Complaint handling code self-assessment

How a complaint is defined

Compliance status and additional notes for Section 1 criteria of the Housing Ombudsman's Complaint Handling Code
Code section	Code requirement (from the Housing Ombudsman Complaint Handling Code)	Comply (Yes/No)	Evidence, 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	The policy was updated on 1 March 2024 to be compliant with the Housing Ombudsman's Complaint Handling Code 2024. The prior policy included the same wording. Corporate Complaints and Compliments Policy (page 9 Complaints Policy for Housing Assets Service). A complaint is defined as the concern or dissatisfaction of a customer regarding the service, action or lack of action taken by the Council.
1.3	A 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	The policy includes clear reference to accepting complaints from third parties that are authorised to act on the customer's behalf. Responses to these complaints will be issued directly to the authorised party. Anonymous complaints will not be accepted.
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	Detailed in the policy (page 9 'Definitons'). The Policy was updated on 1 March 2024 to be compliant with the Housing Ombudsman's Complaint Handling Code 2024. The prior policy included the same wording.
1.5	A 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	Detailed in the policy (page 9 'Definitons'). The Policy was updated on 1 March 2024 to be compliant with the Housing Ombudsman's Complaint Handling Code 2024. The prior policy included the same wording.
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	We will ensure that surveys make it clear that tenants can make a complaint separately. Insight surveys where carried out are reviewed monthly and respondents contacted where feedback is negative or where dissatisfaction/comments made.

Accessibility and awareness

Compliance status and additional notes for Section 3 criteria of the Housing Ombudsman's Complaint Handling Code
Code section	Code requirement	Comply (Yes/No)	Evidence, commentary and any explanations
3.1	Landlords 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	Page 3 of the complaints policy provides information on how complaints are made. Page 10 of the complaints policy confirms that third party complaints can be accepted. The Council's website contains an explanation of the policy and provides the option to request the policy in an alternative accessible format: Corporate complaints and compliments policy - Great Yarmouth Borough Council documentation (great-yarmouth.gov.uk) Additional information is also provided on how tenants can make a complaint on the Your Tenancy section of the website How you can make a complaint - Great Yarmouth Borough Council (great-yarmouth.gov.uk) Complaints to the Council can be made in the following ways: email online in person letter phone through the tenant's MP and councillor using an agreed third party advocate solicitor Citizens Advice Bureau any other reasonable request The Policy was updated on 1 March 2024 to be compliant with the Housing Ombudsman's Complaint Handling Code 2024. The prior policy included the same wording.
3.2	Residents 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	Information on how to make a complaint is available on the Council's website along with a complaints form (which is one available option of how to make a complaint): How do I give my comments, compliments and complaints? - Great Yarmouth Borough Council (great-yarmouth.gov.uk) All Housing Assets Service staff were notified of the updated Corporate Complaints and Compliments Policy, how a resident can make a complaint, including in person via staff.
3.3	High 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	The Council recognises this point.
3.4	Landlords 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	Our website includes information on how make comments, complaints and compliments. An annual article in the tenant newsletter promoting complaints with information on the Housing Ombudsman is published. Website has been updated to reflect the updated policy. The website has been updated to reflect the updated policy.
3.5	The policy must explain how the landlord will publicise details of the complaints policy, including information about the Ombudsman and this Code.	Yes	Annual article in the tenant newsletter promoting complaints with information on the Housing Ombudsman. The Council website has information on the complaints policy and role of the Housing Ombudsman. The Council publishes a copy of the self assessment against the code.
3.6	Landlords 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.	Yes	See page 10 of the complaints policy: different ways to make a complaint as example third party. The Policy was updated on 1 March 2024 to be compliant with the Housing Ombudsman's Complaint Handling Code 2024. The prior policy included the same wording.
3.7	Landlords 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 Council's website provides information on the right to access the Housing Ombudsman's Service and how to contact the Ombudsman. In complaint acknowledgements and responses, the Council states it is compliant with the Housing Ombudsman's Complaint Handling Code and provides contact details for the Housing Ombudsman's Service.

Complaint handling staff

Compliance status and additional notes for Section 4 criteria of the Housing Ombudsman's Complaint Handling Code
Code section	Code requirement	Comply (Yes/No)	Evidence, 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 Corporate Services Team log all complaints and act as the main liaison with the Housing Ombudsman Service. There is no dedicated complaints team or complaints officer within the Housing Assets Service. However, there are a number of staff within the Housing Assets Service and Repairs Service who are responsible for complaint handling. The Head of Housing Assets is responsible for reporting complaints to the Council's Cabinet.
4.2	The 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	Complaint Investigating Officers have the authority and autonomy to resolve disputes. Compensation requests are approved by the Council's Section 151 Officer.
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.	Yes	Complaint training is held for all staff undertaking complaint investigation.

Complaint handling process

Compliance status and additional notes for Section 5 criteria of the Housing Ombudsman's Complaint Handling Code
Code section	Code requirement	Comply (Yes/No)	Evidence, commentary and any explanations
5.1	Landlords must have a single policy in place for dealing with complaints covered by this Code. Residents must not be treated differently if they complain.	Yes	Appendix 1 relates to the Housing Assets Service - an appendix has been used to allow the Council to update the policy to comply with the 2024 Complaints Handling Code as there was no time to complete a wider review of the Complaints Policy - this wider refresh of the policy will take place in 2024 aligning all complaints across the Council to reflect the Two Stage process in place for the Council's landlord service. Residents who complain are not treated differently.
5.2	The 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.	Yes	The policy has two complaint stages. There is no informal complaint process.
5.3	A 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.	Yes	From 18 March 2024, a two stage complaint process was introduced for the Council's landlord services. Prior to this the three stage process in place across other council services applied to the landlord service.
5.4	Where 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.	Yes	The Councils Joint Venture, Great Yarmouth Norse will undertake complaint handling at stage 1 and where escalated, the stage 2 complaint will be considered by the Council.
5.5	Landlords are responsible for ensuring that any third parties handle complaints in line with the Code.	Yes	The policy has been shared with GYN, training of the complaints lead has been completed with training of all managers due to be completed in 2024. This will ensure complaints handling and investigations comply with the Council's policy and the Complaint Handling Code.
5.6	When 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.	Yes	See page 10 of the complaints policy: section on 'Complaints' and page 11 section on 'Complaint Investigation'. This requirement was included in the training and template for acknowledging complaints.
5.7	When 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.	Yes	See page 10 of the complaints policy: section on 'Complaints' and page 11 section on 'Complaint Investigation'. This requirement was included in the training and template for acknowledging complaints.
5.8	At each stage of the complaints process, complaint handlers must: a. deal with complaints on their merits, act independently, and have an open mind; b. give the resident a fair chance to set out their position; c.take measures to address any actual or perceived conflict of interest; and d. consider all relevant information and evidence carefully.	Yes	See page 11 of the complaints policy: section on 'Complaint Investigation' Requirements included in training.
5.9	Where 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.	Yes	See page 11 of the complaints policy: section on 'Complaint Responses'. Requirement included in training.
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	Requirement included in training. Case management process captures these requirements (disability and agreed reasonable adjustments).
5.11	Landlords 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.	Yes	Complaint process outlined in policy. The policy states that escalation to Stage 2 will not be accepted more than six months after the Stage 1 complaint response.
5.12	A 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.	Yes	Internal case management process includes this. Relevant supporting documentation, reports or surveys will be held on property files not as part of complaint management.
5.13	Landlords 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	Part of complaint handling training.
5.14	Landlords 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.	Yes	The Council has a specific policy for dealing with abusive, persistent or vexatious complaints and complainants policy.
5.15	Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010.	Yes	See above.

Complaint stages

Compliance status and additional notes for Section 6 criteria of the Housing Ombudsman's Complaint Handling Code: Stage 1 complaints
Code section	Code requirement	Comply (Yes/No)	Evidence, commentary and any explanations
6.1	Landlords 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	Complaints are dealt with in a timely way with further investigation taken when required to ensure responses can be provided at the earliest opportunity.
6.2	Complaints must be acknowledged, defined and logged at stage 1 of the complaints procedure within five working days of the complaint being received.	Yes	See page 10 of the complaints policy: section on 'Complaint Stages'. The Policy was updated on 1 March 2024 to be compliant with the Housing Ombudsman's Complaint Handling Code 2024. The prior policy stated that complaints would be acknowledged within 5 working days of being received into the complaints@great-yarmouth.gov.uk email box.
6.3	Landlords must issue a full response to stage 1 complaints within 10 working days of the complaint being acknowledged.	Yes	See page 10 of the complaints policy: section on 'Complaint Stages'. The Policy was updated on 1 March 2024 to be compliant with the Housing Ombudsman's Complaint Handling Code 2024. The prior policy stated that complaints would be responded to within 10 days. Requirement also included in complaint handling training.
6.4	Landlords 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.	Yes	See page 11 of the complaints policy: section on 'Complaint Responses'. Included in complaint handling training.
6.5	When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.	Yes	See page 11 of the complaints policy: section on 'Complaint Responses'. Included in complaint handling training and in template wording to advise of the need for an extension.
6.6	A 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	Included in complaint handling training.
6.7	Landlords 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.		Included in complaint handling training.
6.8	Where 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.		See page 11 of the complaints policy: section on 'Complaint Responses'.
6.9	Landlords must confirm the following in writing to the resident at the completion of stage one in clear, plain language: the complaint stage the complaint definition the decision on the complaint the reasons for any decisions made the details of any remedy offered to put things right details of any outstanding actions details of how to escalate the matter to stage two if the resident is not satisfied with the answer		Requirements included in complaint handling training and template for complaint response.

Compliance status and additional notes for Section 6 criteria of the Housing Ombudsman's Complaint Handling Code: Stage 2 complaints
Code section	Code requirement	Comply (Yes/No)	Evidence, commentary and any explanations
6.10	If all or part of the complaint is not resolved to the resident's satisfaction at stage one it must be progressed to stage two of the landlord's procedure. Stage 2 is the landlord's final response.	Yes	Complaint response clearly states how to escalate the complaint to Stage two if the complaint has not been resolved to the resident's satisfaction.
6.11	Requests 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.	Yes	See page 10 of the complaints policy: section on 'Complaint Stages'.
6.12	Residents 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.	Yes	Residents are not required to explain the reason for their escalation.
6.13	The person considering the complaint at stage two, must not be the same person that considered the complaint at stage one.	Yes	See page 10 of the complaints policy: Section 'Complaint Stages'
6.14	Landlords must issue a final response to the stage 2 within 20 working days of the complaint being acknowledged.	Yes	See page 10 of the complaints policy: section on 'Complaint Stages'. Requirement also included in complaint handling training.
6.15	Landlords 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	See page 11 of the complaints policy: section on 'Complaint Responses'. Included in complaint handling training.
6.16	When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.	Yes	See page 11 of the complaints policy: section on 'Complaint Responses'. Included in complaint handling training and in template wording to advise of the need for an extension.
6.17	A 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	See page 11 of the complaints policy: section on 'Complaint Responses'. Included in complaint handling training.
6.18	Landlords 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.	Yes	See page 11 of the complaints policy: section on 'Complaint Investigation'. Included in complaint handling training.
6.19	Landlords must confirm the following in writing to the resident at the completion of stage two in clear, plain language: the complaint stage the complaint definition the decision on the complaint the reasons for any decisions made the details of any remedy offered to put things right details of any outstanding actions details of how to escalate the matter to the Ombudsman Service if the resident remains dissatisfied	Yes	Requirements are included within template for response.
6.20	Stage two is the landlord's final response and must involve all suitable staff members needed to issue such a response.	Yes	See page 10 of the complaints policy: section on 'Complaint Stages'. Investigating officers seek additional information from other officers to allow them to complete their investigation. Compensation payments are required to be approved by the Council Section 151 Officer. From 18 March 2024 the complaints policy for the Housing Assets Service has only two stages. Prior to this it had three stages.

Continuous learning and improvement

Compliance status and additional notes for Section 9 criteria of the Housing Ombudsman's Complaint Handling Code
Code section	Code requirement	Comply (Yes/No)	Evidence, commentary and any explanations
9.1	Landlords 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	Included within complaint handling training. Internal complaint monitoring processes will record learning and improvement from complaints.
9.2	A 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	Complaints are recognised as a valuable source of feedback on service delivery and are used to improve service delivery.
9.3	Accountability 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	To be implemented from 1 July 2024 to allow this Self-Assessment and the Annual Complaints Performance and Service Improvement Report to be shared with staff, Cabinet and tenants through the Tenant Engagement Panel which is being established in 2024/25. The formal report (see 8.1 above) will be considered by Cabinet and shared with staff via team meetings. On an ongoing basis information on complaints and learning will be shared on a quarterly basis reflecting the format of the Annual Complaints Performance and Service Improvement Report.
9.4	Landlords 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.	Yes	The Head of Housing Assets will be responsible for assessing trends from complaints.
9.5	In 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').	Yes	The Council's MRC is the Portfolio holder for Operational Property and Assets.
9.6	The 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	To be implemented from 1 July 2024. The MRC and Cabinet will have quarterly information on complaints including complaint performance, outcome and reasons for complaints. The MRC will have access to all relevant staff to perform their role.
9.7	As a minimum, the MRC and the governing body (or equivalent) must receive: regular updates on the volume, categories and outcomes of complaints, alongside complaint handling performance; regular reviews of issues and trends arising from complaint handling; regular updates on the outcomes of the Ombudsman's investigations and progress made in complying with orders related to severe maladministration findings; and annual complaints performance and service improvement report.	Yes	To be implemented from 1 July 2024 (see 9.3 above).
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: have a collaborative and co-operative approach towards resolving complaints, working with colleagues across teams and departments; take collective responsibility for any shortfalls identified through complaints, rather than blaming others; and act within the professional standards for engaging with complaints as set by any relevant professional body.	Yes	Being implemented through 2024/25 Personal Development Review process for all relevant staff.

Self-assessment and compliance

Compliance status and additional notes for Section 8 criteria of the Housing Ombudsman's Complaint Handling Code
Code section	Code requirement	Comply (Yes/No)	Evidence, commentary and any explanations
8.1	Landlords must produce an annual complaints performance and service improvement report for scrutiny and challenge, which must include: the annual self-assessment against this Code to ensure their complaint handling policy remains in line with its requirements. 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; any findings of non-compliance with this Code by the Ombudsman; the service improvements made as a result of the learning from complaints; any annual report about the landlord's performance from the Ombudsman; and any other relevant reports or publications produced by the Ombudsman in relation to the work of the landlord.	Yes	See page 12 of the complaints policy: section on 'Implementation and Compliance'. The Annual Complaints Performance and Service Improvement Report has been produced. This Self Assessment is a separate document. A link to the Self-Assessment is provided in the report. The report meets the requirements of 8.1.
8.2	The annual complaints performance and service improvement report must be reported to the landlord's governing body (or equivalent) and published 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 and this Self-Assessment have been completed and shared with the Council's Member Responsible for Complaints (MRC). The report will be considered by the Council's next available Cabinet meeting on 17 July 2024. Following this meeting, the Cabinet's response will be published alongside the report.
8.3	Landlords must also carry out a self-assessment following a significant restructure, merger and/or change in procedures.	Yes	Requirement is noted.
8.4	Landlords may be asked to review and update the self-assessment following an Ombudsman investigation.	Yes	The Council will review the policy upon any investigation outcome.
8.5	If 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.	Yes	The Council will inform the Ombudsman should this issue arise.

Putting things right

Compliance status and additional notes for Section 7 criteria of the Housing Ombudsman's Complaint Handling Code
Code section	Code requirement	Comply (Yes/No)	Evidence, 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.	Yes	Details of appropriate remedies are included within the complaint handling training.
7.2	Any remedy offered must reflect the impact on the resident as a result of any fault identified.	Yes	Included within complaint handling training. All remedies offered are based on each individual case and the impact of any resolution is considered from a wider perspective and included within any learning from complaints.
7.3	The 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.	Yes	Included within complaint handling training.
7.4	Landlords must take account of the guidance issued by the Ombudsman when deciding on appropriate remedies.	Yes	Included within complaint handling training.