By Carl Makin, PhD Researcher at the University of York

The latest insight report from the Housing Ombudsman Service paints a stark picture. Between April and June 2022, the Ombudsman found full or partial maladministration in almost half (48%) of cases.

The removal of the so-called ‘democratic filter’ through the Building Safety Act 2022 reduces the barriers faced by tenants wishing to escalate their complaints. The Ombudsman clearly expects an uptick in the number of complaints it receives, given its recent recruitment campaign in search of 30 additional adjudicators.

The Ombudsman has made moves to share examples of good practice and points of learning that providers should reflect on. Larger providers will likely have members of staff dedicated to dealing with customer complaints or governance that will have time in their busy schedules to sit, read and digest the important messages being put out by the Ombudsman. Others may struggle to find the bandwidth within their organisation to take full advantage of these materials.

To put meat on the bones of the ‘best practice’ guidance, using data kindly provided by the service, HQM spoke to three providers with low rates of upheld Ombudsman determinations, as compared with similar providers and the wider sector. This means that although some of their tenants have escalated their complaints to the Ombudsman, very few (if any) resulted in a finding of maladministration or service failure.

Between the three providers we spoke to, there was a variety of principles, approaches and outcomes. Every provider will face completely different challenges and will have a completely different starting point, but we have distilled five key takeaways that seemed common among our high performers.

1) The right structure

The structure of the complaint handling function is largely determined by organisational history. The providers described key points when their complaint handling systems were completely reinvigorated: the publication of the Ombudsman’s code; following the appointment of a new chief-executive; or when they conducted an internal review and realised they needed to take action. Each provider structures their complaint handling function in a different way, but there are some key decisions to be made that determine where this function sits within the organisation, the power it has and its relationship with the rest of the organisation.

One key question facing providers seems to be whether to centralise or de-centralise complaint handling. In a centralised system, complaint handling sits within a specific team. At Broadacres, complaints sit within their customer engagement and communications executive, where those handling complaints are seen as an “independent challenge” to other functions within the organisation.

By contrast, Karbon Homes has a well-developed de-centralised model, where individual teams deal with complaints that fall within their own remit. There’s a small central team with some staff dedicated to complaint handling, but the view is that learning from complaints flows throughout the organisation. The role of the central complaint handling function here is to build capacity, skills and knowledge so that wherever a complaint lands, it’s dealt with effectively.

As a result of mergers, Thirteen Group inherited a dispersed and decentralised structure that they were struggling with. They felt that by bringing the complaints team into their customer relations department, ensuring everything relating to residents was in one place, they could “look at the situation factually and say what’s gone wrong and what needs to be put right”. Thirteen have found that having an independent complaint handler in the middle helps prevent operational teams responding defensively to complaints about their work.

Both centralised and de-centralised systems appear to have distinct benefits in how complaint handling fits within each organisation, but a strategic decision is needed at the outset to develop an overall complaints architecture. Without this vision, it’s almost impossible to create clear pathways for complaints to flow through and change policies, processes and behaviours.

2) The right processes

In a robust system, complaints should never fall between two stools. As the Ombudsman’s recent report on the complaint handling failings at Clarion shows, poor complaint handling often has two limbs: poor procedures and poor administration. Yet, the providers we spoke to have grasped the nettle and focused on the detail of their complaint handling.

Of course, one might point out that the scale of complaints handled by the organisations featured here are on a completely different magnitude to those faced by the likes of Clarion, but the strength of processes must be proportionate to the organisation’s size, and the regulator has repeatedly told us (and the DLUHC Select Committee) that Clarion has the right systems in place to deal with the challenges it faces.

“Both centralised and de-centralised systems appear to have distinct benefits in how complaint handling fits within each organisation, but a strategic decision is needed at the outset to develop an overall complaints architecture”

Broadacres took early steps to get their procedures and administration right. Complaints are seen as a top priority, with directors and heads of service meeting monthly as part of their ‘lessons learned’ programme. They have processes to track complaints, and to create a space in which directors can constructively challenge how complaint management is being embedded across the association. During these meetings, they also take a deep dive into some of the complaints to make sure that any actions agreed, or lessons learned, have been implemented on the ground.

Similarly, Karbon makes use of a cross-team case review process where complaints are reviewed using four lenses:

• Policy and procedure – did we get this right, according to our policies?
• Culture and behaviours – did we behave in an appropriate way with our residents?
• Accessibility – are there any equality or accessibility issues that we haven’t thought about?
• Quality – does the decision made represent high-quality decision-making?

The overall message here is that complaint handling needs to be well thought out. Your organisation won’t develop a gold-plated system for dealing with complaints without a root and branch approach to tackling service issues.

3) The right systems

The ‘golden thread’ of information is an important but perhaps overused phrase. Realistically, your information cannot possibly be a golden thread if it’s stored in an incoherent mess across different spreadsheets, archaic IT systems or in a file on a member of your team’s desktop. If your organisation engages in any of this retro data handling, it’s very much out of fashion. As the Housing Ombudsman, Richard Blakeway, explained in our September edition of HQM: “Strong record keeping practices are core to good services and will be the focus of a future systemic investigation by the Housing Ombudsman, with the aim of making recommendations and sharing learning across the social housing sector.”

The key questions providers with a system that isn’t terribly outdated but could do with some TLC should be asking themselves are:

• Does our system enable us to manage the complaint journey and not miss deadlines?
• Can the system collect the data we need if a complaint is escalated to the Ombudsman?
• Is the system able to provide us with the right information so that we can see what’s going on at both the headline and the granular level?

Both Broadacres and Thirteen were able to work with their existing systems but have had to make some changes so that they can respond to complaints in line with their policies. Wendy Graham, Assistant Director of Customer Service at Karbon, explained: “We recognised that things weren’t all we wanted them to be and the system was one side of it.

“One of the things that we were struggling with was to be able to report on whether we were closing complaints within our timescales or not, but also the system didn’t allow us to have management oversight, so that management could look at the cases their team were dealing with. So much of what we were doing was manual…”

Even with their shiny new complaints handling system, Wendy said it can sometimes be difficult to provide the level of detail needed by the Ombudsman.

The key to dealing with this, all three providers agreed, was making a judgement as early as possible as to whether the complaint is going to be complex and whether it might be one that you struggle to resolve without it reaching the Ombudsman. Where this was the case, all three providers had a system of beefing up the information they collect on a particular issue and preparing detailed case files whilst a complaint is progressing through internal stages.

Implementing new IT systems can cause headaches for organisations of any size, but a review of complaints data quality and integrity, as well as a wider review of whether the system does everything that you need it to do, is an essential part of any complaint handling strategy. The Ombudsman’s message is clear: good housekeeping is not optional, and poor systems and record keeping easily lead to substandard complaint handling.

4) The right people

As well as developing and finessing policies, procedures and systems, all three providers talked about the need for cultural and behavioural change. You can have the best systems in the world, but without the right people residents will not receive the best service.

Broadacres, for example, found that a corporate restructure and the reshaping of senior job descriptions provided an opportunity to get the colleagues with the right skills acting as complaint champions. As Rebecca Sedgwick, Head of Communications at Broadacres, said: “There are people you don’t want to deal with complaints…They might be fantastic at doing what they do, but they’re not the best at speaking to people. So why give them a complaint to deal with?”

“Your organisation won’t develop a gold-plated system for dealing with complaints without a root and branch approach to tackling service issues”

Of course, training can help, but Rebecca is completely right – get the right people in the right places to deal with complaints and the whole system will work better. However, it’s also important to set down some clear rules on customer interaction. Here, Karbon have developed a set of “customer behaviours”setting out clear dos and don’ts for colleagues engaging with tenants.

The cultural shifts that the three organisations described also led to operational changes that have made a difference. Both Thirteen and Karbon have found that offering a more personal and responsive service has improved resident satisfaction. One element of this new approach is a genuine attempt to engage with residents that have a complaint; to pick up the phone and have a chat about the issue and how it might be resolved.

Bobby Usher, Customer Experience Manager at Thirteen Group, explained: “You can’t convey tone in a letter or e-mail. We make sure we call tenants to try and see if complaints can be resolved in a conversation. If the customer has something they’re unsure of, they can ask it there and then.”

Similarly, Wendy Graham at Karbon pointed out that calling residents is an important part of conveying a genuine apology and, once the complaint has been closed, making sure everything has been resolved to the tenant’s satisfaction. Otherwise, letters sent to tenants “become a formality, rather than a positive way through which we communicate our message.”

Broadacres take this personal approach further. At Stage 2 of their complaints process, their Director of Customer Experience tries to visit tenants and sit down and have a brew with them in a real attempt to resolve the complaint. This is a prime example of how seriously these organisations take resident complaints, how serious they are about putting things right and how they treat their residents with respect and courtesy.

5) Staying ahead of the curve

The three providers have clearly built solid foundations for good complaint handling, and cultures focused on listening, learning and respect. At this point, there’s a risk providers can begin to put their feet up and become complacent. Every organisation has a limited amount of resources, and Blakeway recently expressed concerns that the “immense financial pressures on landlords” could lead to a deterioration in complaint handling.

Providers need to be proactive in at least two ways: staying ahead of developing trends and issues within their own complaints workload and keeping up to date with regulatory expectations.

“Realistically, your information cannot possibly be a golden thread if it’s stored in an incoherent mess across different spreadsheets, archaic IT systems or in a file on a member of your team’s desktop. If your organisation engages in any of this retro data handling, it’s very much out of fashion”

All three organisations have focused on developing their cultures around learning from complaints and using data to understand the direction of travel. Karbon holds regular ‘customer experience action meetings’ to analyse their data and get ahead of potential issues. Broadacres uses its lessons-learned approach to create and implement stringent action plans on the back of complaints, but it combines this with technology on the frontline to try and pre-empt complaints.

They’ve brought in the Rant and Rave Dashboard so they can react in real-time to resident feedback. If a resident gives a poor rating after a call, the customer experience team immediately follows up to understand what went wrong. Being responsive is paramount to any organisation that has a strong culture of learning and continuous improvement.

Mixing it all together…

Complaints need to be taken seriously by every department and all levels within an organisation – including boards or councillors and executive teams. Having senior colleagues in the room talking about what’s going wrong on the ground keeps complaint handling alive and, ultimately, ensures building better services for tenants is a top priority.

Provider profiles:

Thirteen Group is a 35,000-home housing association based in the North East and Yorkshire. In 2020-21, the Housing Ombudsman issued eight findings relating to Thirteen. In one of these cases a service failure finding was upheld.

Broadacres Housing Association is a 6,000- home largely rural housing association operating across Yorkshire and Teesside. In 2020-21, the Housing Ombudsman issued four findings relating to Broadacres. None of those complaints were upheld.

Karbon Homes has just under 30,000 homes spread across the North East and Yorkshire. In 2020-21, the Housing Ombudsman issued 10 findings relating to Karbon. In one of these cases a service failure finding was upheld.

Join our new Complaints Hub

To support members and promote best practice in complaints handling, HQN has teamed up with complaints handling experts John Goodwin and Dave Simmons to create the Complaints Hub.

Members will have access to regularly updated resources including a complaints policy checklist, templates for commonly used letters/forms, and regular drop in sessions with John and Dave so you can get your questions answered.