Camden Council (202115731)

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REPORT

COMPLAINT 202115731

Camden Council

12 September 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 management and handling of:
1. outstanding repairs at the resident’s property.
2. reports of damp and mould in the property.
3. the resident’s complaints.
This report also looks at the landlord’s record keeping practises and handling of knowledge and information.

Background

The resident lives in the upper flat on the second floor of a converted mid-terrace Victorian period property under a secure tenancy agreement let by Camden Council.
The landlord housing records state the resident “described himself as disabled, as having suffered a break-down and having a mental health problem. He is known to Adult Social Care.”
The property underwent kitchen and bathroom refurbishment works prior to 2017 which was referred to by the landlord and residents as a Better Homes programme.
This Service asked the landlord to provide evidence related to this investigation to assist with the assessment and determination. However, the information it provided contained evidence of activity that goes beyond its final stage 2 complaint response, and therefore beyond the scope of this investigation. It is, however, prudent for some elements of the additional evidence to be considered and referenced in the report; where it provides clarity on activity that is within the scope of this report. Where this occurs it is noted.

Relevant policies and procedures

The landlord operates a 2-stage complaints policy which states it will:
1. acknowledge the complaint within 2 working days,
2. respond to the complaint within 10 working days at stage 1 and 25 working days at stage 2,
3. provide an outcome and reasons for the decision.
The landlord’s remedies policy states it offers remedies which are proportionate, appropriate, and reasonable and take into consideration the facts and issues raised in complaints about service failures. It uses a guideline compensation table for calculating awards.
The landlord’s tenancy conditions state:
1. the landlord will keep in repair and in good working order the structure and exterior of the premises,
2. the resident must tell [the landlord] at once about any damage to the home and any defects.
The landlord’s tenancy handbook states:
1. the landlord is responsible for repairs to window frames, internal walls, floorboards, plasterwork, roof repairs, brickworks, damp-proof work,
2. advice about condensation and mould in the home relating to lifestyle, heating the home, and ventilation,
3. mould can be cleaned with a fungicidal spray available from most DIY shops.
The landlord’s repairs policy is in the form of a service booklet which contains links to the landlord’s website, and references to other documents. It states:

a. decorations are the responsibility of the resident, for example where there is a leak from a property above.

b. responsive repairs timescales as:

1 hour or the same day for emergencies where there is immediate or ‘real’ danger to people or possessions,
3 working days for urgent repairs under the statutory “Right to Repair” scheme, otherwise as per that scheme,
5 working days for “urgent” issues, i.e. that would cause significant nuisance,
20 working days for “routine” repairs (not an emergency or urgent) or repairs,
The timescale for programmed or complex works would be by agreement. This includes renewals of items in the home, such as kitchen units.

Summary of events

The landlord raised a works order on 26 February 2020 related to “issues with very draughty sash windows, damp and mould underneath the windows including the walls. Also cracks in hallway walls. Please investigate and report back.”
The landlord raised a works orders on 10 March 2020 to “carry out repairs to window in bedroom, remove sealant on outside and redo to stop water ingress, overhaul window on stairs.”
The landlord raised a works order to repair the resident’s window on 30 July 2020 and conducted repairs to the sealant on resident’s bedroom window on 11 September 2020.
The landlord reassessed the resident’s bedroom window on 3 December 2020 and reported “there were no repairs required to the bedroom windowsill as it was due to condensation”.
The landlord raised a works order on 28 April 2021 to investigate “structural cracks to the ceiling, hallway, and kitchen ceiling and walls. The cracks continue in the living room, all along the walls.”
The landlord inspected cracks in the resident’s property on 10 May 2021 and recommended a structural engineer to “carry out a survey on the property for suspected subsidence.”
The landlord raised a “condensation case” under the resident’s address on 13 May 2021.
The landlord emailed the resident on 9 July 2021 following a conversation it held the same day. The landlord apologised for the frustration the repairs team caused and stated it would:
1. produce a list of outstanding repairs and email this to the resident for him to review and amend by 16 July 2021,
2. set about a plan of action to complete repairs it was able to,
3. provide an update on “movement monitoring at the property being conducted by our insurers by 16 July 2021”.
The resident emailed the landlord on 13 July 2021 listing his outstanding property repairs as:
1. cracks throughout the flat,
2. painting ceiling and wall water damage and painting repaired cracks,
3. repair and paint windows and window sealant,
4. repaint bathroom and kitchen with waterproof paint which was incorrectly done as part of your better homes scheme,
5. sealant around hot tap,
6. fix kitchen cooker wall switch,
7. repair window glass and system allowing the top window to be opened,
8. dipped ceiling in living room,
9. dipped floor in living room caused by subsidence,
10. bedroom window humidity,
11. bedroom window mould,
12. kitchen floor dip after floorboard was incorrectly cut and then covered with laminate to hide it (better homes scheme again),
13. living room ceiling mould.
The resident emailed the landlord on 21 July 2021 stating he had not heard back from the council about repairs and subsidence from the insurers as expected.
The resident emailed the landlord again on 30 July 2021 stating it “has been 9 days since my last message and I am still yet to hear back regarding works”. The resident further stated the landlord did not confirm it would attend the property related to an appointment it had asked the resident to set up.
The resident emailed the landlord again on 12 August 2021 stating he had not received contact from the landlord about his repairs and subsidence and had raised the matter with his councillor.
The landlord raised works orders on 12 August 2021 to:
1. “renew basin taps preferably with longer spout,”
2. “ease / adjust / repair top sash in living room and repair sash in bedroom also letting in rainwater,”
3. “repair sealant around the hot tap.” The notes subsequently made on this works order stated, “it has been closed off until the flooring is repaired.”
The resident emailed the landlord on 13 August 2021 stating he were contacted to set up three future appointments to “observe and triage what needs to be done.” The resident stated, “the best you can do is book only 3 of the many repairs that need to be done and expect me to wait an additional 2 months just for someone else to see what needs to be done.”
On 1 September 2021, the landlord raised works orders to repair a roof leak “as damp around the area above the living room” and repair the kitchen flooring. The landlord repaired the roof flashing at the resident’s property on 13 September 2021.
The landlord attended the resident’s property on 14 September 2021 but failed to remedy the uneven kitchen flooring during the appointment. The resident emailed the landlord the same day stating:
1. repair staff attending the property uncovered a list of issues related to poor work that was previously “signed off,”
2. the supervisor told the operative “not to do the job properly but to quickly patch it up because it’s quicker.”
3. The repairs were listed as:
  1. floorboards are wrongly cut,
  2. 3 different layers of vinyl flooring were found,
  3. wood from the kitchen units were used to hide the incorrectly cut flooring,
  4. kitchen units incorrectly installed.
On 22 September 2021, the landlord arranged a works order to complete further works to the kitchen floor on 23 September 2021. The landlord texted the resident to confirm the appointment for the next day.
The landlord contacted the resident on 23 September 2021 to arrange a follow-on appointment to repair the kitchen floor, but the resident refused stating he were going to be unavailable on 24 September 2021 and wanted to speak to a supervisor.
The resident emailed the landlord on 23 September 2021 stating:
1. an unsuitable appointment was made without his permission,
2. “the kitchen flooring has taken 8 days and is still ongoing,”
3. “it hugely concerns me that after the job was half done last week, I heard nothing from your team,”
4. “your tradesmen did not cover the kitchen with dust sheets, I was left to clean the house after they had left,”
5. “I’m incredibly concerned about what will happen when you have to redo the living room ceiling, among all the other pending repairs,”
6. “your team continue to push and push me. Not only do I not receive any replies, apologies, or explanations to my emails, but I’m always left chasing your team to complete your legal obligations as my landlord.”
The resident emailed a stage one complaint to the landlord on 26 September 2021 to complain about:
1. “a long list of outstanding repairs,”
2. “senior repair team ignoring my emails requesting help,”
3. “my request to be relocated due to the severity of repairs,”
4. “a list of emails that have gone unnoticed which will go to the ombudsman once this stage of the complaint is done.”
The landlord forwarded the resident’s email on 28 September 2021 to identify the list of repairs the resident’s email referred to. The repairs team replied on 30 September 2021 stating they “do not have such records”. The landlord therefore replied asking its repairs team to “progress the resident’s concerns by contacting them”.
The resident contacted this Service on 11 October 2021 stating he made various formal complaints about repairs issues to the landlord but did not receive any written responses. This Service sent a first request for action letter to the landlord the same day asking the landlord to respond to the resident’s complaint by 25 October 2021.
The landlord emailed this Service on 25 October 2021 advising that it has not received a complaint from the resident and requested that we provide it with contact details to log a formal complaint. The landlord subsequently registered the resident’s stage one complaint on the same day.
The landlord emailed this Service on 18 November 2021 stating:
1. it was responding to the matter of the resident’s complaint on behalf of an absent colleague,
2. there was no record of the resident making any formal complaints since 2019,
3. enquiries about the repair complaint were sent to the resident using an existing email address,
4. a response date of 2 December 2021 was provided to the resident after which the complaint will be considered withdrawn.
The landlord emailed the resident on 18 November 2021 stating it could not find the resident’s complaint about repair issues. The landlord requested a copy of the resident’s complaint for it to outline the repairs it wanted to discuss.
The resident emailed a further copy of his stage one complaint to the landlord on 18 November 2021.
The landlord emailed the resident on 19 November 2021 stating:
1. the resident’s complaint arrived on 26 September 2021 and was forwarded to the repairs team two days later because the list of repairs it referred to was not attached, as indicated,
2. the repairs team replied on 30 September 2021 and confirmed it was not aware of the resident’s repair reports,
3. the resident’s email “was not registered as a complaint” and was “pending clarification from the repairs service that they knew of the repair reports.”
4. it had asked the repairs team to contact the resident to progress the repairs and apologised that this was not progressed,
5. a further request for the resident to provide the list of the outstanding repairs for his complaint to progress.
The resident replied to the landlord on 20 November 2021 stating:
1. “it has been 36 days since I made my complaint, and no one has been in contact,”
2. “you’ve said the case was not considered a complaint which is strange as I used your complaints portal and have a reference number,”
3. “if you researched the repair issues with the repairs team or contacted me like your complaints processes dictates, you would have the list of repairs that need to be done.”
The landlord sent an internal email to its repairs service on 22 November 2021 in relation to the resident’s complaint. The landlord requested an appointment for inspection of the resident’s home and repairs booked and stated:
1. the resident approached this Service about his complaint,
2. “there is a long list of repair needs at his property, which we are refusing to deal with,”
3. “he is proving uncooperative in providing details of what those repairs needs are,” but we have “two photos sent in September which showed a radiator and a hole in the floor,”
4. “it wouldn’t surprise me if he refuses access, but we need to make the attempt,”
5. the ‘complaint’ made using the on-line reporting process was sent to [the repairs email address] on 28th September for consideration as ‘business as usual.’
The landlord emailed this Service on 22 November 2021 stating it arranged a “property inspection to see what needs attention” and that the resident “is still not telling us what his long list of repairs is”.
The resident emailed a list of outstanding repairs to the landlord on 16 December 2021. The list was identical to the list provided in his email of 13 July 2021 except ‘fix kitchen cooker wall switch’ was removed. The resident requested compensation for missed work due to repair appointments and stated the kitchen has no flooring at all and the matter was causing an impact on his mental health.
The landlord sent an internal email to the repairs service on 17 January 2022 requesting information about outstanding repairs at the resident’s address. The landlord explained that it logged the repairs matter as a complaint in November 2021 and requested specific information from the resident by 2 December 2021. The email confirmed the resident replied to the landlord on 16 December with a list of outstanding repairs, by which time the complaint was withdrawn.
The repairs service replied to the landlord on 17 January 2022 stating repairs to the flooring would be completed on 18 February 2022 and that a longer basin tap was ordered, and the resident was already advised of the progress of the tap repair.
The landlord sent an email to its repairs service on 18 January 2022 to enquire about the progress of two particular works orders and for comments about the progress of works orders.
The repairs service replied on 19 January 2022 stating arrangements for all works were handled by a supervisor because the resident “was not happy with the service” and “there were things we were attending to which he didn’t regard a priority”. The repairs service stated the resident became rude and confirmed it raised works orders to respond to the resident’s requests and for any further contact to be put through two named staff members.
On 10 February 2022, the landlord scheduled a repairs appointment to repair the kitchen floor on 23 February 2022. The landlord confirmed plumbing works to repair the tap would be completed afterwards in response to the resident’s request. The landlord notified the resident of the appointment by text 9 times between 10 and 23 February 2022.
This Service issued a complaint handling failure to the landlord on 11 February 2022. The order stated the landlord failed to provide a stage one complaint response within the housing ombudsman complaint handling code timescales, despite advice and information being provided. Further that the stage one complaint response was unreasonably delayed and caused avoidable distress and inconvenience.
The landlord emailed his stage one response to the resident on 18 February 2022, five months after it was issued. The landlord’s response stated:
1. it had investigated cracks throughout the flat which resulted in the council insurance section investigating subsidence via trial pits and monitoring,
2. an email address could be used for the resident to request an update if required,
3. a roof leak was resolved on 13 September 2021 when the roof flashing was repaired,
4. an inspection related to subsidence was completed by the insurance team, but all other decorative repairs were the resident’s responsibility,
5. a carpenter repaired the bedroom window sealant on 11 September 2020, and second operative attended three months later on 3 December 2020 and reported no repairs were required due to condensation,
6. a “condensation case” was raised on 13 May 2021 and the “condensation was related to subsidence,”
7. it would refer the matter to the mould and damp team because “the council takes damp cases very seriously”.
8. the dipped living room floor would be included as part of the subsidence investigations,
9. works to repaint the bathroom and kitchen with waterproof paint took place in 2017 and due to the length of time [the landlord] was unable to comment on this any further,
10. arrangements would be made for a qualified damp surveyor to attend and provide a full damp survey,
11. a kitchen flooring repair was completed on 14 September 2021 but was deemed unsatisfactory so an appointment for 23 February 2022 was raised,
12. works to repair the hot tap sealant “were closed off until the flooring is repaired,”
13. the complaint was upheld due to a service failure on handling and logging the original complaint,
14. many repairs were managed by the insurance section but there were delays, poor communications, and poor workmanship,
15. £450 compensation was offered comprising £300 for distress and inconvenience related to complaint handling and £150 for time and trouble related to the repairs.
The resident responded to the landlord’s stage one response email the same day stating:
1. the landlord’s response was “inaccurate, lie after lie,”
2. he should be relocated due to outstanding repairs and missed and cancelled appointments.
The landlord replied to the resident’s email on 18 February 2022 stating:
1. there was no evidence that jobs have been cancelled apart from a works order on 29th September 2021 that stated “tenant was unable to keep the appointment as he has a new job and will have to arrange time off. Will call back to organise at a later date,”
2. if the resident remained unhappy with the landlord’s decision he could escalate the complaint to a review stage.
The resident escalated his complaint to the next stage of the complaint procedure on 25 February 2022. The resident’s stage two complaint stated:
1. he was concerned the complaints team did not log the complaint he made using the complaint page on the landlord’s website,
2. the repairs team had already been provided with a list of the outstanding repairs,
3. multiple surveyors visits had taken place during which photos were taken,
4. an update about cracks throughout the flat remained outstanding following a plasterer’s visit 9 months previously,
5. the landlord should obtain and share from the insurers about the matters rather than expect the resident to,
6. paintwork and water damage to the walls is in the bedroom not in the living room as indicated in the landlord’s complaint response,
7. the living room ceiling repairs referred to were never repaired, decoration vouchers were not issued as agreed, “and now you have forgotten it ever existed,”
8. damage in the property related to water ingress from the roof,
9. new inspections take place by new staff members and the repairs process restarts repeatedly,
10. mould in living room and kitchen was first raised in 2008 and multiple contractors tried to resolve the matter but failed,
11. he was advised to buy a dehumidifier, open windows, and wipe the mould as it was his responsibility,
12. he was told that a fan would be installed which was not completed,
13. updates about the dipped living room floor due to subsidence were outstanding,
14. the landlord’s statement that said, ‘I am unable to comment’ when referring to repairs completed in 2017 “is not good enough,”
15. he had previously used humidity paint prior to a new bathroom and kitchen installation being ‘forced upon them” and no decorating vouchers were issued as advised,
16. repairs to replace the kitchen taps that were “too short” remained outstanding 5 months after a contractor advised new taps would be ordered,
This Service sent an email to the landlord on 2 March 2022 with reference to a stage 2 escalation the resident issued to it on 25 February 2022. This Service asked the landlord to issue its stage two response to the resident by 25 March 2022.
The landlord emailed the resident on 3 March 2022 stating it had not received his stage 2 escalation request. The landlord stated it would respond to the resident’s stage 2 complaint when the resident provided a replacement copy of it.
The resident embedded his reply to the landlord’s previous stage one complaint response in an email he sent to the landlord on 3 March 2022 stating:
1. it was the second time the landlord required his assistance in “locating a complaint which was created on your complaint system”,
2. he wished to move to the final stage of the complaint process,
3. there were “a number of outstanding major repairs that need to be done”,
4. he created a housing application because he would like to be moved from his home,
5. the amount of compensation offered did not cover the time of work taken for repairs and missed appointments,
6. he should receive compensation for higher bills due to window insulation issues.
The landlord sent a stage two complaint response to the resident on 15 March 2022. The landlord stated:
1. it had reviewed the resident comments obtained from three emails he sent in response to the landlord’s stage one complaint,
2. it summarised its understanding of the resident reasons for escalating the complaint as:
  1. “you are concerned that your complaint was not registered at the time it was originally made,
  2. there has been a 9-month delay in progressing plastering work at your home and you have not been provided with updates,
  3. The water damage to the ceiling and wall you are referring to is in the bedroom not the living-room,
  4. the damage is due to a fault with the roof and is thus the landlord’s responsibility.
  5. you have been reporting mould issues since 2008 and have had conflicting and contradictory advice on the need for mechanical ventilation,
  6. it unacceptable to refuse to provide advice on the ‘Better Homes’ work programme,
  7. you have not been updated on progress with works to your taps.
  8. the delay, and issues at your home, have affected your mental health,
  9. you want to be relocated to a different property.
  10. the reason this has not been agreed is racially motivated.”
3. The landlord responded by stating:
  1. it recognised the resident’s opinions on the matter but there was no evidence to suggest the stage one response was not dealt with properly, contained lies and that the resident was treated inappropriately,
  2. an apology for the resident’s complaint not being identified and registered,
  3. a new complaint monitoring, and registry system was being implemented,
  4. £300 compensation provided previously was appropriate,
  5. the snagging period related to his 2017 complaint about better homes works had ended and could not be reopened, but any faults still remaining can be considered under the day-to-day reactive program,
  6. a discussion about “mechanical ventilation” related to mould investigation indicated “condensation and not a penetrative damp issue.”
  7. advice about how to deal with condensation in the home was already provided,
  8. an apology for any conflicting advice about the need for mechanical ventilation in the home,
  9. no works order are currently outstanding at the property, but a survey was completed on 7 March 2022 which stated:
  10. the bathroom extractor required a repair or replacement with a light operated fan,
  11. plastering and repainting the bedroom and bedroom window were also considered, but there was no advice about tap repairs.
4. A further update would be provided to the resident within 10 days about the completion of the repairs referred to in the survey,
5. the condition of the home and does not warrant a decant or managed transfer.
6. the complaint was not upheld.
The resident provided a copy of the landlord’s stage two complaint response to this service on 15 March 2022 and subsequently contacted this Service to express dissatisfaction with the landlord’s stage two complaint response. The resident’s complaint was accepted as duly made on 17 March 2022.
The landlord sent an email to the resident on 15 August 2022 that confirmed no repairs were outstanding at the resident’s property. It stated, “The last jobs that were completed were related to replacing the flooring in your kitchen under the cooker and washing machine (March 2022); fixing the sealant on a window (Nov 2021) and fixing an external roof leak (Sept 2021).”

Assessment and findings

In reaching a decision we consider whether the landlord has kept to the law, followed proper procedure and good practice, and acted in a reasonable way. Our duty is to determine complaints by reference to what is, in the Service’s opinion, fair in all the circumstances of the case. The Service has a very specific role in considering whether the landlord has met its obligations to a resident and taken reasonable steps to resolve the complaint.

The landlord’s management and handling of outstanding repairs in the resident’s property

The Ombudsman notes that there have been delays and gaps in the provision of records by the landlord. The Ombudsman can only base its decisions on the documentary evidence provided to it by the parties and there is an expectation that the landlord, as the professional organisation with resources available to it, should be in a position to provide adequate evidence of its actions. This is addressed in more detail later in the report but has a bearing on the following findings related to its handling of repairs.
The landlord raised works orders to address bedroom and stairway window repairs in the resident’s property in February and March 2020. The landlord confirmed it repaired the sealant due to water ingress in September 2020, 7 months after the resident’s report was made. This was outside of the landlord’s repairs policy and was an unreasonable time to affect a sealant repair. This Service had not seen any record to clarify why there was a delay which would have caused an extended period of detriment to the resident related to water ingress and draughts.
The landlord raised a works order to investigate structural cracks throughout the resident’s property on 28 April 2021 and recommended a structural engineer’s assessment when its contractor attended on 10 May 2021. This repair appointment was completed within the landlord policy timescales for routine repairs and the suggestion to arrange a specialist was a reasonable recommendation for the landlord to make to address its escalated concerns about structural defects.
The landlord referred the resident’s property to a separate team with reference to concerns about subsidence which it was entitled to do. It is this Service’s view that ensuring the most qualified staff complete assessments and coordinate repairs of this nature was appropriate and good practice. By ensuring the structural condition of the property was monitored by specialist staff the landlord took a reasonable approach to protect the health and safety of its residents and the condition of its housing stock and this was an effective use of its qualified staff resources.
The landlord confirmed it would provide an update to the resident about the structural condition and ‘movement monitoring of the property’ by 16 July 2021. The resident chased the landlord for this information 3 times in the following months and in his stage 2 complaint confirmed he had not received any advice 9 months later. The landlord failed to uphold the commitments it provided to the resident, and this was unreasonable and would have caused inconvenience to the resident. Furthermore, given that the matter related to subsidence in the home this Service would have expected the landlord to recognise the distress the matter would have caused the resident. This Service has not seen any evidence to confirm the completion of, or outcomes of any structural assessments.
The resident provided a list of 13 outstanding repairs to the landlord on 13 July 2021, elements of which included reference to window repairs and cracks throughout the flat. The inclusion of these items suggest that the repairs completed previously were not lasting, or not completed in full. It is not clear to this Service whether the landlord had made arrangements to address the outstanding repairs prior to the resident providing the repair list. The resident re-sent the same list of repairs with the exception of one item again in his stage one complaint in September 2021 and further in December 2021. This thereby indicates the landlord did not arrange, nor complete repairs it was notified of, and this was unreasonable. This Service can see no good reason for the landlord’s failure to arrange and complete repairs or provide related information to the resident to manage his expectations. This caused time and trouble and inconvenience to the resident who resided in a property that did not meet acceptable standards of repair.
The resident made reference to his understanding that internal decorating was his responsibility. Further he make reference to the landlord’s offer to provide decorating vouchers to assist with decorations that were required as a result of repairs the landlord was responsible for. This Service would have expected to the landlord to uphold its agreement by issuing the vouchers or to have provided information to confirm why its offer was withdrawn. This agreement raised the expectations of the resident but the landlord’s subsequent failure to honour the commitment resulted in frustration and a loss of trust and confidence in the landlord’s repair services.
The quality of repairs conducted by the landlord was questioned by the landlord’s own contractor on 14 September 2021 when it identified four poor workmanship issues in the resident’s kitchen. The contractor contacted the landlord to seek approval to put right the repairs and this was a good practice approach to take that represents a proactive repairs service. However it was reported that the repairs supervisor advised “not to do the job properly but to quickly patch it up because it’s quicker.” This advice was wholly unacceptable and caused avoidable frustration and inconvenience to the resident.
It is not the intention of this report to address each of the outstanding repairs listed given that a significant delay of 5 months has already been established. This in itself is outside of the landlord’s repair policy timescales and is considered by this Service to be unreasonable. Furthermore, sufficient evidence of repairs and repair appointments is unavailable or inconclusive. However, it is of note that the landlord recognised a poor standard of workmanship itself in its complaint response. Furthermore, that subsequent repairs to remedy the landlord’s kitchen repair failings led to further appointment conflicts, delays, and continued detriment to the resident leading him to express understandable concerns about the impact and quality of future works required to the living room ceiling.
The resident makes reference to various surveyor’s visits and missed appointments, but this Service has not seen evidence to confirm the dates, or outcomes of these assessments, and this would be expected. Furthermore, the resident reports experiencing a ‘fresh start’ to repairs whenever new contractors attend thereby suggesting detailed notes and follow on works are not raised or retained. This is addressed later in this report. Notwithstanding this was unacceptable and caused significant time and trouble to the resident in pursuing repairs the landlord was responsible for over an unacceptable extended period of time.
The resident took reasonable steps to report the repairs, raise enquires about their progress and raise complaints when he considered a service failure had occurred. The resident stated “your team continue to push and push me. Not only do I not receive any replies, apologies, or explanations to my emails, but I’m always left chasing your team to complete your legal obligations as my landlord.” The landlord’s failure to respond to the resident so as to result in frustration being expressed in this way was wholly unreasonable. This Service expects landlord’s to take a proactive approach to repairs handling so as to limit the negative impact repairs have on its residents. In this case the landlord not only failed to respond to the resident’s reasonable repair requests it exacerbated the matters by not coordinating an effective approach and this was avoidable. Taking all matters into account this Service finds maladministration in the landlord’s management and handling outstanding repairs in the resident’s property.
This Service is aware than some aspects of the resident’s list of repairs remain outstanding. Whilst this is outside of the jurisdiction of this report, this Service would have expected the landlord to have addressed the matters it was responsible for, such as by coordinating an action plan and/or clearly explaining to the resident what it would or would not repair. The landlord’s own statement in its stage 2 complaint response suggested it can complete outstanding repairs under its day-to-day reactive program, further that it had completed an assessment of the property. Therefore it is unclear why some repairs remain outstanding, and/or the resident is unclear about what repairs he can expect the landlord to complete.

The landlord’s management and handling of reports of damp and mould in the resident’s property

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.
It is evident from the resident’s stage 2 complaint that the resident first raised the concerns about damp and mould with the landlord in 2008. However, evidence related to this complaint confirms the landlord only raised a works order to investigate damp and mould in the resident’s property in February 2020. It is not clear if an appointment to progress this was completed or what the findings were as no evidence was provided to this service to confirm the outcome. This Service would expect the landlord to have produced, shared, and retained a detailed record of its assessment of the condition of the property related to the reports it had received, where these align with document retention guidelines. Providing this would have been an effective early method of managing the resident’s expectations in relation to the landlord’s repairing obligations and ensured adequate oversight of any required repairs through to satisfactory completion.
The landlord stated that it opened a ‘condensation case’ for the resident’s address in May 2020 but no further advice was provided to this Service, or the resident about what this entailed or any outcomes. This appears to suggest a targeted and proactive approach to the presence of moisture in the home was being taken and this was a sign of good practice. This Service would however expect the landlord to have provided further information about this. Failing to do so was a further missed opportunity to evidence the matter was being addressed and thereby promote confidence in the landlord’s repairs service.
The landlord attended the resident’s property in December 2020 to reassess a window repair and at that time categorised the presence of moisture as condensation in the property. This was an assessment the landlord was entitled to make, but it is unclear to this Service if or how the advice was communicated to the resident, or if any further action took place. This was a missed opportunity to provide advice and information to the resident to help with the management of condensation in the home in line with good practice guidance.
This Service has seen no other reference of damp and mould in the property until 6 months later when the resident provided a list of outstanding repairs to the landlord in July 2021. The list of repairs included “bedroom and ceiling mould” and “bedroom humidity.” The requirement for the resident to report the repairs again was inconvenient given the landlord was expected to either complete repairs, arrange an action plan or explain why repairs were not required. This caused time and trouble to the resident in pursuing a remedy. Furthermore, given that the landlord had already been made aware of the presence of mould in the property this Service can see no good reason why it was not addressed. This was unreasonable.
The landlord raised a works order to repair a roof leak which had caused damp in the resident’s living room in September 2021. Whilst it is evident that the roof was repaired, this Service has not seen any evidence that the landlord took any internal follow up actions. Furthermore, no evidence was provided to confirm the landlord revisited the property when the water ingress had dried to determine if actions it had taken had indeed remedied the reported problems. Not taking measures to reassess the efficacy of its works was unreasonable and cannot but have further aggravated the matter and caused increased detriment to the resident.
It is evident from statements made by the resident that he took advice from the landlord by using a dehumidifier, ventilating the property by opening windows and cleaning mould because “it was their responsibility.” Whilst the advice provided to the resident and the subsequent action he took was appropriate it is this Services view that it should not absolve the landlord from maintaining a focus on the matter and seeking alternative remedies.
The Housing Ombudsman spotlight report on damp and mould explains “Landlords should avoid taking actions that solely place the onus on the resident. They should evaluate what mitigations they can put in place to support residents.” Further it states, “Landlords should make the most of every opportunity to identify and address damp and mould.” This Service has seen evidence that the landlord was made aware of damp and mould in the property, further that it had accessed the home and categorised moisture in the home as condensation. However there is no evidence to confirm if risk assessments, moisture readings and/or property condition surveys were completed and this is expected as a standard, minimal approach to ensuring the safety of resident’s and the habitable condition of the property. Notwithstanding the landlord’s assessment was its own to make and it is not the role of this Service is not to reinterpret the conclusions it was qualified to make in the best interests of the resident and the property.
The resident refers to an agreement by the landlord to install a fan in the property to further ventilate the property but that this did not progress due to conflicting advice from the landlord’s contractors about whether it was required. The use and installation of fans where damp, mould, and condensation is present is considered an effective means for addressing moisture in the home and the landlord was expected to be able to effectively decide if it was required. It is evident that conversations were held with the resident about “mechanical ventilation” and these were referenced by the landlord in its complaint response with an apology for providing conflicting information. This Service has not seen records from the landlord that relate to the installation of a fan, or mechanical ventilation in the resident’s home therefore is unable to comment on the effectiveness or potential resolution these remedies would have provided. However, the absence of appropriate and functional mechanical ventilation cannot but have had a negative material impact on the management of humidity levels at the property. Notwithstanding this conflicting advice is likely to have caused frustration and inconvenience to the resident and created an uncertainty about which of the landlord’s assessment to believe.
In the landlord’s stage 1 complaint response it confirms it would refer the resident’s case to a damp and mould team because it “takes damp and mould seriously”. This is an appropriate and expected response for the landlord to take, where concerns are identified. However, this was raised much later than this Service would expect and is likely to have exacerbated an existing problem thereby resulting in an increase of detriment to the resident. This Service would expect the landlord to have taken damp readings or wet wall tests in the property prior to the stage 2 complaint but has not seen any evidence that this type of measure was completed. The reality of the resident experience was significantly at odds with the values expressed by the landlord when it said that it takes damp and mould seriously.
The landlord confirmed that it would arrange for a damp survey to be conducted at the property, the outcome of which would have been reached outside of the jurisdiction of this case. This Service would therefore expect the landlord to have put in place actions to address the presence of damp and mould in the property and communicated clearly to the resident what could be achieved and within reasonable timescales. However, evidence provided to this Service indicates this was not achieved. Where habitable conditions fall below reasonable standards it would expected for the landlord to consider suitable decant arrangements.
The presence or potential presence of damp and mould in a property is a significant matter that presents a risk to health and safety of its occupants. In this case this Service would expect the landlord to have completed detailed assessments and/or retained accurate contemporaneous records of any assessments it undertook, whether visual or technical to verify with certainty what action, if any it could undertake. The landlord record keeping in this case was exceptionally poor and cannot but have hindered cohesive and effective management of repair needs at the property. Further it is clear that the landlord recognised a requirement to investigate further in its stage 2 complaint response. It is not clear to this Service why further steps have not been taken to address damp and mould thereby alleviating the resident’s concerns about the landlord’s ability to repair the property to an acceptable standard. Taking all factors into account this Service finds maladministration in the landlord’s management and handling of reports of damp and mould in the property.

The landlord’s management and handling of the resident’s complaints

In identifying whether there has been failure in service the Ombudsman considers both the events that initially prompted a complaint and the landlord’s response to those events through the operation of its complaint and compensation policy and procedures. The extent to which a landlord has recognised and addressed any shortcomings and the appropriateness of any steps taken to offer redress are therefore as relevant as the original mistake or service failure.
The landlord publishes a complaints procedure which sets out the expectations for handling complaints at stage one and stage two. The policy states complaints should be acknowledged within 2 working days and responded within 10 working days at stage one and 25 working days at stage two. The response timescale for stage 2 complaint is outside of the principles of the Housing Ombudsman complaint handling code (the ‘code’).
This Service has not seen any evidence that the landlord issued acknowledgment emails to the resident within 2 days of receipt of his stage 1 and stage 2 complaints and this was expected in order comply with its own policy and the code. This resulted in inconvenience to the resident who was uncertain when he could expect the landlord’s response to the matters raised.
This Service contacted the landlord about the resident’s stage 1 complaint in a ‘first request for action’ letter issued in October 2021. The landlord had failed to identify or respond to the resident’s complaint within the recommended timescales. This caused further detriment to the resident who did not receive information about the complaint he raised with expectations that his complaint would result in information or action being provided to address his concerns.
The landlord later stated to this Service that it did not receive the resident’s stage 1 complaint when he submitted it via an online complaint process in September 2021. However, it later confirmed the email was received but not identified as a complaint nor registered as such. This Service expects the landlord to be able to identify what is and is not a complaint and provide accurate advice about its handling of complaints. Such practice is a basic minimum standard and it is of significant concern that landlord has failed to even capture the resident’s complaint successfully.
The rationale behind landlord’s decision to forward the resident’s complaint to the repairs team rather than identify it as a stage one complaint is unclear. While it is common practice to seek comment from relevant services, referral of a complaint to the service complained about is a questionable practice given the potential for conflict of interest. In this case the practice caused inconvenience to the resident and resulted in a five month delay extensive delay in responding to the initial stage one complaint he made in September 2021.
The landlord wrote to the resident in November 2021, 5 weeks after it received contact from this Service, to request he provide a copy of his complaint within 2 weeks, or the complaint would be closed. This was outside the principles of the complaint handling code which states under section 1.7 “the landlord must accept the complaint unless there is a valid reason not to do so.” Further it was outside the suggested timescales this Service referred to in our correspondence. This Service would expect the landlord to have contacted the resident using an alternative communication channel to accept the complaint it was aware had been made. Relying on the resident to resend a complaint it later confirmed was received but not registered was wholly inappropriate. Suggesting it would not be progressed if a response were not received by December 2021 was also a totally unreasonable approach for the landlord to take when it could have contacted the resident itself to record the complaint details.
The communications between this Service, the resident, and the landlord in relation to the handling of the resident’s stage one complaint resulted in a complaint handling failure being issued to the landlord in February 2022. It is therefore not necessary for this report to re-present in detail the circumstances that led to the order beyond referencing the failure itself. The landlord issued its stage one complaint response on 18 February 2022, 5 months after the initial complaint was submitted and this caused extended distress, inconvenience, time, and trouble to the resident in pursuing a remedy to the matters he raised. This was unreasonable and far from the complaint standards this Service expects of member landlords.
The landlord’s stage one response addressed the matters the resident raised in his complaint by grouping some aspects of repairs together. Whilst this Service accepts the complaint response itself simplified the complaint, it failed to reassure the resident that matters were in hand and this was unacceptable, especially given the time taken for the response to be issued and the ongoing nature of outstanding repairs which the resident reported went back 12 years. Further this simplified approach resulted in a lack of detail being provided about the individual repairs the resident had raised. This Service would have expected the landlord to have recognised it had not provided a resolution to the repairs raised and to state if would assign a single point of contact to coordinate and resolve the matters raised, or to explain clearly why this was not possible.
The resident made reference to the cumulative impact the matters had on his mental health in emails dated 20 November 2021, 16 December 2021, 3 March 2022, and 30 May 2022. This Service has seen limited evidence that the landlord took reasonable steps to respond to these statements and could have made further enquiries to understand if any reasonable adjustments, in addition to the completion of repairs, were required. The landlord’s stage two complaint response stated “I am sorry to hear that your experiences, in trying to progress your complaint, have affected your mental health” but did not go any further in considering how the landlord’s actions had exacerbated his mental health and the extent of the detriment caused.
The landlord provided a statement to this Service which stated “the resident described himself as disabled, as having suffered a break-down and having a mental health problem. He is known to Adult Social Care.” Further the landlord sent an email dated 22 November 2021 that referenced the resident’s breakdown and disability. Therefore the landlord was reasonably expected to have exercised an increased level of empathy, and/or considered a referral for support, given its awareness of the resident’s vulnerabilities.
The landlord’s complaint response made reference to a ‘condensation case’ and stated its insurance team was overseeing investigations into subsidence. However it did not provide any further information to the resident about its findings or expected timescales and this was unreasonable. This Service would have expected the landlord to have investigated and provided an update about these matters by contacting its insurance team for updates related to the complaint. This exemplifies the landlord passing responsibilities to others that it could have addressed itself. Simply providing an email address for the resident to follow up on himself was inappropriate and cannot be viewed as an effective complaint management strategy. It was also likely to have caused additional frustration and further time and trouble to the resident in requiring him to personally pursue a remedy to landlord failings.
The resident escalated his complaint to stage 2 of the complaint procedure and once again the landlord failed to register the complaint and stated it was not received. The resident resent the complaint to the landlord which it subsequently registered and responded to in line with its policy timescales. However, it is not clear to this Service why the landlord failed once again to receive, recognise, or register the resident’s complaint escalation request. Given the failure to capture the residents stage 1 complaint it would reasonably expected that the landlord had identified and resolved any system or other failings in its online complaint capture processes, yet it did not do so. Asking the resident to provide a copy of his complaint again indicated no lessons were learnt or service improvements made which cannot but have further reduced the resident’s confidence in the landlord’s housing services and its capacity to resolve the issues of complaint.
The landlord’s stage two complaint response failed to offer a commitment to adequately address or provide confidence that the outstanding repairs it stated could be “considered under its day-to-day reactive program” would indeed be carried out and when. This lacked empathy or acknowledgement of the resident extended poor experience of the landlord service. Further, the landlord also failed to respond to the frustration the resident raised when indicating he had reported matters to the landlord many times which according to the resident were “either forgotten or restarted.”
The landlord apologised for providing conflicting advice related to condensation, damp and mould but did not indicate why or how this occurred. The landlord’s failure to provide a detailed explanation and/or establish a clear direction of travel for the completion of the outstanding repairs was a further missed opportunity to restore confidence in the landlord’s provision of responsive housing services. Furthermore the landlord’s assertion that there were no outstanding repairs registered at the resident’s address reinforced the resident’s view that the landlord was not responsive to him or his reports of outstanding repairs and this was poor. The landlord did not uphold the complaint, and this was unreasonable given it was aware it had not fully completed repairs in the resident’s property and had completed a survey in the property the previous week to review the condition of the property and outstanding repairs.
The landlord considered an offer of compensation for the distress and inconvenience its failings caused to the resident in its stage one complaint response. Under the terms of its remedies policy it was entitled to do so to resolve complaints where there have been service failures. The landlord recognised distress and inconvenience related to delays and poor workmanship in its handling kitchen repairs. Further for time and trouble related to repairs, but the landlord did not consider the additional failures such as its investigation and communication related to damp and subsidence when offering redress. The landlord reviewed its compensation offer in its stage two complaint response and also failed to recognise the additional areas of and extended detriment caused to the resident. This was a further failing. The financial redress the landlord offered to the resident did not adequately take into account the full extent of detriment the resident experienced, and an order is made below in respect of this.
The landlord failed to register, acknowledge, and respond to the resident’s complaints within its own policy timescales and when prompted by this Service. The landlord provided contradictory information about the handling and registration of the resident’s stage one complaint and required the resident to resend information about his complaints at both stage one and stage two of the complaint procedure. The landlord failed to recognise its oversight on the impact the landlord’s record keeping and complaint handling processes had on the progress and resolution of the outstanding repairs issues. Furthermore the cumulative adverse impact its administration processes had on the resident. This Service reviewed the landlord’s complaint handling and issued a complaint handling failure order in February 2021, yet similar complaint handling mistakes took place afterwards indicating a culture of learning and ownership was not embedded. The landlord’s complaint responses failed to demonstrate an adequate level of empathy given the time taken to address the repairs and the resident’s vulnerabilities. Taking all aspects of the landlord’s investigations and response to the resident and this Service into account this Service finds severe maladministration in the landlord’s management and handling of the resident’s complaints.

The landlord’s record keeping practises and handling of knowledge and information.

Good record keeping is vital in order to maintain a record of a landlord’s actions. It is also important in instilling confidence in the landlord and in its management systems and information. Landlords should therefore take steps to ensure that its record keeping practices are adequate, including retaining and having access to previous and existing policies, and that care is taken to provide all necessary documentation requested by the Ombudsman for its investigations.
It is evident throughout this case that the landlord failed to keep accurate and contemporaneous records of visits, repairs and/or its survey visits / assessments it completed at the property. This resulted in duplicate appointments being raised and multiple failures to respond effectively to the various repairs the resident reported. The resident should not have been required to provide a list of repairs to the landlord for repairs to have been actioned. Furthermore, the resident should not have been required to resend the outstanding repairs list again, twice when the landlord could not locate it. This caused distress, and time and trouble to the resident and cannot but have compromised confidence in the landlord.
The landlord raised works orders with statements such as “please investigate and report back” and “carry out a survey on the property for suspected subsidence.” Despite these issued instructions this Service has not seen anything like an adequate presentation of records, surveys or reports related to the resident’s property. It is unclear why it was the case that pertinent information was not recorded, captured, retained, or shared between departments and this has no doubt been a significant factor that hindered the landlord from delivering effective repair and complaint management services.
The Housing Ombudsman’s May 2023 spotlight report on knowledge and information refers specifically to these types of incidences and the landlord is encouraged to consider the impact its knowledge management has on the quality of its housing services. Further to consider its legal responsibilities alongside the obvious benefit of retaining documents.
The landlord provided commitments to share information related to its investigations into subsidence, but this was not provided, despite the resident making three requests. The delay in obtaining and sharing this information was unreasonable and would have caused further distress to the resident who was living in a property with “substantial cracks throughout,” and an increasing adverse impact on his mental health. It is evident in the landlord’s complaint responses that it relied on other teams, such as an insurance and damp and mould specialists to effect certain repairs and the landlord is entitled to arrange its housing service as it chooses. However, it is this Services expectation that where required the landlord should join up communication between departments, rather than pass the responsibility to others. In this case, information was not obtained from these separate departments to inform the landlord’s complaint responses and/or identify the progress of repairs. This was unreasonable.
The resident referred to multiple surveyor’s visits during which photographs of the property were taken, and the additional repair appointments were arranged to “observe and triage what needs to be done.” The landlord was expected to have retained and used information it had already obtained about the property to inform what action it was required to take. This Service has not seen any evidence that surveyor’s assessments or photographs were retained or used as would be expected. Setting up additional appointments to reapproach matters the landlord had already assessed caused avoidable time and trouble to the resident who had to make arrangements with his employer to be at home.
The landlord issued conflicting information related to its assessment of mechanical ventilation, condensation, and damp in the property. The landlord was expected to have used evidence and information effectively so as to have diagnosed the presence of moisture in the property effectively. Further to have provided consistent advice to the resident about the repairs so as to manage his expectations.
The resident was asked to provide copies of his stage one and stage two complaint because the landlord was unable to locate them. Accepting receipt of a complaint effectively such as by registering and acknowledging it is considered a minimal requirement by this Service. Apart from being unreasonable, the landlord’s request caused further time and trouble to the resident which was avoidable. The landlord’s failure to recognise and register the resident’s complaint indicate there were information handling concerns upon the receipt of information using the online complaints processes and this was unreasonable and required investigation to prevent further occurrences. It is not evident to this Service that the landlord identified why the complaint handling failings occurred or indeed if any investigation was undertaken whatsoever as to the cause and a means to avoid recurrence.
By failing to manage, share, and use information effectively and retain accurate, contemporaneous records of activity undertaken, the landlord was unable to progress the repairs or provide effective communication to the resident in a timely manner. The impact of its information handling practices caused extended detriment, in the form of time, trouble, and distress to the resident and resulted from a lack of ownership amongst the landlord’s staff. Consequently this service finds maladministration in the landlord’s handling of information and record keeping practices.

Determination (decision)

In accordance with Paragraph 52 of the Housing Ombudsman Scheme there was maladministration in respect of the landlord’s management and handling of:
1. outstanding repairs at the resident’s property
In accordance with Paragraph 52 of the Housing Ombudsman Scheme there was maladministration in respect of the landlord’s management and handling of:

b. reports of damp and mould in the property.

In accordance with Paragraph 52 of the Housing Ombudsman Scheme there was severe maladministration in respect of the landlord’s management and handling of:

c. the resident’s complaints.

In accordance with Paragraph 52 of the Housing Ombudsman Scheme there was maladministration in respect of the landlord’s:

d. record keeping practices and handling of knowledge and information.

Reasons

The landlord was expected to provide an effective joined-up repairs service thereby effecting repairs within reasonable timescales in line with its policies. However this was not achieved despite lists of outstanding repairs being provided by the resident and multiple inspection appointments being completed. The quality and workmanship was recognised by the landlord itself as poor and timely communication about the progress and communication about subsidence in the property was not provided effectively as expected.
The landlord failed to evidence that it assessed reports of damp and mould in the property such as by completing risk assessments, damp survey, or moisture readings. The landlord referred the property to its damp and mould team later than would be expected thereby causing extended detriment to the resident.
The landlord failed to respond to or register complaints made at stage one and two of the complaint procedure in line with its expected policy timescales. The stage one response was unreasonably delayed causing avoidable distress and inconvenience and resulted in a complaint handling failure order being issued by this Service. The landlord’s responses failed to show empathy toward the resident and the compensation award offered did not fully address the detriment caused.
The landlord failed to manage, share, and use information effectively and retain accurate, contemporaneous records of activity undertaken. The landlord was unable to progress the repairs or provide effective communication to the resident in a timely manner as a result of its failure to accurately record and retain information. The impact of its information handling practices caused detriment, in the form of time, trouble, and distress to the resident.

Orders and recommendations

The landlord is ordered to apologise to the resident for its failings in managing the various repairs and for its complaint handling failures. This is to be provided within 28 days of its receipt of this report.
In addition to any compensation previously offered and within 28 days of its receipt of this report the landlord is ordered to pay the resident:
1. £350 for inconvenience, time, and trouble associated with landlord’s handling of outstanding repairs at the resident’s property,
2. £1500 for distress and inconvenience related to its handling of damp and mould in the property,
3. £500 for distress, time, and trouble caused to the resident related to the landlord’s complaint handling failures.
The landlord is ordered to review the list of outstanding repairs with the resident and arrange for repairs to be completed at the property within 2 months of receipt of this report. Further it is to provide the resident with clear information, supported by technical surveys and moisture readings about the potential presence of damp, mould, and subsidence in the property. The landlord is expected to consider alternative rehousing where the property condition or completion of repairs has a significant impact on the quality of life of the resident.
The landlord is ordered to review the learning on this case in respect of its management of knowledge and information. It is recommended that the landlord reviews and incorporates the best practise highlighted in the Housing Ombudsman’s Spotlight report on knowledge and information into the provision of housing services. In particular related to:
1. the retention and supply of accurate records and information relied on in complaint responses,
2. the accuracy of records stored on the housing databases related to repairs and property surveys,
3. the storage and use of information related to repairs and complaint handling,
4. the storage and use of photographic evidence for assessing repairs,
5. the usage of retained maintenance records so as to avoid a requirement to re-survey.

The landlord should advise the Housing Ombudsman of its intentions to comply with this order within two months of receipt of this report.

The landlord is ordered to review the learning on this case in respect of its management of damp and mould. It is recommended that the landlord reviews and incorporates the best practise highlighted in the Housing Ombudsman’s Spotlight report on damp and into the provision of housing services. In particular related to:
1. the use of specialist equipment and advice to ensure accurate diagnosis and monitoring of damp and mould,
2. communication with residents about the diagnosis and assessment of damp and mould in the home.

The landlord should advise the Housing Ombudsman of its intentions to comply with this order within 2 months of receipt of this report.

The landlord is ordered to consider the learning from this case, and advise this Service of its plans and actions, including timescales, to ensure that its complaint handling practices fully align with the principles of the Housing Ombudsman complaint handling code. In particular:
1. the accessibility and reliability of the online process for submitting complaints to the landlord,
2. the investigation process, detail, and quality of its complaint responses,
3. enhancements to the efficacy and oversight of its complaint management processes to deliver remedy and resolution in addition to basic complaint administration.

The landlord should advise the Housing Ombudsman of its intentions to comply with this order within 2 months of receipt of this report.