Mid Suffolk District Council (202127679)

REPORT

COMPLAINT 202127679

Mid Suffolk District Council

10 May 2023

Our approach

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

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

The complaint

The complaint is about the landlord’s handling of the resident’s:
1. reports of multiple repairs to her property;
2. associated complaint.

Background

The resident holds an assured tenancy with the landlord that began on 20 May 2016. The property is a three-bedroom semi-detached house with a garage. The landlord is a council.
The landlord had no vulnerabilities recorded on the resident’s record.
The resident’s complaint and email communications with the landlord were made on her behalf by her mother. References to ‘the resident’ in this report will refer to either the resident or her mother.

Complaint policy

The landlord’s policy states that it operate a two-stage complaint process. Complaint responses are sent to residents within 10 and 20 working days at stage one and two respectively of the complaints procedure. Where additional time is needed, this may be extended by up to 10 further working days, which will be advised to the resident.

Compensation Policy

The landlord’s compensation policy details the compensation levels under the ‘Right to Repair’ regulations.
The policy describes instances where discretionary compensation payments are appropriate. This includes where a complaint has been handled poorly, significant delays in providing a service and distress and inconvenience caused by the landlord’s actions or inactions. It states that the Ombudsman’s Remedies Guidance is one of the factors considered in calculating compensation payments.

Repairs policy

The landlord has advised it does not have a standalone repairs policy, but its repair responsibilities are set out in the tenancy agreement. The repairs records provided by the landlord to this Service indicate that routine repairs have a target completion date of 28 days from when they are reported.

Summary of events

The landlord’s repairs records said that in February 2020, it had responded to the resident’s report of a leak in her bathroom. The leak was getting through the ceiling of her downstairs toilet. The subsequent repairs were completed in March 2020.
On 14 December 2020, the resident reported mould above the windows and in the corners of two of her bedrooms, as well as in the bathroom. The landlord raised a repair ‘note’ with a target completion date of 7 January 2021.
On 23 April 2021, the landlord raised an inspection request for a specialist contractor to complete a damp and mould inspection of the resident’s property and provide the landlord with a report. The target completion date was 24 May 2021.
On 1 June 2021, the landlord raised jobs for the resident’s property that included cracks in the ceilings of the bathroom, bedroom and kitchen, cracks in her wooden garden fence, and a crack in an external side wall. The landlord’s repair record stated that the repairs had been reported by the resident via telephone and were completed on 29 June 2021.
On 2 June 2021, the landlord attended the resident’s property to inspect the resident’s report of a bathroom leak. It assessed that the bathroom could be repaired rather than replaced and raised various jobs accordingly. The job notes also instructed that a ‘clean and chalk’ should be completed below the coving downstairs in the resident’s property.
On 16 June 2021, the landlord raised a further job for the resident’s bathroom for items including tiling, the bath panel and the shower curtain and rail. The landlord’s records indicated there had been complications with the bathroom works, and that they had overrun.
On 18 June 2021, the landlord’s records noted that bathroom tiles fitted by the resident needed to be removed, and the wall covered with a ‘mermaid board’. It noted the mermaid board would have to be put on ‘special order’. The landlord’s specialist contractor completed a separate damp and mould inspection of the resident’s property the same day.
On 9 July 2021, the landlord’s record stated that there had been difficulties with its supplier providing the mermaid board, but that it had been received that day. It noted that it would return and complete the bathroom works on 15 July 2021 and had booked this in with the resident.
The resident’s letter of complaint was sent to the landlord on 13 July 2021. It was written by the resident’s mother and explained that the resident had recently suffered a family bereavement and was extremely distressed. The complaint concerned the landlord’s repairs service and listed several repairs that it said had been reported in late May and early June 2021. The key repairs were as follows:
1. A bathroom leak that had also occurred previously.
2. A dripping cold tap in the downstairs toilet.
3. An external wall crack.
4. Cracked walls and ceilings in the bathroom, bedroom and kitchen.
5. Damp by the window and on a wall in the bedrooms.
6. The garage door could not be opened, which had originally been reported in 2019.
The resident’s complaint letter said that the landlord had attended her property on 7 June 2021 and decided the bathroom needed to be replaced. The landlord had called the resident and told her this would be done on 10 and 11 June 2021. The resident had explained that this was when her relative’s funeral was taking place and was upset by the lack of sensitivity in the landlord’s response. The landlord had called the resident again a day or two later and told her the work would now begin on 14 June 2021. The resident’s key points concerning the repairs were as follows:
1. The resident’s own bathroom flooring and tiles had been removed and replaced with the landlord’s materials.
2. The plumber would not repair the dripping downstairs tap while he was there and so the resident had reported it again. She had still not received an appointment nor any communication about it.
3. The bathroom works were partly completed and it was usable with care. The resident was told it would be finished in a few days, but it was not booked to be completed until 15 July 2021.
4. The operatives had not properly cleaned up after themselves, there was mould left around the bathroom pipes, the flooring was lifting, and wooden boxing that had been removed had not been replaced.
5. The landlord’s specialist contractor had said the mould around the bedroom window was due to it not being opened, and the mould on the bedroom wall was due to cuddly toys. The resident disagreed with these findings and asked that it be looked at again.
6. The garage door was inspected on 12 July 2021 and needed replacing. She hoped this did not take as long as the bathroom.
7. She had received no information about the other reported repairs and felt the landlord’s communication was poor.
On 15 July 2021, the landlord’s specialist contractor sent the landlord its damp and mould report from its inspection completed at the resident’s property on 18 June 2021. The specialist contractor’s key findings and recommendations were as follows:
1. Mould was forming around the window reveals in two bedrooms. The window trickle vents were full of dirt preventing ventilation. The mould was as a result of condensation.
2. Mould was forming above the skirting on the wall in one corner in the rear left bedroom. The contractor had noted that there were stored items wedged between the wall and the end of the bed preventing adequate heat and ventilation. This was causing the mould on the wall. It had recommended to the resident that she remove the items and clean off the mould.
3. Mould was forming in the bathroom and kitchen, and neither had extractor fans installed. It recommended the landlord fit an extractor in both rooms and also check the loft insulation.
4. Readings were taken on the ground floor walls but did not indicate the presence of moisture. It concluded that the issues were being caused by condensation. It recommended a positive input ventilation unit be installed in the resident’s property and provided a quotation.
On 19 July 2021, the landlord raised a job for extractor fans to be installed in the kitchen and bathroom. It also booked an appointment to visit the resident on 23 July 2021.
The landlord sent a stage one complaint response to the resident. The copy provide to this Service was undated. It said that it had received the complaint on 16 July 2021. It thanked the resident’s mother for making the landlord aware of the resident’s circumstances, which would allow it to manage matters in a sensitive manner. It stated that the resident’s complaint had been upheld. It advised the landlord had agreed to meet the resident at her property on 23 July 2021. It said its intention for that visit was to discuss the situation with the resident, and to survey and schedule the outstanding works with a view to resolving the complaint.
The landlord’s record stated that its repairs team leader had visited the resident on 23 July 2021 and spent a ‘couple of hours’ discussing the complaint and repairs. The record listed the remedial works it raised following the visit.
The landlord’s record stated that the works agreed on 23 July 2021 began on 5 August 2021. The record said that the attending operative had an apprentice with him, who the resident had thought was his son and had objected. It referred to the apprentice leaving a gate open and the resident’s dogs getting out. It explained that the resident had raised various complaints about how the work was being completed, and dirt left on the stair carpet. She had asked that works be stopped, and that after various discussions the incomplete works were put on hold.
The landlords record said that works continued on 10 August 2021, but that the resident was finding it too stressful and had again asked for them to be stopped. The resident had said that she would move home instead, and the landlord’s repairs team had referred the matter to its housing team.
The landlord’s internal email on 10 August 2021 provided an update on an application received from the resident to move home, which it said was being processed as quickly as possible.
On 13 August 2021, the landlord raised works for the resident’s stair carpet to be cleaned.
On 20 August 2021, the landlord raised a job to redo the boxing around the area of the resident’s toilet.
On 3 September 2021, the landlord placed an order for a positive input ventilation unit to be installed in the resident’s property, to assist with the management of condensation.
The resident wrote to the landlord on 24 September 2021. The letter noted that it was an “update from original complaint”. The key points were as follows:
1. The resident requested an urgent face to face meeting with the landlord, as there were too many issues to list.
2. It said that the landlord’s repairs team leader had been visiting and contacting the resident since her complaint. She had been very helpful but had been unable to resolve all of the issues, and new ones had arisen.
3. The property was not fit for purpose and the resident needed to be moved to a large four-bedroom property as soon as possible.
The landlord’s repairs team leader sent an internal email to its customer team. The copy provided to this Service was undated. It indicated that the resident had said, “she doesn’t do technology”. The resident had been struggling to email the landlord’s customer team and so had sent her complaint email on 24 September 2021 directly to the repairs team leader. The records indicated that there was an unknown delay in the repairs team leader picking up the email. When she did pick up the email, she forwarded it to the customer team as a stage two complaint escalation request. The date of this is unknown.
The landlord emailed the resident on 6 October 2021 and said it had begun investigating her stage two complaint. It said it had until 21 October 2021 to respond, and that it may need to extend this a further 10 days. It listed the repairs from the resident’s original complaint and asked that she confirm that this covered everything.
The resident replied to the landlord’s email on 13 October 2021. She said she had requested a face to face meeting due to the volume of issues, but she would do her best to list them. The key points were as follows:
1. The only jobs from her original complaint that had been completed were the internal cracks and the garage door.
2. The landlord’s repairs team leader had visited the resident on 23 July 2021. She had inspected the property and raised a number of additional repairs. Some of these had been done but the following issues were outstanding:
  1. Mould treatment completed in the bedroom and downstairs toilet had taken the original paint off and so the walls needed repainting.
  2. A blown window had been repaired but was still stuck shut.
  3. Two attempts to clean the landlord’s operative’s footprints from the stair carpet had been made but it still was not clean. She asked that the carpet be replaced.
  4. The bathroom renewal and repairs had been done to a poor standard with multiple issues.
  5. The resident had been advised by an operative that there was still a leak in the new bathroom but that they did not know where.
  6. The leaking tap in the downstairs toilet had been completed to a poor standard. The landlord’s contractor had brought his son with him, who had let the resident’s dogs get out after being asked to make sure he did not. The resident asked that the downstairs toilet room be fully redecorated.
  7. The bedroom window had blown, and the extractor fitted in the bathroom had stopped working. Neither of these had been reported to the landlord as the resident needed a break from repairs.
  8. She had been told a vent needed to be fitted in the loft but had heard nothing further about it.
  9. The landlord’s communication had been poor with lots of waiting in for repairs people to arrive, and appointments getting changed or cancelled.
3. The landlord’s team leader had queried why the resident had a bed in the lounge. The resident had explained the health reasons why her two daughters could not share a bedroom, and hence why she had requested a transfer to a four-bedroom property. The form completion for the application process had been difficult and the landlord was dealing with it too slowly.
4. The resident asked her complaint to be resolved by arranging a move for her as soon as possible to a four or five bedroom house, with removal expenses paid by the landlord. She explained the geographic requirements necessary for her daughter to continue attending her specialist school.
On 9 November 2021, the landlord’s customer liaison officer visited the resident to discuss and try to resolve the complaint. The visit lasted around two hours and the landlord has said that the resident was reluctant to agree to works due to the impact they were having on her mental health. It was agreed the customer liaison officer would remain in contact with the resident while her complaint was progressed. The landlord said that the repairs team leader who had attended at stage one of the complaint was no longer in post, but it was agreed a further property inspection would be completed as soon as it was able to.
At the start of December 2021, the resident and landlord exchanged several emails discussing potential complaint resolutions. The resident’s emails made reference to a telephone discussion with the landlord on 29 November 2021, discussing the same.
On 3 December 2021, the landlord’s new repairs team leader attended the resident’s property to complete an inspection. A number of repairs and redress items were agreed, which the landlord detailed in its subsequent stage two complaint response.
On 8 December 2021, the resident emailed the landlord. She thanked it for the conversation that morning and provided her bank details as requested.
On 10 December 2021, the landlord sent its stage two complaint response letter to the resident (the copy provided to this Service was dated 10 November 2021 but the landlord has confirmed this was a typographical error). It apologised for the extent of the works that had been needed to the resident’s property. It referred to its visits to the resident’s property on 9 November 2021 and 3 December 2021, and thanked her for her time. It provided responses to each of the property issues raised in the resident’s complaint. The key points were as follows:
1. Bathroom leak
  1. A new bathroom had been fitted, including flooring, boxing and a mermaid board. The landlord’s new materials had been used as the existing material fell below the required standard.
  2. The landlord had advised that redecoration was the resident’s responsibility. However, it accepted how unhappy the resident was with the time taken to complete the works, and so had agreed to redecorate the bathroom.
  3. The resident was unhappy with the standard of finishing of some of the works, along with footprints left on her stair carpet. Works had been raised to address these issues and the carpet would be professionally cleaned.
2. Downstairs toilet
  1. The works had been completed but the resident was unhappy with the standard and the lack of decoration. The landlord had advised that redecoration was the resident’s responsibility but had agreed to complete it as an option for redress.
  2. The landlord apologised for the delays in completing these works, and that the door had been left open allowing the resident’s dogs to get out.
3. External wall crack
  1. The landlord explained that the issue was not a structural crack but mortar had come out from between some bricks. It advised that it was not advisable to remedy mortar works in the winter, but it would be completed in the warmer months.
4. Internal cracks
  1. All works had been completed, and any remaining minor decorative cracks fell under the resident internal decoration responsibilities.
5. Garage, garden fence and gate
  1. All works had been completed. The resident had subsequently highlighted that she had been told the garage was subsiding, and this would be actioned in April 2022.
6. Damp in bedrooms
  1. Works had been completed. At the landlord’s recent visit, it was identified that some mould had since reappeared, and the resident had raised concerns that there was still a leak in the property.
  2. The landlord said it had taken the correct steps in getting a damp survey completed and must act on the advice of its specialist contractors. Its report had not identified any leaks but had identified condensation.
  3. The landlord would now arrange for an ‘independent operative’ to visit and identify any outstanding repairs, including areas of damp or mould.
7. Additional items raised at stage two
  1. A loft vent and ‘infinity fan’ were still to be installed. It asked that the resident let the landlord know when she was ready to allow works to resume at her property.
  2. The landlord had spoken with the relevant council staff and would make sure the correct people would assist with the resident’s application to move. The resident had been assessed as having a four-bedroom housing need.
  3. The landlord apologised for the resident’s dissatisfaction with its communications. It said that the repairs team leader who had visited at stage one of its complaint process had remained as a point of contact for the resident and helped however she could.
The landlord’s stage two complaint response concluded by apologising for the number of repairs that had been needed, and for the communication and workmanship issues the resident had experienced. It also apologised for the delays in completing the works. It explained that some of these delays had been at the resident’s request when she had asked for works to be stopped or postponed, and that some were as a result of the Covid-19 pandemic. However, it accepted there were also times when it had not attended when the resident had expected. It offered the following redress:
1. £700 compensation for the repairs delays, poor communication and distress caused.
2. Redecoration of the bathroom and downstairs toilet.
3. Professional cleaning of the stairs carpet.
4. A single point of contact to assist with the resident’s repairs and property move queries.

Summary of events after the completion of the landlord’s complaint process

The landlord has said that the works related to the complaint were all completed. This included works relating to the further damp and mould identified at the landlord’s inspection on 3 December 2021, which it said were finalised on 28 January 2022. The landlord’s repair records stated that it completed the redecoration of the resident’s bathroom and downstairs toilet on 17 February 2022.
This Service has seen emails sent from the resident to the landlord from March 2022 expressing dissatisfaction with new repair issues and the single point of contact communication process that the landlord had put in place with her.
The resident emailed this Service in April 2023. She advised that a transfer to a four-bedroom property of another landlord had fallen through in October 2022, due to unforeseen issues with that property. As such, she was still waiting to be rehoused. The resident expressed her dissatisfaction with the landlord’s handling of multiple new repairs issues and the condition of the property. This Service explained to the resident that the scope of this investigation regarded her complaint that concluded the landlord’s process in December 2021. It advised of her right to log a further complaint with the landlord about any matters that have occurred since that time.

Assessment and findings

Repairs handling

The landlord’s repair records show that the resident reported mould forming in her property on 14 December 2020. The landlord did not raise its request for a specialist contractor to inspect until 23 April 2021 and the contractor did not attend until 18 June 2021. The landlord’s repair records indicate that repairs should be attended within 28 days of being reported. The landlord has subsequently said that the delays were due to Covid-19 restrictions in place at that time. Whilst that was likely the case, the Ombudsman would have expected to have seen evidence that this, and further updates, were communicated to the resident, along with interim advice for dealing with the mould. The Ombudsman has seen no evidence of any associated communications, and this was therefore unreasonable.
The landlord raised works for the cracking repairs referred to in the resident’s complaint, on 1 June 2021. The works order states that they were completed on 29 June 2021, which was appropriately in line with the landlords 28-day target.
The landlord received the report and recommendations of its specialist damp and mould contractor on 15 July 2021. It was appropriate for the landlord to act on the specialist’s recommendation to install extractor fans, and that this work was raised on 19 July 2021. It is unclear why the landlord waited until 3 September 2021 to raise works in line with the recommendation to install a positive input ventilation unit, or whether this was communicated to the resident. Whilst there may have been appropriate reasons for the landlord holding back this job, the Ombudsman has again seen no evidence of any associated communication with the resident, and this was therefore unreasonable.
The landlord raised works for the bathroom leak on 2 June 2021. Whilst it initially attended within its target timeframe, the works order states that repairs were not completed until 1 November 2021. The landlord explained that the delays were due to a combination of Covid-19factors, postponements at the resident’s request, and its own service failures. The resident had recently suffered abereavement and would have been extremely distressed. The Ombudsman recognises that this would have made the upheaval and inconvenience of the works even more stressful for the resident. The landlord’s repair records did refer to occasions where the resident had asked for works to stop. The resident’s emails also made reference to work being able to startagain after the school holidays, but it was appropriate for the landlord to accept its own part in the delays.
The landlord accepted and apologised to the resident for the distress caused by its poor communications and those repairs delays it was responsible for. It offered the resident £700 compensation, the redecoration of two rooms she would otherwise be responsible for, and the professional cleaning of her stair carpet. The resident experienced over a year of disruption from when she first reported the damp issue. This included around six months between her reporting the bathroom leak and the landlord completing the works. Whilst the landlord was not solely responsible for those delays, it has evidenced very little communication with the resident through the process. This would have worsened what was already a very difficult period for the resident.
The landlord’s compensation policy states that it considers the Ombudsman’s Remedies Guidance when calculating payments. The Ombudsman’s Remedies Guidance suggests payments of between £600 and £1000 where there has been significant impact on the resident as a result of maladministration. The Ombudsman considers this to be a fair reflection of the impact on the resident from the identified service failings in the landlord’s handling of her repairs. As such, the decoration, carpet cleaning and £700 paid by the landlord to the resident represented reasonable redress for this element of the resident’s complaint.

Complaint handling

The resident’s mother sent her letter of complaint to the landlord on 13 July 2021. The copy of the landlord’s stage one response provided to this Service was undated but referred to its upcoming visit on 23 July 2021. It was appropriate that the landlord met the 10-day timeframe to respond to the resident, as stated in its complaint policy. It was reasonable that it advised the resident her complaint had been upheld. However, the Ombudsman would expect the landlord to have made more progress towards resolving a complaint within this timeframe, beyond just the offer to visit that constituted its stage one complaint response to the resident.
The landlord’s repairs team leader visited the resident on 23 July 2021 and it was appropriate that she appears to have spent significant time discussing the issues with the resident and agreeing a way forward. It was also reasonable that she maintained contact with the resident after this time, and the resident was grateful for her efforts.
The resident’s mother sent the landlord her stage two complaint escalation request on 24 September 2021. There was some delay in the landlord’s correct team receiving it, and the resident’s mother had made clear that she struggled with the use of computers and email. She requested a face-to-face meeting due to the volume of issues she wished to discuss. It was reasonable for the landlord to advise on 6 October 2021 that it would aim to respond by 21 October 2021, but that it may need an additional 10 days in line with its policy. However, given the resident’s mother’s request for a meeting, and her stated computer difficulties, it would have been appropriate to agree to the resident’s mother’s request for a meeting. It was therefore not reasonable that the resident’s mother was left to explain the issues over email, which she did on 13 October 2021.
The landlord visited the resident on 9 November 2021 and it was appropriate that it again spent significant time trying to agree a resolution. The landlord provided no further records of contact in November 2021 although it would seem likely some occurred, as a cordial email from the resident to the landlord in early December 2021 gave thanks for the discussion with the it on 29 November 2021.
In reaching a decision in these circumstances, the Ombudsman’s role is to determine if the landlord has acted reasonably in its complaint handling. In considering this, the Ombudsman takes into account whether the landlord’s actions and any offer of redress were in line with the Ombudsman’s Dispute Resolution Principles: Be fair, Put things right and Learn from outcomes.
It was reasonable for the landlord to take a resolution focused approach to the resident’s complaint. Several emails were exchanged with the resident in early December 2021 discussing possible resolutions and appropriate redress. It was appropriate for the landlord’s newly in post repairs team leader to complete an inspection of the resident’s property on 3 December 2021, to further progress the complaint resolution.
The resident agreed to the landlord’s resolution and provided her bank details for payment of the compensation on 8 December 2021. The landlord’s resolution focused approach involved significant discussion and negotiation with the resident. It may have been the case that the landlord agreed with the resident that it would prioritise achieving a satisfactory resolution, above meeting the stage two response timeframe of its complaint policy. If this was the case, the Ombudsman would expect the landlord to have agreed this in writing with the resident ahead of its complaint response deadline on 21 October 2021. As there is no evidence that this occurred, it was not reasonable that the landlord’s complaint response was sent 36 days after the timeframe stated in its own policy.
It is the view of the Ombudsman that the landlord’s resolution focused approach demonstrated that it did in the main act in line with the first two Dispute Resolution Principles to be fair and put things right. However, there is little evidence that the landlord learnt from the outcomes of the complaint. The resident’s complaint was largely about delays and poor communication. This placed even greater emphasis on the landlord handling the resident’s complaint in a timely manner and keeping her appropriately updated through the process.
The landlord’s complaint response was sent well beyond the timeframe of its own policy and it was unable to evidence it had kept the resident appropriately updated. The landlord’s complaint responses did offer appropriate apologies to the resident, but gave little insight into what it had learnt or how things might change to avoid similar fault in future. The resident’s later similar complaints to the landlord, that are still ongoing at the time of this investigation, further support that it had not learnt from the outcomes of this case. As such, the landlord’s failure to respond to the resident’s complaint within the timeframes of its own policy, and its failure to demonstrate learning, were unreasonable and constitute maladministration.

Determination (decision)

In accordance with paragraph 53(b) of the Housing Ombudsman Scheme, the landlord has offered redress to the resident prior to investigation which, in the Ombudsman’s opinion, satisfactorily resolves the complaint about its handling of the resident’s reports of multiple repairs to her property.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration in respect of the landlord’s handling of the resident’s associated complaint.

Reasons

The delays in the landlord’s handling of the resident’s repairs were not solely attributable to service failures. However, the landlord accepted that there had been failings in terms of the time taken, workmanship and communications. The redress actions taken by the landlord, and the £700 compensation it paid to the resident, were in line with both its own policy and the Ombudsman’s Remedies Guidance. It therefore represented reasonable redress for this element of the resident’s complaint.
The landlord did demonstrate a resolution focused approach in its complaint handling, and made reasonable efforts to be fair, and put things right. However, it failed to demonstrate it had learnt from the outcomes of the resident’s complaint, and failed to respond to her within the timeframes of its own policy, or evidence it had communicated effectively. This would have prolonged the distress experienced by the resident at what was an already emotionally challenging time for her.

Orders

The Ombudsman orders that the landlord write to the resident to apologise for the service failures identified in this report.
The Ombudsman orders that the landlord pays the resident further compensation of £250 for the distress and time and trouble caused to her by the identified service failures in its complaint handling.

The landlord should confirm compliance with these orders to this Service within four weeks of the date of this report.

The Ombudsman orders that the landlord review its record keeping processes with particular regard to telephone and in-person resident communications, and provide an action plan of its intentions to make improvements within eight weeks of the date of this report.