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Complaint Handling Code - Self-assessment

The Housing Ombudsman’s Complaint Handling Code, introduced in July 2020, sets out good practice that helps us respond to complaints effectively and fairly.

It sets out what should expect from us as your landlord when you complain. The requirements in the code also provide residents with information about how to make a complaint and how to progress it through the landlord’s internal complaints procedure.

We, as a landlord, must carry out an annual assessment against the code to ensure our complaint handling remains in line with its requirements:

Compliance with the Complaint Handling Code

Section 1 - Definition of a complaint

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
1.2

A complaint must be defined as:

an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents.'

Yes

Section 4.3 of our policy sets out the definition of a complaint:

‘A complaint is an expression of dissatisfaction about the standard of service, actions, or lack of actions by the organisation, its staff, or those acting on behalf of the organisation. It may affect an individual or group of individuals’.

Examples included within the policy are:

  • a ‘problem that hasn’t been sorted out’
  • a member of staff has been rude to you
  • we have not done something that we said we would
  • we have taken too long to decide or provide a service
  • we have given poor advice
  • we have not treated you fairly
  • you are unhappy about a change we have made

A copy of North Northamptonshire Council’s current Compliments, Comments and Complaint’s Policy is available.

The new policy was approved by the council’s Executive Committee in July 2024 to align all services to the same timescales.

The new version of the policy was published on the council’s website in the complaints section on the 14 October.

1.3The resident does not have to use the word ‘complaint’ for it to be treated as such. Whenever a resident expresses dissatisfaction landlords must give them the choice to make complaint. A complaint that is submitted via a third party or representative must be handled in line with the landlord’s complaints policy.Yes

Residents are not required to use the word ‘complaint’, if a resident expresses dissatisfaction this will be investigated and responded to within the complaints process.

The organisation is committed to ensuring there is a comprehensive understanding to support this and will continue to work to ensure complaints in all forms are recognised and responded to.

1.4

Landlords must recognise the difference between a service request and a complaint. This must be set out in their complaints policy.

A service request is a request from a resident to the landlord requiring action to be taken to put something right.

Service requests are not complaints, but must be recorded, monitored and reviewed regularly.

Yes

Where a service request is received by the complaints team, this will be logged and passed to the relevant person to respond to the service request.

Section 4 of the council’s complaints policy defines the difference between a complaint and a service request.

On the council website customers are provided with the opportunity on the complaints page to submit an online form to report an issue or service request.
 

1.5A complaint must be raised when the resident expresses dissatisfaction with the response to their service request, even if the handling of the service request remains ongoing. Landlords must not stop their efforts to address the service request if the resident complains.Yes

Residents can make a complaint at any time during the handling of a service request, this will be investigated following the complaints process. The service request will still be addressed.

The council’s complaints policy states:

‘Action to address a service request will not stop if a complaint is raised about the issue while action is still ongoing.’

1.6

An expression of dissatisfaction with services made through a survey is not defined as a complaint, though wherever possible, the person completing the survey should be made aware of how they can pursue a complaint if they wish to.

Where landlords ask for wider feedback about their services, they also must provide details of how residents can complain.

Yes

The Tenant Satisfaction Survey of all council tenants conducted in 2023/24 asked whether tenants would be happy to share their details with the council in order to assess further any dissatisfaction. The next survey is being conducted by telephone providing the opportunity to understand dissatisfaction where possible.

The latest edition of the tenant newsletter (November 24) has a page dedicated to the complaints process along with information on the Housing Ombudsman to ensure all tenants understand how they can make a complaint if they need to.

The Housing service are currently reviewing operational satisfaction surveys and will be adding a link to the corporate complaints policy to the bottom of surveys.

Section 2 - Exclusions

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
2.1Landlords must accept a complaint unless there is a valid reason not to do so. If landlords decide not to accept a complaint they must be able to evidence their reasoning. Each complaint must be considered on its own merits.Yes

All complaints are considered on their own merits, and will be accepted as a complaint, unless they fall within the exclusions set out in the council’s corporate complaints policy in section 2.

Section 2 provides detail on what falls outside of the scope of the corporate complaints policy.

2.2

A complaints policy must set out the circumstances in which a matter will not be considered as a complaint or escalated, and these circumstances must be fair and reasonable to residents. Acceptable exclusions include:

  • the issue giving rise to the complaint occurred over twelve months ago
  • legal proceedings have started. This is defined as details of the claim, such as the Claim Form and Particulars of Claim, having been filed at court
  • matters that have previously been considered under the complaints policy
Yes

Section 2 of North Northamptonshire Council’s complaints policy sets out exclusions. The exclusions are outside of the Housing Ombudsman jurisdiction and are normally where there are Government regulations that set out how we make a decision. The appeals process for such decisions would be separate from the complaints process.

The council’s complaints page on the website also includes information on when the corporate complaints process does not apply and where there is a separate process to be followed.

2.3

Landlords must accept complaints referred to them within 12 months of the issue occurring or the resident becoming aware of the issue, unless they are excluded on other grounds.

Landlords must consider whether to apply discretion to accept complaints made outside this time limit where there are good reasons to do so.

YesIn section 4 of the council’s corporate policy it sets out that complainants should contact the council as soon as possible after the matter they wish to complain about and that complaints must be made within 12 months of the issue arising, or when you become aware of the issue.
2.4

If a landlord decides not to accept a complaint, an explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman.

If the Ombudsman does not agree that the exclusion has been fairly applied, the Ombudsman may tell the landlord to take on the complaint.

Yes

All complaints will be accepted unless they fall under the exclusions listed within the policy.

If correspondence falls within the list of exclusions, and therefore follows an alternative process to the complaints process, an explanation will be provided to the resident.

2.5Landlords must not take a blanket approach to excluding complaints; they must consider the individual circumstances of each complaint.YesAll complaints are considered on an individual basis.

Section 3 – Accessibility and awareness

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
3.1Landlords must make it easy for residents to complain by providing different channels through which they can make a complaint. Landlords must consider their duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process.Yes

There are many ways to complain to North Northamptonshire Council including:

  • by website form
  • by telephone
  • by email
  • in writing
  • Asking your local councillor to raise it for you

These are all listed on the council’s website and within the policy.

3.2Residents must be able to raise their complaints in any way and with any member of staff. All staff must be aware of the complaints process and be able to pass details of the complaint to the appropriate person within the landlord.Yes

A copy of the corporate complaints policy is available and a dedicated complaints section has now been added to the council’s intranet.

Complaints training rolled out council wide at the end of September to cover the new policy requirements for wider services and the new system being introduced.

3.3High volumes of complaints must not be seen as a negative, as they can be indicative of a well-publicised and accessible complaints process. Low complaint volumes are potentially a sign that residents are unable to complain.YesComplaint levels indicate that the Corporate Complaint’s policy is easily accessible.
3.4Landlords must make their complaint policy available in a clear and accessible format for all residents. This will detail the two stage process, what will happen at each stage, and the timeframes for responding. The policy must also be published on the landlord’s website.Yes

A copy of the complaints policy is available.

All documents on the council’s website are produced in an accessible format with clear language.

Along with the policy document the two stages are also set out on the complaints page of the council’s website.

3.5The policy must explain how the landlord will publicise details of the complaints policy, including information about the Ombudsman and this Code.YesLink to the Housing Ombudsman website is included in the corporate complaints policy and reference to the code in section 3.
3.6Landlords must give residents the opportunity to have a representative deal with their complaint on their behalf, and to be represented or accompanied at any meeting with the landlord.YesSection 4 of the council’s corporate complaints policy states comments, compliments and complaints may be made on someone else's behalf with their written consent.
3.7Landlords must provide residents with information on their right to access the Ombudsman service and how the individual can engage with the Ombudsman about their complaint.Yes

The Housing Ombudsman details are included in the corporate complaint’s policy, as well as on our website. The Housing Ombudsman details are also part of complaint responses advising customers, they can contact the Housing Ombudsman service to investigate their complaint and that this will be an independent investigation.

Complaint responses include details on the Housing Ombudsman Service along with a link to the complaint form and contact details.

Section 4 – Complaint handling staff

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
4.1

Landlords must have a person or team assigned to take responsibility for complaint handling, including liaison with the Ombudsman and ensuring complaints are reported to the governing body (or equivalent).

This Code will refer to that person or team as the ‘complaints officer’. This role may be in addition to other duties.

Yes

The council has a Corporate Complaints Team who are responsible for acknowledging complaints and passing to the relevant service area for investigation.

The Corporate Complaints Team is responsible for the record keeping of all complaints and is responsible for reporting complaints performance to councillors and the Corporate Management Team.

Housing is currently undergoing a restructure which plans to introduce a dedicated Complaint’s Officer within the Housing team to co-ordinate all Housing complaints and be the liaison with the Corporate Complaints Team to ensure there is a strong oversight and responsibility for complaints within the service.

4.2The complaints officer must have access to staff at all levels to facilitate the prompt resolution of complaints. They must also have the authority and autonomy to act to resolve disputes promptly and fairly.Yes

The complaints process has recently been reviewed. The investigation and responses of complaints are now dealt with within each service area, this helps to improve access to relevant staff and systems.

The policy ensures complaints are responded to by officers with authority to investigate and resolve including where the resolution involves decision making.

4.3

Landlords are expected to prioritise complaint handling and a culture of learning from complaints. All relevant staff must be suitably trained in the importance of complaint handling.

It is important that complaints are seen as a core service and must be resourced to handle complaints effectively.

YesOnce a complaint response is sent to the resident, a learning plan must be produced and sent to the Corporate Complaints Team along with the complaint response. These learning plans will be monitored by the service and used to help improve our services.

Section 5: Complaint handling process

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
5.1Landlords must have a single policy in place for dealing with complaints covered by this Code. Residents must not be treated differently if they complain.YesThe council has one corporate complaints policy approved at executive in July 2024, which covers all aspects of council services which are now all aligned to the same timescales required within the complaint handling codes.
5.2The early and local resolution of issues between landlords and residents is key to effective complaint handling. It is not appropriate to have extra named stages (such as ‘stage 0’ or ‘informal complaint’) as this causes unnecessary confusion.YesNorth Northamptonshire Council has a two stage Complaints process. There is no additional ‘informal’ stage.
5.3A process with more than two stages is not acceptable under any circumstances as this will make the complaint process unduly long and delay access to the Ombudsman.YesNorth Northamptonshire Council has a two stage complaints process only.
5.4Where a landlord’s complaint response is handled by a third party (e.g. a contractor or independent adjudicator) at any stage, it must form part of the two stage complaints process set out in this Code. Residents must not be expected to go through two complaints processes.YesThis is not applicable as complaints are not dealt with by a contractor.
5.5Landlords are responsible for ensuring that any third parties handle complaints in line with the Code.YesThis is not applicable as complaints are not dealt with by a contractor.
5.6When a complaint is logged at Stage 1 or escalated to Stage 2, landlords must set out their understanding of the complaint and the outcomes the resident is seeking. The Code will refer to this as “the complaint definition”. If any aspect of the complaint is unclear, the resident must be asked for clarification.YesThe council’s complaints responses include the understanding of the complaint. The template response letter sets out the need to confirm what the complaint was about.
5.7When a complaint is acknowledged at either stage, landlords must be clear which aspects of the complaint they are, and are not, responsible for and clarify any areas where this is not clear.YesIf there are aspects of the complaint that the council is not responsible for, this will be explained in the acknowledgement. The council’s new Tenant’s Handbook will be published in December 2024 and will include areas that the council is responsible for. along with defining what the tenant is responsible for. 
5.8

At each stage of the complaints process, complaint handlers must:

  1. Deal with complaints on their merits, act independently, and have an open mind.
  2. Give the resident a fair chance to set out their position.
  3. Take measures to address any actual or perceived conflict of interest.
  4. Consider all relevant information and evidence carefully.
YesThe Council’s Complaints process complies with this.
5.9Where a response to a complaint will fall outside the timescales set out in this Code, the landlord must agree with the resident suitable intervals for keeping them informed about their complaint.YesRequests for extensions to timescales for responding to complaints must only be made if there is a good reason to do so. The service areas are responsible for liaising with the resident where an extension is needed in order to investigate the complaint and agree suitable intervals to keep the resident informed. The service area should then report the extension to the Corporate Complaints Team for recording purposes.
5.10

Landlords must make reasonable adjustments for residents where appropriate under the Equality Act 2010.

Landlords must keep a record of any reasonable adjustments agreed, as well as a record of any disabilities a resident has disclosed. Any agreed reasonable adjustments must be kept under active review.

Yes

The Council welcomes complaints from all sections of the community and may encourage people to seek support from friends or other representatives who may be able to assist them in making a complaint. The Council will advise people on where to find such assistance as appropriate.

Assistance will be given where appropriate to people who have difficulty with written or spoken English and to disabled people. People will also be able to make complaints in their own language if this is preferable. The Council’s intention is that all members of the public should have full access to the Compliments, Comments or Complaints Procedure.

5.11Landlords must not refuse to escalate a complaint through all stages of the complaints procedure unless it has valid reasons to do so. Landlords must clearly set out these reasons, and they must comply with the provisions set out in section 2 of this Code.YesThe council complies with section 2 of the code.
5.12A full record must be kept of the complaint, and the outcomes at each stage. This must include the original complaint and the date received, all correspondence with the resident, correspondence with other parties, and any relevant supporting documentation such as reports or surveys.YesThe majority of complaints received are made through the online website form. All complaints are logged centrally by the Corporate Complaints Team before sending to the service areas for a response. The responses are then logged by the Corporate Complaints Team.
5.13Landlords must have processes in place to ensure a complaint can be remedied at any stage of its complaints process. Landlords must ensure appropriate remedies can be provided at any stage of the complaints process without the need for escalation.Yes

A new remedy policy has been drafted and approved. This policy sets out appropriate remedies.

This policy is published internally only.

5.14Landlords must have policies and procedures in place for managing unacceptable behaviour from residents and their representatives. Landlords must be able to evidence reasons for putting any restrictions in place and must keep restrictions under regular review.Yes

Sometimes people may behave unreasonably, be unacceptably persistent, stop us looking into the matter or make repeated complaints about the same subject as well as contacting us many more times than is necessary to resolve a matter.

We call this type of complaint persistent or vexatious.

In these cases, we may limit our responses or advise residents that we cannot respond. The Council’s Unacceptable or Unreasonable Communications and Behaviour Policy has been reviewed, revised and received Executive approval. 

A copy of the policy will be published externally and the council is developing it’s processes and support for managing unacceptable behaviour.

5.15Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010.YesThe Council’s Unacceptable or Unreasonable Communications and Behaviour Policy has been reviewed and approved. The new version of the policy strengthens the proportionate element.

Section 6 – Complaints stages

Stage 1

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
6.1Landlords must have processes in place to consider which complaints can be responded to as early as possible, and which require further investigation. Landlords must consider factors such as the complexity of the complaint and whether the resident is vulnerable or at risk. Most stage 1 complaints can be resolved promptly, and an explanation, apology or resolution provided to the resident.Yes

Improvements have been made to the council’s internal complaints resource on the Intranet.

The page includes a copy of the following:

  • Policy
  • Forms
  • Remedy guidance
  • Template letters
  • Differences between Service request or complaints

The complaints handling toolkit also includes links to Housing Ombudsman guidance.

Ombudsman training sessions are also to be provided to managers following a council wide session held in September 2024.

6.2Complaints must be acknowledged, defined and logged at stage 1 of the complaints procedure within five working days of the complaint being received.YesWhere a resident feels a concern is not resolved at the initial point of contact, North Northamptonshire Council would not obstruct access to the complaint’s procedure. The Council’s policy is to acknowledge complaints within 5 working days.
6.3Landlords must issue a full response to stage 1 complaints within 10 working days of the complaint being acknowledged.YesThe council’s corporate complaint’s policy has a 10-working day timescale for responding to stage one complaints which was approved at Executive in July and published in October 2024, however Housing have been working to these timescales since the Code was introduced.
6.4Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 10 working days without good reason, and the reason(s) must be clearly explained to the resident.YesThe Council’s Corporate Complaints Policy sets out that if a complaint is complex, or we need more information, it may take longer – however we will let residents know when this is required, and when they will hear from us.
6.5When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.YesExtensions to timescales are usually made via telephone or email with the resident.
6.6A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.Yes

Any outstanding actions following the complaint response will be included in the learning plan along with dates when the outstanding actions will be completed.

The Housing service is responsible for maintaining its learning and improvement outcomes; this will be subject to reporting and corporate scrutiny.

6.7Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.YesThe Council’s complaint responses will set out what happened, why and what we are doing about it. It will give the remedies available to the resident and include the lessons that we have learnt where we have got things wrong, so that we don’t make the same mistakes in future.
6.8Where residents raise additional complaints during the investigation, these must be incorporated into the stage 1 response if they are related and the stage 1 response has not been issued. Where the stage 1 response has been issued, the new issues are unrelated to the issues already being investigated or it would unreasonably delay the response, the new issues must be logged as a new complaint.YesThe Council complies with this.
6.9

Landlords must confirm the following in writing to the resident at the completion of stage 1 in clear, plain language:

  1. The complaint stage.
  2. The complaint definition.
  3. The decision on the complaint.
  4. The reasons for any decisions made.
  5. The details of any remedy offered to put things right.
  6. Details of any outstanding actions.
  7. Details of how to escalate the matter to stage 2 if the individual is not satisfied with the response.
Yes

In section 4 of the Council’s Corporate Complaints Policy it sets out:

Our response to you will set out the issues investigated, the background to the case, the evidence used in assessing the case, the reasons for the findings or decisions made. If we identify we did something wrong, we will explain what went wrong and why and take appropriate steps to remedy the service failure in line with appropriate policy.

The council has letter templates for each stage to ensure all relevant information is included in the responses.

Stage 2

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
6.10If all or part of the complaint is not resolved to the resident’s satisfaction at stage 1, it must be progressed to stage 2 of the landlord’s procedure. Stage 2 is the landlord’s final response.YesThe Council’s Corporate Complaints section on the website clearly explains the two-stage process.
Once the resident has received the result of the investigation, they may feel that we have not sorted things out in the way they expected, or they may disagree with our findings and are advised they can now make a stage 2 complaint.
6.11Requests for stage 2 must be acknowledged, defined and logged at stage 2 of the complaints procedure within five working days of the escalation request being received.YesAll stage two complaints are logged, and an acknowledgement sent within 5 working days.
6.12Residents must not be required to explain their reasons for requesting a stage 2 consideration. Landlords are expected to make reasonable efforts to understand why a resident remains unhappy as part of its stage 2 response.YesThe Council complies with this.
6.13The person considering the complaint at stage 2 must not be the same person that considered the complaint at stage 1.YesStage two complaints will not be investigated by the same officer as the stage one complaint.
6.14Landlords must issue a final response to the stage 2 within 20 working days of the complaint being acknowledged.YesThe Council’s timescales for responding to stage two complaints is 20 working days.
6.15Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 20 working days without good reason, and the reason(s) must be clearly explained to the resident.Yes

The Council’s Corporate Complaints Policy in section 4 sets out that if a complaint is complex, or we need more information, it may take longer – however we will let residents know when this is required, and when they will hear from us.

Example - 4.9.4 If a response cannot be provided within 10 working days you will be contacted with an explanation and updated with a date for resolution.

6.16When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.YesExtensions to timescales are usually made via telephone or email with the resident.
6.17A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.YesAny outstanding actions following the complaint response will be included in the learning plan along with dates when the outstanding actions will be completed.
6.18Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.YesThe Council’s complaint responses will set out what happened, why and what we are doing about it. It will give the remedies available to the resident and include the lessons that we have learnt where we have got things wrong, so that we don’t make the same mistakes in future.
6.19

Landlords must confirm the following in writing to the resident at the completion of stage 2 in clear, plain language:

  1. The complaint stage.
  2. The complaint definition.
  3. The decision on the complaint.
  4. The reasons for any decisions made.
  5. The details of any remedy offered to put things right.
  6. Details of any outstanding actions.
  7. Details of how to escalate the matter to the Ombudsman Service if the individual remains dissatisfied.
Yes

In section 4 of the Council’s Corporate Complaints Policy it sets out:

Our response to you will set out the issues investigated, the background to the case, the evidence used in assessing the case, the reasons for the findings or decisions made. If we identify we did something wrong, we will explain what went wrong and why and take appropriate steps to remedy the service failure in line with appropriate policy.

The council has letter templates for each stage to ensure all relevant is included in the responses.

6.20Stage 2 is the landlord’s final response and must involve all suitable staff members needed to issue such a response.YesManagers are responsible for approving stage two responses which will then be sent to the Corporate Complaints team for recording purposes.

Section 7 – Putting things right

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
7.1

Where something has gone wrong a landlord must acknowledge this and set out the actions it has already taken, or intends to take, to put things right. These can include:

  • apologising
  • acknowledging where things have gone wrong
  • providing an explanation, assistance or reasons
  • taking action if there has been delay
  • reconsidering or changing a decision
  • amending a record or adding a correction or addendum
  • providing a financial remedy
  • changing policies, procedures or practices
YesThe Council’s revised Remedies Policy supports this stage.
7.2Any remedy offered must reflect the impact on the resident as a result of any fault identified.YesThe Council’s revised Remedies Policy supports this stage.
7.3The remedy offer must clearly set out what will happen and by when, in agreement with the resident where appropriate. Any remedy proposed must be followed through to completion.YesThe Council’s revised Remedies Policy supports this stage.
7.4Landlords must take account of the guidance issued by the Ombudsman when deciding on appropriate remedies.YesThe Council’s revised Remedies Policy supports this stage, with links to the Housing Ombudsman’s guidance on remedies also included on the staff Intranet to support staff in complaint remedies and responses.

Section 8 – Self-assessment, reporting and compliance

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
8.1

Landlords must produce an annual complaints performance and service improvement report for scrutiny and challenge, which must include:

  1. The annual self-assessment against this Code to ensure their complaint handling policy remains in line with its requirements.
  2. A qualitative and quantitative analysis of the landlord’s complaint handling performance. This must also include a summary of the types of complaints the landlord has refused to accept.
  3. Any findings of non-compliance with this Code by the Ombudsman.
  4. The service improvements made as a result of the learning from complaints.
  5. Any annual report about the landlord’s performance from the Ombudsman.
  6. Any other relevant reports or publications produced by the Ombudsman in relation to the work of the landlord.
Yes

A copy of the Council’s annual complaints performance and service improvement report is available.

The annual complaints performance and service improvement report was presented at the Council’s Executive Committee in September 2024 along with the Regulator of Social Housing Tenant Satisfaction Measures.

8.2The annual complaints performance and service improvement report must be reported to the landlord’s governing body (or equivalent) and published on the on the section of its website relating to complaints. The governing body’s response to the report must be published alongside this.Yes

The annual complaints performance and service improvement report was presented at the Council’s Executive Committee in September 2024.

Executive Committee Decision:

Resolved

That the Executive:

a) Noted the performance of the new Tenant Satisfaction Measures (TSMs) as set out in Appendix A, comparative performance across six other housing providers provided in Appendix B and the Annual Complaints Performance and Service Improvement Report provided in Appendix C

8.3Landlords must also carry out a self-assessment following a significant restructure, merger or change in procedures.Yes

This self-assessment has been reviewed following the 2024 changes to the Code and will be reviewed following any significant restructure or change in procedures.

The new Customer comments, Compliments and Complaints Policy was approved by the Council’s Executive Committee in July 2024 and published online in October 2024. This self-assessment form has been updated based on the new policy.

8.4Landlords may be asked to review and update the self-assessment following an Ombudsman investigation.YesThe Council will comply with this if requested to do so.
8.5If a landlord is unable to comply with the Code due to exceptional circumstances, such as a cyber incident, they must inform the Ombudsman, provide information to residents who may be affected, and publish this on their website Landlords must provide a timescale for returning to compliance with the Code.YesThe Council will comply with this if required.

Section 9 – Scrutiny and oversight: continuous learning and improvement

Code sectionCode requirementComply: Yes or noEvidence, commentary and any explanations
9.1Landlords must look beyond the circumstances of the individual complaint and consider whether service improvements can be made as a result of any learning from the complaint.Yes

Learning plans are produced along with complaint responses. Each service area is responsible for maintaining its learning and improvement outcomes; this will be subject to reporting and corporate scrutiny.

Further work to be undertaken on learning from complaints and analysing the information to provide data insight which can link in with and identify service improvement projects.

9.2A positive complaint handling culture is integral to the effectiveness with which landlords resolve disputes. Landlords must use complaints as a source of intelligence to identify issues and introduce positive changes in service delivery.Yes

The new policy supports this, and a positive Complaint Handling culture is being developed with additional training, guidance and information being rolled out and a new case management system being introduced. A project team has been set up to help enhance our customer experience, automate complaints processes, boost efficiency, and effectively address complaints for organisational learning and improvement.

The way complaints are handled within the service area is currently being reviewed, with the forthcoming recruitment of a Complaints Officer as part of the restructure. This will ensure there is more work on learning from complaints and linking in with service improvement.

9.3Accountability and transparency are also integral to a positive complaint handling culture. Landlords must report back on wider learning and improvements from complaints to stakeholders, such as residents’ panels, staff and relevant committees.Yes

The Corporate Performance team report on complaints to Executive on a regular basis. Power BI dashboard is currently being developed to help provide real-time information on housing complaints which can be shared with key stakeholders on a regular basis.

The way complaints are handled within the service area is currently being reviewed, with the plan to recruit a dedicated Complaints Officer. This will ensure there is more work on learning from complaints and linking in with service improvement.

9.4Landlords must appoint a suitably senior lead person as accountable for their complaint handling. This person must assess any themes or trends to identify potential systemic issues, serious risks, or policies and procedures that require revision.YesConfirmed as Simon Mills, Assistant Director Customer Experience.
9.5In addition to this a member of the governing body (or equivalent) must be appointed to have lead responsibility for complaints to support a positive complaint handling culture. This person is referred to as the Member Responsible for Complaints (‘the MRC’).YesConfirmed as Cllr Lloyd Bunday, Executive Member for Finance and Transformation.
9.6The MRC will be responsible for ensuring the governing body receives regular information on complaints that provides insight on the landlord’s complaint handling performance. This person must have access to suitable information and staff to perform this role and report on their findings.YesComplaint information is regularly presented as part of the monthly performance report to Executive.
9.7

As a minimum, the MRC and the governing body (or equivalent) must receive:

  1. Regular updates on the volume, categories and outcomes of complaints, alongside complaint handling performance.
  2. Regular reviews of issues and trends arising from complaint handling.
  3. Regular updates on the outcomes of the Ombudsman’s investigations and progress made in complying with orders related to severe maladministration findings.
  4. Annual complaints performance and service improvement report.
YesThe Corporate Performance Team provide regular complaints performance to Executive.
9.8

Landlords must have a standard objective in relation to complaint handling for all relevant employees or third parties that reflects the need to:

  1. Have a collaborative and co-operative approach towards resolving complaints, working with colleagues across teams and departments.
  2. Take collective responsibility for any shortfalls identified through complaints, rather than blaming others.
  3. Act within the professional standards for engaging with complaints as set by any relevant professional body.
Yes

Improvements have been made to the Council’s internal complaints resource on the Intranet. The page includes a copy of the following:

  • Policy
  • Forms
  • Remedy guidance
  • Template letters
  • Differences between Service request and complaints

Training has been rolled out to staff to support the introduction of the new case management with the aim to enhance our customer experience, automate complaints processes, boost efficiency, and effectively address complaints for organisational learning and improvement.

Compliance with the Complaint Handling Code

Section 1 - Definition of a complaint

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
1.2

A complaint must be defined as:

‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the landlord, its own staff, or those acting on its behalf, affecting a resident or group of residents.’ 

 

Yes

Section 4.3 of North Northamptonshire Council’s Housing Landlord Services Customer Complaints Policy sets out the following: 

‘A complaint is an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the landlord, its own staff, or those acting on its behalf, affecting a resident or group of residents’.

The council has introduced a new Housing Landlord Services Customer Complaints Policy. This policy will sit as an annex to the main Corporate Complaints Policy and has been produced in line with the Housing Ombudsman’s Complaint Handling Code. This self-assessment is based on the new policy. A copy of which will be available on the council’s website following Audit and Governance committee on 29th September 2025.
1.3A resident does not have to use the word ‘complaint’ for it to be treated as such. Whenever a resident expresses dissatisfaction landlords must give them the choice to make complaint. A complaint that is submitted via a third party or representative must be handled in line with the landlord’s complaints policy.Yes

Section 4.5 of the Housing Landlord Services Customer Complaints Policy sets out: 

‘Where a resident expresses dissatisfaction, they will be given the choice to make a complaint under this policy; the word complaint is not required to be used in the expression of dissatisfaction for it to be treated as a complaint’. 

The organisation is committed to ensuring there is a comprehensive understanding to support this and will continue to work to ensure complaints in all forms are recognised and responded to in a timely manner.
1.4Landlords must recognise the difference between a service request and a complaint. This must be set out in their complaints policy. A service request is a request from a resident to the landlord requiring action to be taken to put something right. Service requests are not complaints, but must be recorded, monitored and reviewed regularly.Yes

Section 4.4 of the Housing Landlord Services Customer Complaints Policy sets out the following in relation to service requests: 

‘A service request is a request from a resident to the landlord requiring action to be taken to put something right. Service requests are not complaints, but will be recorded, monitored and reviewed regularly. Action to address a service request will not stop if a complaint is raised about the issue while action is still ongoing. You can contact us online, by telephone, in writing or in person to submit a service request.  If you submit a service request as a comment, compliment, or complaint it will be acknowledged and recorded and forwarded to the service for resolution in line with the policies and processes applicable to the service being requested’. 

On the complaints page of the council’s website customers are provided with the opportunity to submit an online form to report an issue/service request.
1.5A complaint must be raised when the resident expresses dissatisfaction with the response to their service request, even if the handling of the service request remains ongoing. Landlords must not stop their efforts to address the service request if the resident complains. Yes

Section 4.4 of the Housing Landlord Services Customer Complaints Policy states:

‘Action to address a service request will not stop if a complaint is raised about the issue while action is still ongoing’.

The complaints handling approach ensures service requests are actioned and complaints are handled separately.
1.6An expression of dissatisfaction with services made through a survey is not defined as a complaint, though wherever possible, the person completing the survey should be made aware of how they can pursue a complaint if they wish to. Where landlords ask for wider feedback about their services, they also must provide details of how residents can complain. Yes

The Tenant Satisfaction Survey of a sample of tenants conducted in 2024/25 via telephone gave tenants the opportunity to express dissatisfaction. Any alerts arising from the Tenant Satisfaction were then followed up promptly. 

The Housing transactional surveys in place include a link to the Complaints Policy to ensure tenants are aware of how to complain.

When carrying out feedback surveys throughout the year, we ensure customers are aware of the complaint handling process.

 

Section 2 - Exclusions

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
2.1Landlords must accept a complaint unless there is a valid reason not to do so. If landlords decide not to accept a complaint they must be able to evidence their reasoning. Each complaint must be considered on its own meritsYesAll complaints are considered on their own merits, and will be accepted as a complaint, unless they fall within the exclusions set out in the Housing Landlord Services Customer Complaints Policy outlined under section 2.3.

Our complaints policy details the circumstances where we would and would not accept a complaint, and this is also available on our website.

If the complaint is not accepted, we will explain the reason for this.

2.2

A complaints policy must set out the circumstances in which a matter will not be considered as a complaint or escalated, and these circumstances must be fair and reasonable to residents. Acceptable exclusions include:

  • The issue giving rise to the complaint occurred over twelve months ago.
  • Legal proceedings have started. This is defined as details of the claim, such as the Claim Form and Particulars of Claim, having been filed at court.
  • Matters that have previously been considered under the complaints policy. 
Yes

Section 2.3 sets out the matters which are out of scope of the Housing Landlord Services Complaints Policy. These include:

  • Complaints about compensation
  • Decisions subject to appeals
  • Recharges fees for repairs
  • Planning consultation responses
  • Expressions of dissatisfaction made through a survey
  • Matters under consideration by courts or tribunals
  • Matters subject to legal action
  • Matters for insurance claims
  • Matters not related to the actions or decisions of the council or anybody acting on its behalf
  • Political comments
  • Matters raised by Members of Parliament (MPs) are responded to directly
  • Matters raised by Councillors are responded to directly
  • Matters raised by employees which fall under internal policy
  • Matters subject to internal disciplinary or grievance procedures
  • HR Recruitment complaints
  • Complaints already concluded under this policy
  • Complaints on matters which an Ombudsman Service has concluded no fault to the council
The council’s complaints page on the website also includes information on when the corporate complaints process does not apply and where there is a separate process to be followed.
2.3Landlords must accept complaints referred to them within 12 months of the issue occurring or the resident becoming aware of the issue, unless they are excluded on other grounds. Landlords must consider whether to apply discretion to accept complaints made outside this time limit where there are good reasons to do so. YesSection 4.8 of the Housing Landlord Services Customer Complaints Policy asks residents to contact North Northamptonshire Council as soon as practically possible about the matter they wish to raise. Unless a complaint is excluded on other grounds set out in the policy.The council will accept complaints raised within 12 months of the issue occurring or of the resident becoming aware of the issue. Complaints raised outside of the 12-month time limit will be considered on individual merit.
2.4If a landlord decides not to accept a complaint, an explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman. If the Ombudsman does not agree that the exclusion has been fairly applied, the Ombudsman may tell the landlord to take on the complaint. YesThe Housing Landlord Services Customer Complaints Policy states that if the council does not accept the complaint, the resident will be provided with the reasons why and will have the right to ask the Housing Ombudsman to review that decision.If correspondence falls within the list of exclusions and therefore follows an alternative process to the complaints process, an explanation will be provided to the resident.
2.5Landlords must not take a blanket approach to excluding complaints; they must consider the individual circumstances of each complaint.YesSection 4.8 of the Housing Landlord Services Customer Complaints Policy states that unless a complaint is excluded on other grounds set out in the policy, the council will accept complaints raised within 12 months of the issue occurring or of the resident becoming aware of the issue. Complaints raised outside of the 12-month time limit will be considered on individual merit.Our approach to complaint handling ensures that individual circumstances are taken into consideration for all cases.

 

 

Section 3: Accessibility and Awareness

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
3.1Landlords must make it easy for residents to complain by providing different channels through which they can make a complaint. Landlords must consider their duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process. Yes

Section 4.9 of the Housing Landlord Services Customer Complaints Policy states that 

Comments, compliments, complaints may be made in a variety of ways to ensure accessibility. The quickest way is to submit this is on our website. You can also submit a complaint in writing, via email, by telephone or in person at our offices. We will ask if adjustments are required and if so, we will endeavour to ensure reasonable adjustments are made’.

All complaints are then logged and managed on the corporate case management system.
3.2Residents must be able to raise their complaints in any way and with any member of staff. All staff must be aware of the complaints process and be able to pass details of the complaint to the appropriate person within the landlord.YesA copy of the Housing Landlord Services Customer Complaints Policy will be made available on the council’s website following the Audit and Governance Committee on 29 September 2025. In the meantime, the current Corporate Complaints Policy is available on the council’s website. A dedicated complaints section is also available on the council’s intranet for staff dealing with complaints.Housing staff have also been undertaking the Housing Ombudsman Complaints Handling Code training to ensure they understand the requirements of the Code and to ensure complaint handling is effective across the service.
3.3High volumes of complaints must not be seen as a negative, as they can be indicative of a well-publicised and accessible complaints process.  Low complaint volumes are potentially a sign that residents are unable to complain.Yes

Complaint levels indicate that the Corporate Complaint’s policy is easily accessible. 

This approach to viewing complaints volumes as a positive is also emphasised through the recent Housing Ombudsman Complaint Handling Code training undertaken by staff.

A Service Improvement Team is being introduced as part of the Housing Restructure which will take a lead on analysing complaints and identifying reasons along with driving improvements and learning from complaints.
3.4Landlords must make their complaint policy available in a clear and accessible format for all residents. This will detail the two stage process, what will happen at each stage, and the timeframes for responding. The policy must also be published on the landlord’s website.Yes

The Housing Landlord Services Customer Complaints Policy will be published on the council’s website following the Audit and Governance Committee on 29 September. In the meantime, the Council’s Corporate Complaints Policy is available on the Council’s website.

Section 5.2 of the Landlord Services Customer Complaints Policy sets out the equality implications of the policy. The policy has been written in an inclusive manner to ensure ease of understanding by the widest possible audience. It has been written in plain English to ensure ease of translation. The council will ensure a variety of access methods are available to customers. The council will monitor and evaluate processes to ensure that they continue to be accessible to customers. The council will seek to accommodate reasonable adjustments and preferred methods of contact.

Along with the policy document the two stages are also set out clearly on the complaints page of the council’s website.
3.5The policy must explain how the landlord will publicise details of the complaints policy, including information about the Ombudsman and this Code.YesA link to the Housing Ombudsman website is included in section 3.1 of the Housing Landlord Services Customer Complaints Policy along with a link to the Complaint Handling Code. A link to the Housing Ombudsman’s contact details is also available on the council’s website.

We publicise our complaints policy on our website.

A copy of the self-assessment and annual complaints and service improvement report are also published annually on the website.

Throughout the complaint handling process, including within template letters, Housing ombudsman details are provided.

3.6Landlords must give residents the opportunity to have a representative deal with their complaint on their behalf, and to be represented or accompanied at any meeting with the landlord. YesSection 4.6 of the Housing Landlord Services Customer Complaints Policy states that comments, compliments and complaints may be made on someone else's behalf with their written consent and will be handled in line with this policy.Our complaint handling process is compliant with this section of the code.
3.7Landlords must provide residents with information on their right to access the Ombudsman service and how the individual can engage with the Ombudsman about their complaint.YesSection 3.1 of the Housing Landlord Services Customer Complaints Policy provides this information.In addition, this information is available on our website and the Housing Ombudsman details are also part of complaint responses advising customers, they can contact the Housing Ombudsman service to investigate their complaint and that this will be an independent investigation.

 

Section 4 - Complaint handling staff

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
4.1

Landlords must have a person or team assigned to take responsibility for complaint handling, including liaison with the Ombudsman and ensuring complaints are reported to the governing body (or equivalent). This Code will refer to that person or team as the ‘complaints officer’. This role may be in addition to other duties. 

 

YesThe council has a Corporate Complaints Team who are responsible for acknowledging complaints and passing to the relevant service area for investigation. The council has introduced a new corporate complaints case management system to enable improved monitoring and record keeping of complaints.Within Housing there are dedicated managers and staff who lead on complaint responses for their service.
4.2The complaints officer must have access to staff at all levels to facilitate the prompt resolution of complaints. They must also have the authority and autonomy to act to resolve disputes promptly and fairly.Yes

The investigation and responses of complaints are dealt with within each service area, this helps to improve access to relevant staff and systems along with ensuring subject matter experts are involved in the complaint response.

 

The policy ensures complaints are responded to by officers with authority to investigate and resolve including where the resolution involves decision making.
4.3Landlords are expected to prioritise complaint handling and a culture of learning from complaints. All relevant staff must be suitably trained in the importance of complaint handling. It is important that complaints are seen as a core service and must be resourced to handle complaints effectivelyYesOnce a complaint response is sent to the resident, a learning plan must be produced. These learning plans will be monitored by the service and used to help improve our services.A Service Improvement Team is being introduced as part of the Housing Restructure which will take a lead on analysing complaints and identifying reasons along with driving improvements and learning from complaints.

Section 5 - The complaint handling process

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
5.1Landlords must have a single policy in place for dealing with complaints covered by this Code. Residents must not be treated differently if they complain. YesThe council has a Housing Landlord Services customer complaints policy in addition to the Corporate Complaints Policy to ensure compliance with the requirements of this code. This policy has been developed in line with the Complaint Handling Code of Practice and recommendations from the Housing Ombudsman as part of a recent compliance audit in 2025.
5.2The early and local resolution of issues between landlords and residents is key to effective complaint handling. It is not appropriate to have extra named stages (such as ‘stage 0’ or ‘informal complaint’) as this causes unnecessary confusion.  YesNorth Northamptonshire Council has a two stage Complaints process. There is no additional ‘informal’ stage.The two-stage process is clearly outlined on the council’s website.
5.3A process with more than two stages is not acceptable under any circumstances as this will make the complaint process unduly long and delay access to the Ombudsman.YesNorth Northamptonshire Council has a two stage Complaints process only.The council is compliant with this.
5.4Where a landlord’s complaint response is handled by a third party (e.g. a contractor or independent adjudicator) at any stage, it must form part of the two stage complaints process set out in this Code. Residents must not be expected to go through two complaints processes.YesThis is not applicable as complaints are not dealt with by a contractor.All complaints are dealt with by the Corporate Complaints Team and subject matter experts within Housing.
5.5Landlords are responsible for ensuring that any third parties handle complaints in line with the Code.  YesThis is not applicable as complaints are not dealt with by a contractor.All complaints are dealt with by the Corporate Complaints Team and subject matter experts within Housing.
5.6When a complaint is logged at Stage 1 or escalated to Stage 2, landlords must set out their understanding of the complaint and the outcomes the resident is seeking. The Code will refer to this as “the complaint definition”. If any aspect of the complaint is unclear, the resident must be asked for clarification. YesThe council has reviewed its complaints process and has introduced a new process to ensure there is a complaint acknowledgement from the relevant team within the service that will set out the understanding of the complaint.If any aspects of the complaint are unclear, the complaint handler will seek clarification.
5.7When a complaint is acknowledged at either stage, landlords must be clear which aspects of the complaint they are, and are not, responsible for and clarify any areas where this is not clear.  YesIf there are aspects of the complaint that the council is not responsible for, this will be explained in the acknowledgement. The complaint definition will provide clarity on elements of responsibility to ensure tenants understand any elements that fall outside of landlord's responsibility to enable correct signposting.The council’s new Tenant’s Handbook includes areas that the council is responsible for along with defining what the tenant is responsible for and is available on the website.
5.8

At each stage of the complaints process, complaint handlers must:  

  1. deal with complaints on their merits, act independently, and have an open mind;
  2. give the resident a fair chance to set out their position;
  3. take measures to address any actual or perceived conflict of interest; and
  4. consider all relevant information and evidence carefully.  

 

YesThe council’s Complaints process complies with this requirement ensuring complaints are responded to independently and impartially by staff with comprehensive knowledge of the services provided and the appropriate authority to change decisions or act as required.

The complaints process will always aim to:

  1. deal with complaints on their merits, act independently, and have an open mind
  2. give the resident a fair chance to set out their position
  3. take measures to address any actual or perceived conflict of interest
    and
  4. consider all relevant information and evidence carefully.  
5.9Where a response to a complaint will fall outside the timescales set out in this Code, the landlord must agree with the resident suitable intervals for keeping them informed about their complaint.YesIf a response cannot be provided within the timescales set out in the Code, the service area is responsible for contacting the resident with an explanation of why and to provide a revised timescale for response which will not exceed a further 10 working days. The council will provide the resident with contact details for the Ombudsman Service and explain the right to escalate the complaint. Extensions if needed will be logged on the case management system.
5.10Landlords must make reasonable adjustments for residents where appropriate under the Equality Act 2010. Landlords must keep a record of any reasonable adjustments agreed, as well as a record of any disabilities a resident has disclosed. Any agreed reasonable adjustments must be kept under active review.  Yes

The council is fully committed to treating people fairly and understands its statutory duties under the Equality Act (2010). The equality implications have been considered. The policy has positive implications for several protected groups. It has been written in an inclusive manner to ensure ease of understanding by the widest possible audience.  It has been written in plain English to ensure ease of translation. 

The council want to ensure services are accessible for residents to provide feedback. The council will ensure a variety of access methods are available to customers. The council will monitor and evaluate our processes to ensure that they continue to be accessible to residents. The council will seek to accommodate reasonable adjustments and preferred methods of contact. Where a complaint has equality implications, the equality team will be notified to advise accordingly.

Any complaint including discrimination is passed to the Equality Officer for review.
5.11Landlords must not refuse to escalate a complaint through all stages of the complaints procedure unless it has valid reasons to do so. Landlords must clearly set out these reasons, and they must comply with the provisions set out in section 2 of this Code. YesAll complaints are considered on their own merits, and will be accepted as a complaint, unless they fall within the exclusions set out in the Housing Landlords Customer Complaints Policy section 2.3.The approach is not to refuse to escalate a complaint unless there are valid reasons.
5.12A full record must be kept of the complaint, and the outcomes at each stage. This must include the original complaint and the date received, all correspondence with the resident, correspondence with other parties, and any relevant supporting documentation such as reports or surveys.  YesThe council introduced a new corporate complaints case management system in April 2025 which enables improved monitoring and record keeping of all complaints.

All complaints are logged and status updated on this new system along with all relevant documentation attached to the case file for future reference. A clear audit trail is available for each complaint on the system.

Random checks will be undertaken to ensure that all complaints have a clear audit trail available for evidence purposes.

 

5.13Landlords must have processes in place to ensure a complaint can be remedied at any stage of its complaints process. Landlords must ensure appropriate remedies can be provided at any stage of the complaints process without the need for escalation.  YesThe council has a Remedy Policy which sets out appropriate remedies.Our complaint handling process encourages a focus on complaint resolution from the initial stage and training, and guidance is based on the Housing Ombudsman guidance.
5.14Landlords must have policies and procedures in place for managing unacceptable behaviour from residents and/or their representatives. Landlords must be able to evidence reasons for putting any restrictions in place and must keep restrictions under regular review.YesThe council appreciates that sometimes upset can cause people to act out of character in unacceptable ways. The council aims to deal with feedback, including complaints empathetically. However, sometimes behaviours can cross the line of what is acceptable, and unacceptable behaviour will be managed under the council’s Unacceptable Customer Behaviour Policy.The council’s Unacceptable Customer Behaviour Policy can be found on the council website. The council has a process for managing behaviour that falls to be dealt with under the Unacceptable Behaviour Policy. The process ensures that restrictions are applied only where necessary, are suitably authorised and reasons fully evidenced. The process includes assurance of communication and review where any restrictions are applied.
5.15Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010. YesThe council’s Unacceptable or Unreasonable Communications and Behaviour Policy has been reviewed and approved. The new version of the policy strengthens the proportionate element.The council’s Unacceptable Customer Behaviour Policy can be found on the council website.

 

 

Section 6 - Complaints Stages

Stage 1

 
Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
6.1Landlords must have processes in place to consider which complaints can be responded to as early as possible, and which require further investigation. Landlords must consider factors such as the complexity of the complaint and whether the resident is vulnerable or at risk. Most stage 1 complaints can be resolved promptly, and an explanation, apology or resolution provided to the resident. Yes

The council’s internal complaints resource on the Intranet includes a copy of the following:

  • Policy
  • Forms
  • Remedy guidance
  • Template letters
  • Differences between Service request/complaints

The complaints handling toolkit also includes links to the Housing Ombudsman guidance.

Staff are also able to view the council’s corporate complaints system to allow ease of monitoring and follow up of complaints.

Housing staff have also been undertaking the Housing Ombudsman’s Complaints Handling Code training.
6.2Complaints must be acknowledged, defined and logged at stage 1 of the complaints procedure within five working days of the complaint being received.

Yes

 

Section 4.10 of the Housing Landlords customer complaints policy sets out the council will acknowledge and log complaints within 5 working days of receipt. The council will contact the resident to set out the understanding of the complaint and the outcomes the resident is seeking. The council will advise the resident if there are any aspects of the complaint which they are not responsible for. If any aspect of the complaint is unclear, the resident will be asked for clarification. The Council Policy and Complaint Handling Process is in line with requirements of the Complaint Handling Code timescales.
6.3Landlords must issue a full response to stage 1 complaints within 10 working days of the complaint being acknowledged.YesThe timescales for responding to complaints are set out in the policy. A written response will be provided within 10 working days of the complaint being acknowledged.The Council Policy and Complaint Handling Process is in line with requirements of the Complaint Handling Code timescales.
6.4Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 10 working days without good reason, and the reason(s) must be clearly explained to the resident.  YesIf a response cannot be provided within the timescales set out in the Code, the service area is responsible for contacting the resident with an explanation of why and to provide a revised timescale for response which will not exceed a further 10 working days.Section 4 of the policy outlines that the customer will be notified if an extension is needed and will not exceed a maximum of ten working days.
6.5When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman. YesThe council will provide the resident with contact details for the Housing Ombudsman Service and explain the right to escalate the complaint.Letter templates are used within the process to ensure this information is consistent and included within all responses.
6.6A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.   YesAny outstanding actions following the complaint response will be included in the learning plan along with dates when the outstanding actions will be completed.The Housing service is responsible for maintaining its learning and improvement outcomes; this will be subject to reporting and corporate scrutiny.
6.7Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate. YesThe council’s response will set out the issues investigated, the background to the case, the evidence used in assessing the case, the reasons for the findings or decisions made. If the Council identifies they did something wrong, they will explain what went wrong and why and what will be done to put things right.In 2024/25, Stage 1 remedies included: apologising for delays in repairs, providing clearer explanations of policies where confusion had arisen, expediting outstanding works orders. These responses aimed to resolve issues promptly at the first stage.
6.8Where residents raise additional complaints during the investigation, these must be incorporated into the stage 1 response if they are related and the stage 1 response has not been issued. Where the stage 1 response has been issued, the new issues are unrelated to the issues already being investigated or it would unreasonably delay the response, the new issues must be logged as a new complaint. YesSection 4.10.3 of the Housing Landlord Services Customer Complaints Policy sets out the process that is followed ‘If further related matters are raised about the complaint while it is still being investigated, these will be incorporated and responded to unless it unreasonably delays the response’.The Council Policy and Complaint Handling Process is in line with requirements of this Complaint Handling Code requirement.
6.9

Landlords must confirm the following in writing to the resident at the completion of stage 1 in clear, plain language:  

  1. the complaint stage;
  2. the complaint definition;
  3. the decision on the complaint;
  4. the reasons for any decisions made;
  5. the details of any remedy offered to put things right;
  6. details of any outstanding actions; and
  7. details of how to escalate the matter to stage 2 if the individual is not satisfied with the response. 
YesThe council’s response will set out the issues investigated, the background to the case, the evidence used in assessing the case, the reasons for the findings or decisions made. If the council identifies they did something wrong, they will explain what went wrong and why and what will be done to put things right. The council has corporate letter templates in place for each stage to ensure all relevant information is included in the responses.

 

Stage 2

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
6.10If all or part of the complaint is not resolved to the resident’s satisfaction at stage 1, it must be progressed to stage 2 of the landlord’s procedure. Stage 2 is the landlord’s final response.YesIf the resident remains dissatisfied with the response they can ask for the complaint to be looked at again; this should be done immediately or as soon as reasonably practical. Any new matters raised after the response has been issued will be treated as a new complaint and reviewed by a different member of staff. The aim is for complaints to be resolved as early as possible but if this is not the case the two-stage process is in place to review these cases.
6.11Requests for stage 2 must be acknowledged, defined and logged at stage 2 of the complaints procedure within five working days of the escalation request being received. YesWithin 5 working days of receiving the request the council will acknowledge and log the complaint. The council will contact the resident to set out the understanding of the complaint and the outcomes the resident is seeking. The Council will advise the resident if there are any aspects of the complaint which they are not responsible for. If any aspect of the complaint is unclear, the resident will be asked for clarification. 

The Council Policy and Complaint Handling Process is in line with requirements of the Complaint Handling Code timescales.

 

6.12Residents must not be required to explain their reasons for requesting a stage 2 consideration. Landlords are expected to make reasonable efforts to understand why a resident remains unhappy as part of its stage 2 response.YesThe council complies with this, and all complaints are processed at stage 2 when requested by the resident.If a customer isn't satisfied with the response they receive at stage one, they have a right to escalate their complaint to the second stage in our process.
6.13The person considering the complaint at stage 2 must not be the same person that considered the complaint at stage 1. YesStage two complaints will not be investigated by the same officer as the stage one complaint.4.11.1 of the policy states that the complaint will be investigated by a different officer.
6.14Landlords must issue a final response to the stage 2 within 20 working days of the complaint being acknowledged.  Yes

A written response will be provided within 20 working days of the complaint being acknowledged.

 

The Council Policy and Complaint Handling Process is in line with requirements of the Complaint Handling Code timescales.
6.15Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 20 working days without good reason, and the reason(s) must be clearly explained to the resident.  YesIf a response cannot be provided within 20 working days, the council will contact the resident with an explanation of why and provide a revised timescale for response which will not exceed a further 20 working days. Section 4 of the policy outlines that the customer will be notified if an extension is needed and will not exceed a maximum of ten working days
6.16When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman. Yes

The council will provide the resident with contact details for the Ombudsman Service and explain the right to escalate the complaint. 

 

Letter templates are used within the process to ensure this information is consistent and included within all responses.

 

6.17A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.  Yes

A response will be provided to the resident when the answer is known and not when outstanding actions are completed. If there are outstanding actions, the resident will be provided with arrangements for updates on these outstanding actions. The resident will be provided with details of how to escalate the complaint should they not be satisfied with the response and you will be provided with the Housing Ombudsman’s contact details.

 

The Housing service is responsible for maintaining its learning and improvement outcomes; this will be subject to reporting and corporate scrutiny.

 

6.18Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.YesThe council’s response will set out the issues investigated, the background to the case, the evidence used in assessing the case, the reasons for the findings or decisions made. If the council identifies they did something wrong, they will explain what went wrong and why and what will be done to put things right.In 2024/25, Stage 2 remedies included: offering financial redress where service failures were identified and revisiting earlier decisions where evidence had been overlooked. These actions ensured final responses addressed the full scope of the complaint and provided closure.
6.19

Landlords must confirm the following in writing to the resident at the completion of stage 2 in clear, plain language:  

  1. the complaint stage;
  2. the complaint definition;
  3. the decision on the complaint;
  4. the reasons for any decisions made;
  5. the details of any remedy offered to put things right;
  6. details of any outstanding actions; and
  7. details of how to escalate the matter to the Ombudsman Service if the individual remains dissatisfied. 
YesThe council’s response will set out the issues investigated, the background to the case, the evidence used in assessing the case, the reasons for the findings or decisions made. If the council identifies they did something wrong, they will explain what went wrong and why and what will be done to put things right. The council has letter templates for each stage to ensure all relevant information is included in the responses.
6.20Stage 2 is the landlord’s final response and must involve all suitable staff members needed to issue such a response.YesThe Housing Landlord Services Customer Complaints Policy states that the stage 2 response, once provided to the resident, will conclude the council’s complaint procedure and be the final response to the complaint. If the resident remains dissatisfied with the response they have received, they can raise the matter with the Housing Ombudsman Service; this should be done immediately or as soon as reasonably practical. 

Section 7: Putting things right

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
7.1

Where something has gone wrong a landlord must acknowledge this and set out the actions it has already taken, or intends to take, to put things right. These can include: 

  • Apologising;
  • Acknowledging where things have gone wrong;
  • Providing an explanation, assistance or reasons;
  • Taking action if there has been delay;
  • Reconsidering or changing a decision;
  • Amending a record or adding a correction or addendum;
  • Providing a financial remedy;
  • Changing policies, procedures or practices. 
YesThe council’s Remedies Policy supports this stage and focuses on putting things right when things have gone wrong.

If something does go wrong, the council will:

  • acknowledge
  • apologise
  • put things right

If our customer has experienced injustice or hardship, then a remedy will be considered including financial if applicable.

7.2Any remedy offered must reflect the impact on the resident as a result of any fault identified.  YesThe council’s Remedies Policy supports this stage. 
7.3The remedy offer must clearly set out what will happen and by when, in agreement with the resident where appropriate. Any remedy proposed must be followed through to completion.YesThe council’s Remedies Policy supports this stage. 
7.4Landlords must take account of the guidance issued by the Ombudsman when deciding on appropriate remedies.  YesThe council’s Remedies Policy supports this stage, with links to the Housing Ombudsman’s guidance on remedies also included on the staff Intranet to support staff in complaint remedies or responses. 

 

Section 8 - Self-assessment, reporting and compliance

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
8.1

Landlords must produce an annual complaints performance and service improvement report for scrutiny and challenge, which must include: 

  1. the annual self-assessment against this Code to ensure their complaint handling policy remains in line with its requirements.
  2. a qualitative and quantitative analysis of the landlord’s complaint handling performance. This must also include a summary of the types of complaints the landlord has refused to accept;
  3. any findings of non-compliance with this Code by the Ombudsman;
  4. the service improvements made as a result of the learning from complaints;
  5. any annual report about the landlord’s performance from the Ombudsman; and
  6. any other relevant reports or publications produced by the Ombudsman in relation to the work of the landlord.  
Yes

The 2024/25 annual complaints performance and service improvement report is due to be presented at the council’s Audit and Governance Committee on 29 September 2025. 

The report meets the requirements set out in the Complaint Handling Code.

Following the Audit and Governance committee meeting on 29 September 2025, a copy of the report and governing body’s response will be published on the complaints section of the website.
8.2The annual complaints performance and service improvement report must be reported to the landlord’s governing body (or equivalent) and published on the on the section of its website relating to complaints. The governing body’s response to the report must be published alongside this.Yes

The 2023/24 annual complaints performance and service improvement report was presented at the council’s Executive Committee in September 2024 and is available on the council’s website.

The 2024/25 annual complaints performance and service improvement report is due to be presented at the council’s Audit and Governance Committee on 29 September 2025. 

Following the Audit and Governance committee meeting on 29 September 2025, a copy of the report and governing body’s response will be published on the complaints section of the website.
8.3Landlords must also carry out a self-assessment following a significant restructure, merger and/or change in procedures.YesThe council will comply with this if required and has completed the self-assessment following the introduction of the new policy for Housing Landlord Services.The latest self-assessment has been undertaken in August 2025.
8.4Landlords may be asked to review and update the self-assessment following an Ombudsman investigation.YesThe council will comply with this if required. 
8.5If a landlord is unable to comply with the Code due to exceptional circumstances, such as a cyber incident, they must inform the Ombudsman, provide information to residents who may be affected, and publish this on their website Landlords must provide a timescale for returning to compliance with the Code.YesThe council will comply with this if required. 

 

 

 

Section 9 - Scrutiny and oversight: continuous learning and improvement  

Code provisionCode requirementComply: Yes / NoEvidenceCommentary / explanation
9.1Landlords must look beyond the circumstances of the individual complaint and consider whether service improvements can be made as a result of any learning from the complaint.  YesLearning plans are produced along with complaint responses. Each service area is responsible for maintaining its learning and improvement outcomes; this will be subject to reporting and corporate scrutiny.Further work to be undertaken on learning from complaints and analysing the information to provide data insight which can link in with and identify service improvement projects. This will be part of the remit of the new Service Improvement Team.
9.2A positive complaint handling culture is integral to the effectiveness with which landlords resolve disputes. Landlords must use complaints as a source of intelligence to identify issues and introduce positive changes in service delivery.  YesThe new policy supports this, and a positive Complaint Handling culture is being developed with additional training, guidance and information being rolled out along with the introduction of the new case management system in April 2025.The way complaints are handled within the service area is currently being reviewed. This will ensure there is more work on learning from complaints and linking in with service improvement.
9.3Accountability and transparency are also integral to a positive complaint handling culture. Landlords must report back on wider learning and improvements from complaints to stakeholders, such as residents’ panels, staff and relevant committees.Yes

The Corporate Performance team report on complaints to Executive on a regular basis. Power BI dashboard is currently being enhanced to help provide real-time information on housing complaints which can be shared with key stakeholders on a regular basis.

Learning from complaints will also be reported to the Tenant Advisory Panel and summarised through tenant newsletters and the annual report to tenants. This will ensure transparency and demonstrate how tenant feedback directly informs and drives service improvements.

The way complaints are handled within the service area is currently being reviewed. This will ensure there is more work on learning from complaints and linking in with service improvement.
9.4Landlords must appoint a suitably senior lead person as accountable for their complaint handling. This person must assess any themes or trends to identify potential systemic issues, serious risks, or policies and procedures that require revision.  YesConfirmed as Simon Mills, Assistant Director Customer Experience.The Assistant Director Customer Experience is part of the Corporate Leadership Network and oversees the complaint handling process for the council.
9.5In addition to this a member of the governing body (or equivalent) must be appointed to have lead responsibility for complaints to support a positive complaint handling culture. This person is referred to as the Member Responsible for Complaints (‘the MRC’).YesThe Member Responsible for Complaints is Councillor Graham Cheatley, Executive Member for Finance, Efficiency and Change.Corporately Complaint Handling is part of Customer Services Directorate which sits within an Executive Member’s portfolio.
9.6The MRC will be responsible for ensuring the governing body receives regular information on complaints that provides insight on the landlord’s complaint handling performance. This person must have access to suitable information and staff to perform this role and report on their findings.Yes

Complaint information is regularly presented as part of the performance report to Executive. 

 

The Tenant Satisfaction Measures on complaint handling are also presented to the Housing Improvement and Assurance Board as part of the monthly performance dashboard.
9.7

As a minimum, the MRC and the governing body (or equivalent) must receive: 

  1. regular updates on the volume, categories and outcomes of complaints, alongside complaint handling performance;
  2. regular reviews of issues and trends arising from complaint handling;   
  3. regular updates on the outcomes of the Ombudsman’s investigations and progress made in complying with orders related to severe maladministration findings; and   
  4. annual complaints performance and service improvement report. 
YesThe Corporate Performance Team provide regular complaints performance to Executive.The Tenant Satisfaction Measures on complaint handling are also presented to the Housing Improvement and Assurance Board as part of the monthly performance dashboard.
9.8

Landlords must have a standard objective in relation to complaint handling for all relevant employees or third parties that reflects the need to: 

  1. have a collaborative and co-operative approach towards resolving complaints, working with colleagues across teams and departments;
  2. take collective responsibility for any shortfalls identified through complaints, rather than blaming others; and
  3. act within the professional standards for engaging with complaints as set by any relevant professional body. 
Yes

The council has a complaints page on the Intranet which includes a copy of the following:

  • Policy
  • Forms
  • Remedy guidance
  • Template letters
  • Differences between Service request and complaints
Training has been undertaken with staff to support the introduction of the new case management with the aim to enhance the customer experience, automate complaints processes, boost efficiency, and effectively address complaints for organisational learning and improvement.

Last updated 10 October 2025