal records supports what it told the resident that, at all times, it adhered to her request and did not discuss her reports with the neighbours. However, it is clear that on one occasion in June 2021, the resident was advised by the landlord’s customer service centre that the HM had raised her reports with neighbours. The landlord clarified to the resident at the time that it had not contacted the neighbours and in its final response, the landlord acknowledged and apologised for its miscommunication in this regard. Whilst this would have caused distress to the resident, by apologising and explaining the error, the landlord took reasonable steps to put this right.
The resident’s request for the landlord not to raise the issues with the neighbours was understandable as it was borne out of concern that it would exacerbate the situation. However, to some extent, this limited the action the landlord was able to take. For example, it could not raise the issues with the neighbours or issue any written tenancy warnings about any behaviour that was considered to be in breach of tenancy conditions. The option of getting the neighbours to sign an ABA was also removed. The resident also declined the landlord’s offer to provide mediation on the same basis. Mediation can be a successful tool used by landlords to facilitate resolution between the neighbours in dispute, however this service recognises it may not be appropriate in all instances of ASB.
Nonetheless, as part of its investigation, the landlord increased the number of inspections of the resident’s estate in an attempt to monitor the situation. It also asked the Highways team to check that the markings of the resident’s disabled bay were correct due to her concern raised about this, to which the Highways team confirmed they were. Furthermore, the landlord’s HM continued with visits to the resident’s property to discuss her concerns. These were all reasonable steps to take in the circumstances. In its stage one response, the landlord advised that it had not witnessed any incidents on these inspections and whilst it had been in contact with the police, they had advised they had no incidents logged at that time.
Evidence of the landlord’s internal communications with the police in October 2021 confirm this, therefore this aspect of its response was reasonable although the police later confirmed to the landlord that the resident had in fact reported damage to her tyres to them on 27 September 2021, indicating the previous advice given to the landlord was incorrect.
The resident advised the landlord throughout, including in her formal complaint, that the resolution she desired was for it to move the neighbours from their property. Although the landlord told the resident in its final response that there was insufficient evidence for it to take steps to evict the neighbours, there is no clear evidence to show it managed the resident’s expectations around her request prior to the final response. Whilst under its ASB policy, the landlord is able to take enforcement action to evict a perpetrator, this usually only happens where there is evidence of serious breaches of the tenancy. On balance, the landlord’s failure to explain to the resident its ASB policy an earlier stage, including the circumstances it would take enforcement action, shows a failure in the service provided.
The resident had CCTV installed in October 2021 and provided a number of recordings to both the landlord and the police in support of further ASB reports made, including a further incident of damage to her car and instances of the neighbours harassing her (putting two fingers up at her).The new HM appointed to the resident’s case in early October 2021 liaised with the police and made a number of attempts to arrange a joint visit to the resident with the police to discuss the ASB she had raised. The evidence indicates this did not go ahead as either the resident or the police officer cancelled for different reasons. Nonetheless, by communicating with the police in regards to the reported issues including vandalism and damage, the landlord acted in accordance with its ASB policy which requires it to work with other agencies to investigate and tackle ASB.
In its final response, the landlord provided a detailed explanation as to why each of the video recordings did not demonstrate ASB or any tenancy breaches by the neighbours. It also advised that, due to a lack of substantive evidence to prove ASB, it would not pursue evicting the neighbours. Whilst the resident was understandably disappointed with this, it is clear that the landlord fully assessed all of the evidence including the recordings provided by the resident in support her allegations before reaching this conclusion. This service has had sight of the CCTV recordings and is mindful of the evidence showing the police reached the same conclusion as the landlord. In the circumstance, the landlord’s response was appropriate and in accordance with its ASB policy.
As the resident’s reports were ongoing around the date of the final response, it was important that the landlord kept her ASB case open which it did. In the final response, the landlord also urged the resident to continue to report any further incidents to both it as well as the police so they could investigate and take action against neighbours where relevant. This advice was appropriate.
The landlord in its final response requested the resident to alter the position of her CCTV as it was recording footage of the neighbours going in and out of their property and went beyond the curtilage of the boundary her property. Whilst the resident has confirmed to this Service that she had installed CCTV for her personal security, the landlord’s advice was appropriate as footage that allows an individual to be identified may be subject to the GDPR. It is clear from the recordings that the CCTV extended beyond the boundary of the resident’s property as such it was reasonable for the landlord to request that she alter its position. The resident has told this service she was unhappy with the landlord’s tenancy warning given regarding failure to comply with this request. In the circumstances this is understandable however, the landlord had a duty to ensure the resident understood the consequence of not acting upon its request. On balance, this does not demonstrate any failure in the service provided by the landlord.
The landlord made a safeguarding referral to the local authority safeguarding team in December 2021 due to concerns about the resident’s wellbeing. The landlord has a duty to ensure resident’s have access to support where needed and the landlord’s internal communications show it made this decision after an internal meeting with different teams following its receipt of both text and email communications from the resident regarding ASB. In the circumstances, it was reasonable for the landlord to make a safe guarding referral to check the resident was receiving appropriate support.
In summary, whilst there were two minor failures in the service provided, overall the landlord took sufficient and reasonable steps in the circumstances to resolve the issues raised concerning parking and ASB as well as providing appropriate support to the resident.
The service notes that the landlord told us that it had no vulnerabilities recorded on its system for the resident. As it is clear that the resident has disabilities, a recommendation has been included below for it to amend its records to reflect this.

Complaint handling

The landlord issued it stage two final response on 9 December 2021. As the resident first asked it to escalate the complaint to stage two on 18 October 2021, this shows it took the landlord more than 40 working days to provide its final response. This was after the resident reiterated her escalation request on 9 November 2021. This is evidence of it not providing its response in accordance with the 20 working day timescale stated in its policy
The landlord told this Service that it was awaiting evidence from the police and the resident. Nonetheless, this is not sufficient reason to delay with providing the final response within the timescales set out in its policy. This is evidence of a service failure by the landlord whilst handling the resident’s complaint.

Determination (decision)

In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was no maladministration by the landlord when responding to ASB reports including concerns about the neighbours’ parking.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was service failure by the landlord when handling the related complaint.

Reasons

In response to the resident’s ASB reports about the neighbours, the landlord took action in accordance with its ASB policy. However, the tools available to it to tackle ASB were limited due to the resident making clear she did not wish it to raise her reports to the neighbours. Nonetheless, it acted reasonably by investigating her concerns, providing appropriate support and working with third party agencies demonstrating it took the resident’s ASB reports and wellbeing seriously.
There was a delay by the landlord in providing the resident with its final complaint response which prolonged the complaints process.

Orders and recommendations

The Ombudsman orders that the landlord:
1. pay the resident £100 in compensation in respect of its service failure whilst handling her complaint.
2. comply with the above order within four weeks.
The Ombudsman recommends that the landlord:
1. reviews what steps it can take to better manage resident’s expectations around the circumstances it would seek to evict a perpetrator of ASB where relevant.
2. update its system to reflect that the resident has disabilities.