Lambeth Council (202303637)

REPORT

COMPLAINT 202303637

Lambeth Council

30 August 2024

Our approach

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

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

The complaint

The complaint is about the landlord’s response to:
1. Reports of damp and mould in the hallway, bedroom and bathroom.
2. Reports of personal belongings damaged by damp and mould.
3. Requests to replace fencing panels.
4. The complaint.
This investigation has also considered the landlord’s record keeping.

Jurisdiction

What the Ombudsman can and cannot consider is called the Ombudsman’s jurisdiction. This is governed by the Scheme. When a complaint is brought to this service, the Ombudsman must consider all the circumstances of the case, as there are sometimes reasons why a complaint will not be investigated.
Paragraph 42(a) of the Scheme says the Ombudsman may not investigate complaints which have not completed the landlord’s internal complaints process, unless there is evidence of a complaint handling failure and the Ombudsman is satisfied the landlord has not taken action within a reasonable timescale.
The records seen show that when the resident made the landlord aware of the extent of the mould in January 2022, he did say that the mould had spread and damaged property. Although no details have been seen regarding what items were damaged or to what they were damaged.
However, this issue was not included in the resident’s stage 1 complaint nor was it raised when the resident escalated their complaint to stage 2 through this Service.
As this appears to be a separate issue to those raised in the resident’s original complaint to the landlord, it is not a subject the Ombudsman can make a determination on at this stage because the landlord needs to be provided with the opportunity to investigate and respond to it.
The resident will need to contact the landlord and, if appropriate, raise a separate complaint to get these matters resolved. Alternatively, the landlord can contact the resident to obtain further details about the damaged personal items before advising of appropriate next steps.

Background and summary of events

Since 21 January 2021 the resident has been a secure tenant of a 1 bed ground floor flat. The resident is a wheelchair user and the property is adapted to accommodate their needs. The landlord is a local authority.
On 3 March 2022 the resident raised a stage 1 complaint about various repair issues which he said had been outstanding since January 2021, some of which had been due for repair before he moved in. He listed the following outstanding works:
1. The disability frame around the toilet was rusted through and the arms had broken off with rust. It was also unadjustable.
2. The fencing around the garden had collapsed before he moved in.
3. Mould and water structural damage from an upstairs leak had not been fixed in over 6 months.
4. Rising damp, structural damage and mould damage in the bedroom rendering it unusable. He stated that he had been sleeping on the sofa for weeks.
An appointment was made for a contractor to attend the property on 19 September 2022. However the appointment was then rescheduled to 5 October 2022 due to the Queen’s funeral as this was a bank holiday. On 5 October 2022 waterproofing works were completed.
The resident contacted the landlord on 1 December 2022 and reported that previous mould washes had not worked, and it was growing again in the bathroom, bedroom and hallway.
The landlord issued its stage 1 complaint response on 13 December 2022 and stated the following:
1. An order to fix the fence had been made on 16 September 2021 but when they attended on 15 October 2021 the work could not be completed due to the need to cut back the trees and shrubs around the fence. As the work could not be completed until this was done the resident had said they would contact the landlord about this, the order was later closed as the contractor had not received an update to say the garden had been cleared. The landlord said it had spoken to the neighbourhood manager about arranging for the bushes to be trimmed and asked the resident to contact its contractors to discuss how to secure the garden.
2. The resident spoke to the landlord about the mould on 25 November 2022 and an order was raised for a mould wash on 1 December 2022. A damp inspection by a surveyor was also raised on 8 December 2022. The responsive repairs team would be in touch to arrange an appointment.
3. The landlord offered £250 as a gesture of goodwill for the delays in service, inconvenience caused, the time and trouble caused by the resident having to chase the works.
Works to fix the mould were started on 2 February 2023 and continued until 20 June 2023.
On 21 June 2023 an order to repair the fence was raised. Although it was noted in July 2023 that while the order had been marked as closed, the contractor had only taken photos but no work had been undertaken on the fence. A new order was raised on 4 August 2023 and the works were completed on 23 August 2023.
The resident escalated their complaint to stage 2 through this Service on 6 September 2023, they then spoke to the landlord on 18 September 2023. The landlord’s records of this call say the resident confirmed “the issues with the back fence & the D/M (damp and mould) have now been resolved, but the Ombudsman still want to know why it took 2.5years to fix”.
The stage 2 complaint response was issued on 27 September 2023 and provided the following outcomes:
1. Between 16 September 2021 and 5 October 2022 multiple attempts were made to rid the hallway of damp and mould. The landlord’s repairs manual says this type of work can take between 28 to 90 days to be completed, in this instance each phase of work had been completed within the 90 day period.
2. An order for the damp and mould in the bedroom and bathroom was raised on 8 December 2022. Its notes for 6 February and 1 March 2023 say that more time was required. A contractor attended on 18 April 2023 and follow on work was scheduled for 7 and 8 June 2023. These were then completed on 14 June 2023.
3. The fence repair was first reported on 16 September 2021, but overgrown greenery prevented the works completion until 20 June 2023. The work was delayed while the contractors awaited confirmation that the greenery had been removed and apologised that works were not completed in a reasonable timeframe.
4. The landlord offered £500 compensation for the delay to the replacement of the fence as well as works on the bedroom and bathroom.
The resident contacted the Ombudsman on 5 October 2023 and said they wanted us to investigate the complaint because several dates given by the landlord were incorrect, but it also did not address:
1. Why it took 11 months to fix the damp and mould in the bedroom and bathroom. The landlord also did not address that the resident had informed it multiple items had been damaged and that the bedroom had been unusable.
2. Why it took over 2 and half years and constant chasing by the resident to fix the fence. Additionally, they had not addressed why the voids team failed to secure the property before he moved in or that while the fence was left broken there were security problems with intruders.
3. The landlord never addressed his complaint points about the rusted disability frame. It was agreed this would be replaced before he moved in but it was not done until 29 March 2022, over a year later.

Assessment and findings

Scope of this investigation

In the resident’s correspondence, he has referred to historical issues of damp and mould in the property and reports made to the landlord. Under Paragraph 42(c) of the Scheme operated at the time, the Ombudsman may not consider complaints that were not brought to the attention of the landlord as a formal complaint within a reasonable period, which would normally be within 6 months of the matters arising. Therefore, whilst the historical incidents provide contextual background to the current complaint, this assessment focuses on events from October 2021 onward, which is 6 months prior to the formal complaint being made.

Landlord’s response to reports of damp and mould

Section 11 of the Landlord and Tenant Act 1985 places a statutory obligation on the landlord to keep the structure and exterior of the property in repair. The landlord also has a responsibility under the Housing Health and Safety Rating System, introduced by The Housing Act 2004, to assess hazards and risks within its rented properties. Damp and mould growth are a potential hazard and therefore the landlord is required to consider whether any damp and mould problems in its properties amount to a hazard and require remedying.
The landlord’s repairs policy states that planned repairs will be completed between 28 to 90 days, this includes non-urgent work to prevent problems arising in future.
The landlord’s damp and mould policy states that it prioritises the removal of mould, with the initial wash and treatment being carried out within 7 days of a report. Additionally, it says that:
1. The landlord will arrange an inspection to diagnose the issue within 28 days or sooner in emergency situations.
2. It will agree and write an action plan with the resident to resolve the damp, including timeframes.
3. If there is persistent damp a surveyor will be allocated to act as a Healthy Homes Partner, they will arrange the necessary work and stay in touch until it is completed.
The Ombudsman’s Spotlight Report on damp and mould (2021) sets out what is expected from landlords where damp and mould are concerned. It says landlords should take a zero-tolerance approach to damp and mould, carry out proactive intervention, communicate effectively with residents and, where significant works may be required, it should consider whether the resident is vulnerable and should be moved from the property at an early stage.
The Ombudsman’s March 2019 Spotlight Report on repairs sets out the expectations the Ombudsman has for landlords where repairs are concerned. The report says landlords should keep clear, accurate, and easily accessible records of residents’ reports of disrepair and the landlord’s responses, including details of appointments, any inspections, any work carried out, and completion dates. Landlords should also monitor the progress of any reported repairs and comply with the repair timescales set out in their policies as far as possible. When it is not possible to comply with the timescales set out in its policies, a landlord should communicate the reason for the delay with its resident.
As the instances of damp and mould have different histories, each will be addressed individually.

Damp and mould in the hallway

In May 2021 there was a leak in the flat above the resident’s property and this came through into their hallway.
The records seen show that on 16 September 2021 the resident called the landlord regarding outstanding works following recommendations by an occupational therapist, including the need for damp proofing and a mould wash in the hallway.
On 24 September 2021 the landlord’s contractor attended and completed a mould wash on the hallway walls and ceiling.
On 23 November 2021 an order was raised for damp treatment/redecoration to be carried out, the stage 2 response says that on 11/01/22 an “RHL” report was submitted. However, no record has been seen to confirm what an “RHL” report is, whether this was the date the works were completed or, if not, when it was.
Following an inspection of the property on 26 May 2022 it was recorded that the hallway needed to be replastered, the order was raised on 30 May 2022 for the renewal of defective plaster following the leak. This work was completed on 7 July 2022. That same day an order was raised for the decoration of the hallway following the plastering works. The landlord’s records show this was completed on 4 August 2022.
However, on 7 September 2022 the resident reported that damp and mould had come back through into the hallway. An appointment was scheduled for 19 September 2022, but the work was postponed due to the bank holiday. The rescheduled date was 5 October 2022 and a mould wash was carried out on that date.
Based on the records seen the mould washes carried out in the hallway were all completed within the repair policy timescale of 90 days. However, no evidence has been seen to show the redecoration works ordered on 23 November 2021 were completed prior to 4 August 2022, which is far more than the landlord’s repair policy timescales. Additionally, the damp and mould policy states that a wash will be applied within 7 days and an inspection to diagnose the issue carried out within 28 days, and the records show this was not always adhered to.
For instance, on 16 September 2021 the resident contacted the landlord to chase it about the mould wash in the hallway which had been recommended by an occupational therapist. While the landlord has not provided a record of when this recommendation was received, the work was not completed until around 8 days after this call and as such could not have been completed within the 7 day timeframe of the initial report given in its policy. Also of note is that the occupational therapist’s report contained work recommendations directly relevant to the complaint made, therefore the landlord’s failure to provide a copy of it shows a serious failure in its record keeping.
Similarly, return of the mould was reported by the resident on 7 September 2022 and the work was not scheduled until 19 September 2022, which was 12 days later. This is not taking into account the additional 16 days delay due to the bank holiday.
The Ombudsman has not seen any records to explain why these works were not completed within the landlord’s damp and mould policy timescale or why the bank holiday caused a further delay of 16 days. Additionally, no record has been seen of a damp and mould survey to diagnose the cause of the mould.
It is appreciated that based on the records seen the original cause was the leak in May 2021. However, given the mould returned around 7 September 2022, despite the previous works to rectify the issue, the landlord should have been proactive and arranged a survey to determine why the mould had returned. It could then have taken the relevant steps to fix this and prevent the mould from returning in future.

Damp and mould in the bedroom and bathroom

On 17 January 2022 the resident reported mould in the bedroom and that it had damaged personal property, it was spreading from the point in the wall where an internet company had “dug at” on 18 December 2021. A contractor attended the next day, the report states “inspected the bedroom wall area of property and I could find leaks, just a bit of mould on the wall and water weeping from the skirting board. I would advise that a surveyor to attended and see if any water pipe are running underneath the property or check the blueprint to this estate before we attended and do a mould wash”.
The resident then contacted the landlord on 25 January 2022 and explained that the mould in the bedroom had spread to the extent that the room was no longer usable. He was therefore sleeping on the sofa, which was painful due to his chronic pain condition, and he had had to move everything from the bedroom into the living room. This meant he was unable to use his wheelchair to move around the living room because there was not enough space.
On 10 February 2022 the resident called the landlord to chase it about arranging a surveyor to inspect the bedroom and bathroom to discover the source of the mould, as he had not been contacted about this since the visit on 18 January 2022.
The landlord’s records show that waterproofing and a mould wash were completed in the rooms on 5 October 2022, after having been delayed from 19 September 2022. Although the landlord has not provided any information to explain why it took 9 months for this work to be completed. This was an unreasonable amount of time for the works to be completed and far exceeds the timescales set out in the landlord’s repairs policy.
Not only did this exceed the landlord’s own timescales, as set out in the repairs policy, i.e. between 28-90 days to enact a repair, but it also far exceeded those in its damp and mould policy which states a wash treatment will be carried out within 7 days.
Additionally, the resident had informed it in January 2022 that the severity of the mould had made the bedroom unusable, so he was sleeping on the sofa which was exacerbating his chronic pain condition. Therefore, the landlord’s failure to carry out repairs within a reasonable time was made more severe because it was fully aware of the resident’s disabilities and he had reported the impact the situation was having on him as well.
The resident reported the return of the mould on 1 December 2022 and the landlord’s stage 1 response states that a surveyor inspection had been ordered on 8 December 2022. It also informed him that they would be in contact with the resident to arrange an appointment.
The surveyor’s inspection was ordered within 28 days of the resident reporting that the mould had returned, in line with the landlord’s damp and mould policy timescales for persistent mould. However no additional evidence has been seen to show when the surveyor inspected the property nor what they found. Detailed inspections are crucial for identifying the causes of damp and mould and for raising remedial works, therefore there has been a record keeping failure as reports should be on file as part of the audit trail of actions to resolve such cases.
The landlord’s mould repair history dated 14 December 2022 states that an order to “treat mould in bedroom and bathroom, hack off defective wall and re-plaster in hallway by FED, Seal crack on ext wall by FED, apply concrete plinth to base of ext wall from bathroom area to bedroom, overhaul ext fan” was raised. These works were started on 2 February 2023 and were completed on 20 June 2023.
Regarding the length of time it took to complete the works, the landlord’s system notes for 6 February and 1 March 2023 only say ‘more time required’. No records have been seen to explain why more time was needed or how much more, therefore the landlord’s record did not demonstrate that the added delay was reasonable. As already mentioned above detailed inspection and work reports are crucial for landlord’s to be able to monitor outstanding works, as such the lack of detailed reports in this instance shows poor record keeping practices by the landlord.
Similarly, a contractor attended the property on 18 April 2023 and found that follow on work was required, this was scheduled for 7 and 8 June 2023. The records seen show that further additional works were then required, these were booked in for 14 June 2023 and completed on 20 June 2023. Yet, as above, no records have been seen to explain what these follow on works were nor why they took a further 2 months to be booked in and completed.
Clear record keeping is an essential part of providing a repairs service and responding to complaints. It allows a landlord to monitor outstanding works and contractor performance, as well as provide accurate information and an effective service to its residents. A landlord should have systems in place to maintain accurate records including, but not limited to, resident repair reports, attendances by contractors, notes of inspections, actions taken because of the inspection, details of any complaints received, and its responses to complaints.
Overall, the landlord’s failures in its handling of reports of damp and mould at the property, as set out above, can be summarised as:
1. Unnecessary delays in carrying out work to resolve the damp and mould in the property.
2. Failure to adhere to its repair and damp and mould policies.
3. Inadequate record keeping.
Cumulatively these failings amount to maladministration as they caused unnecessary delays to the mould issues and subsequent redecoration works being resolved in a timely manner, which in turn impacted the resident’s use of the bedroom and overall enjoyment of the property. Additionally, these failings also caused the resident avoidable time, trouble, distress and inconvenience to the resident.

Requests to replace fencing panels

The landlord’s repairs policy confirms that it is responsible for repairs to fences and states “we will identify potential disrepair issues during our void maintenance process and deploy resources to remedy any defect before the property is re-let. We will also take proactive steps to prevent future disrepair claims by considering ventilation and thermal works during the void process. The property must be fit for habitation before new tenants move in”.
The resident states that in January 2021 it was agreed with the property manager that the back fence would be repaired and the garden secured before he moved into the flat. However, the landlord has not provided a record or log of any conversations between the resident and its agent before he moved in.
The stage 1 response states a work order was raised on 16 September 2021 for the replacement of the fence and its contractor attended the property on 15 October 2021. The work could not be carried out due to overgrown trees and shrubs, which the resident was due to contact the landlord to arrange for these to be cut back. The order was later closed as the contractor did not receive an update to say this had been completed.
The response also says the resident’s housing manager was coordinating the pruning and removal of any obstructive bushes and trees. They were trying to arrange for the bushes to be trimmed by a local group of volunteers, once the overgrown trees and shrubs were cut back an order to fix the fence would be raised.
The records seen show that on 21 June 2023 an order for the replacement of the fence was raised and the contractor asked to contact the resident to arrange an appointment. The contractor attended on 5 July 2023 and the order was then marked as complete, yet the records show that all they did was take photos and no works were carried out on the fence. A new order was raised on 4 August 2023 and the works were then completed on 23 August 2023.
While the landlord has not provided evidence of any conversations with the resident about the fence being fixed before he moved in, it is not disputed that the fence was in a state of disrepair at that time and therefore the landlord has failed to follow its repairs policy. The issues with the fence would have been identifiable and therefore should have been fixed during the void period.
Furthermore, the records seen do not provide an explanation as to why it took around 2 and a half years to fix the fence, which is in breach of the timescales set out in the landlord’s repairs policy.
While the resident says the issue was reported before he moved in as well as in May and July 2021, no records of these have been seen. The earliest repair record seen which relates to the fence repair is dated 15 October 2021, and simply states “resident is in contact with Lambeth to get the trees and shrubs cut back as in (sic) would be impossible to repair fence at the moment. resident to make contact when garden cleared”.
As mentioned earlier in this report the stage 1 response confirmed that the visit on 15 October 2021 was in response to a repair order raised on 16 September 2021. This order was later closed as the contractor had not heard back from the resident regarding the overgrown trees and shrubs being cut back. However, no information has been seen to show that the landlord or its contractor ever got back in contact with the resident to follow up on this and/or to help in having this arranged.
Landlords should be proactive in seeking to resolve issues that are brought to their attention. In this case the landlord was aware of what work was required before the fence could be replaced and the property made secure. Therefore, the landlord should have monitored the repair and followed up with the resident about the overgrown trees and shrubs, rather than simply asking him to arrange for them to be cut back and closing the order when it did not receive an update.
The stage 1 response says that around November 2022 the housing manager was trying to arrange for the pruning/removal of the trees and shrubs to be done by a local group of volunteers. It also says they had contacted someone to ask why there were delays in undertaking this work, but once an update was received they would raise the necessary work order and request an appointment date.
However, the records seen do not show that an answer to why there were delays was received nor that this was followed up by the landlord. There is also no record to confirm when the overgrown trees and shrubs were eventually cut back, only a record dated 21 June 2023 stating a new order to fix the fence had been raised.
Furthermore, no record has been seen to show why the contractor only took photos of the fence on 5 July 2023 or why the order was closed without the works being carried out. On top of which it then took a further 2 months for the landlord to realise the works had not been completed and to arrange for them to be carried out.
As has already been mentioned in this report, clear record keeping is an essential part of providing a repairs service and responding to complaints. Landlords should have systems in place to maintain accurate records, including resident repair reports, attendances by contractors, notes of inspections and actions taken as a result of the inspection.
Overall, the landlord’s failures, as set out above, can be summarised as:
1. Failing to adhere to its void policy in respect of identifiable disrepairs.
2. Failing to adhere to the timescales in its repairs policy.
3. Inadequate record keeping.
Cumulatively these amount to maladministration as these have caused an unnecessary delay in the fence being fixed and the property being secured, which in turn caused the resident avoidable time, trouble, distress and inconvenience. These delays also impacted the resident’s full enjoyment of the property as he has said that due to the broken fence there were security issues with people walking into the garden, as a result he did not feel safe and secure in his own home.

The landlord’s handling of the complaint

The landlord’s complaints policy states that it will respond to stage 1 complaints within 10 working days and stage 2 complaints within 20 working days.
In this instance the resident raised his stage 1 complaint on 3 March 2022 and the landlord did not issue its response until 13 December 2022, around 9 months after the complaint was first raised and therefore in breach of its own policy timescales.
The Ombudsman acknowledges that on occasions there will be circumstances that mean a complaint response cannot be provided by the designated timeframe. The Complaint Handling Code operated at the time states that when a complaint response cannot be provided within the designated timeframe, “landlords may provide an explanation to the resident containing a clear timeframe for when the response will be received. This should not exceed a further 10 days without good reason”. This is usually to be expected when complaints are complex and further investigation is required. Therefore, it would be reasonable to expect that a landlord would contact the resident, explain in detail the reasons for the delay, and provide a new timeframe whereby the resident would expect to receive a response.
However, no evidence has been provided to show that the landlord contacted the resident to explain the stage 1 response would not be issued within the timeframe set out in its complaints policy, nor that a new deadline was given. That said, even if the landlord had contacted the resident on one or more occasions to advise of a delay in the stage 1 response, it would still not be considered reasonable for it to have taken the landlord 9 months to issue its response.
Additionally, the resident’s stage 1 complaint states that 1 of the heads of complaint is that “the disability frame around the toilet is rusted through and the arms are broken off with rust and it’s unadjustable and dangerous. The NHS have provided me with an adjustable replacement, I have made countless phone calls and emails asking you to remove the dangerous equipment”. Yet neither the stage 1 nor stage 2 responses address this complaint point.
The Ombudsman’s Code, operated at the time, required that landlords must address all points raised in a complaint and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.
This is of particular importance in this case due to the resident requiring this adaptation because of his disability and the impact the delays had on him. Namely that he was left with an unsuitable and potentially dangerous disability frame for an unnecessarily extended period of time, i.e. from when the resident moved in until 29 March 2022, which is the date the resident has said it was removed.
As mentioned earlier in this report the landlord offered £250 compensation in its stage 1 response and a further £500 in the stage 2 response. Based on all the above, it was appropriate for the landlord to acknowledge the service failings and uphold the resident’s complaint and offer compensation.
However further compensation is warranted to adequately address the impact the landlord’s failings had on the resident, namely the impact of its failure to effectively deliver timely, enduring remedies to the required repairs. This is particularly the case regarding the works relating to the damp and mould in the bedroom and the broken fence, as well as the consequential time, trouble, distress and inconvenience caused by the delays, the poor level of communication and the resident having to repeatedly chase the landlord.
Overall, the landlord’s failures, as set out above, can be summarised as:
1. Failing to respond to the resident’s complaint within its complaints policy timescales.
2. Failing to address the resident’s complaint about the broken disability toilet frame.
3. Insufficient redress offered to adequately address the landlord’s failings.
Cumulatively these amount to maladministration as the unnecessary delay in the landlord responding to the resident’s stage 1 complaint and the failure to address the issues with the disability toilet frame caused the resident avoidable time, trouble, distress and inconvenience.

Determination (decision)

In accordance with paragraph 42(a) of the Scheme, the handling of the resident’s reports of personal belongings damaged by damp and mould are outside the Ombudsman’s jurisdiction.
In accordance with paragraph 52 of the Scheme, there was maladministration by the landlord in relation to its handling of reports of damp and mould in the hallway, bedroom and bathroom.
In accordance with paragraph 52 of the Scheme, there was maladministration by the landlord in relation to its handling of requests to replace fencing panels.
In accordance with paragraph 52 of the Scheme, there was maladministration by the landlord in relation to its handling of the resident’s complaint.
This investigation has also found maladministration in respect of the landlord’s record keeping standard that surfaced in this case.

Orders

Within 4 weeks of the date of this report the landlord must apologise to the resident for its failures. This written apology must be from a member of the landlord’s senior management team and should follow the Ombudsman’s apologies guidance on our website.
Within 4 weeks of the date of this report the landlord must provide the Ombudsman with evidence that it has directly paid the resident £1,600 compensation, which is in addition to the £750 it offered in its final responses, comprised of:
1. £800 for the time, trouble, distress and inconvenience caused by the landlord’s handling of reports of damp and mould.
2. £500 for the time, trouble, distress and inconvenience caused by the landlord’s handling of fence repairs.
3. £200 for the time, trouble, distress and inconvenience caused by the landlord’s handling of the complaint.
4. £100 for the time, trouble and inconvenience caused by the landlord’s poor record keeping practices.

Recommendation

The landlord should consider carrying out a review of its practices in relation to its system for managing and responding to repair issues, taking into consideration the recommendations and findings of the Spotlight Report on Knowledge and Information Management (May 2023). The review should include, but not be limited to, the landlord’s processes and procedures for oversight of work orders as well as its failure to keep detailed records of:
1. Conversations between residents and its agents before the tenancy starts.
2. Its complaint capture and response coverage.