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Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
Access To Complaints Procedures Report
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Access To Complaints Procedures Report

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Research conducted by Michael Hill (as part of CPA) looking at the effectiveness of housing association complaint procedures

Research conducted by Michael Hill (as part of CPA) looking at the effectiveness of housing association complaint procedures

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  • 1. ACCESS TO COMPLAINTS PROCEDURES BY TENANTS OF RSLs REPORT OF A STUDY FOR THE INDEPENDENT HOUSING OMBUDSMAN LTD AND THE HOUSING CORPORATION Caroline Pickering Associates March 2002
  • 2. Access to Complaints Procedures for RSL residents Caroline Pickering Associates CONTENTS 1 INTRODUCTION ............................................................................................................................ 4 COMMISSIONING AND BRIEF ..................................................................................................................... 4 METHODS................................................................................................................................................. 4 COPYRIGHT ............................................................................................................................................ 4 2 EXECUTIVE SUMMARY AND RECOMMENDATIONS – ...................................................... 5 HEADLINES .............................................................................................................................................. 5 OVERALL RECOMMENDATIONS ................................................................................................................. 5 SPECIFIC RECOMMENDATIONS ................................................................................................................. 6 SUMMARY OF FINDINGS ........................................................................................................................... 6 Complaints are good for residents and RSLs - the review of literature and research. ..................................... 6 Tenants’ and RSLs’ experience - the first survey of residents and RSLs. ....................................................... 7 How to achieve the change - the Best Practice Guidance................................................................................ 8 Eight ‘golden rules’ for RSLs’ complaints management..................................................................... 8 3 OUR FINDINGS IN DETAIL ....................................................................................................... 10 THE WIDER CONTEXT ............................................................................................................................ 10 What is good practice in complaint management? – The Literature Review.................................... 10 Overview....................................................................................................................................................... 10 Introduction................................................................................................................................................... 10 The benefits of effective complaint management.......................................................................................... 11 Common Features ......................................................................................................................................... 11 Quality Assurance ......................................................................................................................................... 12 Definition of a complaint .............................................................................................................................. 12 Access ........................................................................................................................................................... 14 Simplicity...................................................................................................................................................... 15 Speed............................................................................................................................................................. 16 Fairness ......................................................................................................................................................... 16 Confidentiality............................................................................................................................................... 18 An effective response .................................................................................................................................... 19 Management Information .............................................................................................................................. 19 Training......................................................................................................................................................... 20 CURRENT EXPERIENCE........................................................................................................................... 22 The first questionnaires to residents and RSLs. ................................................................................ 22 Our key findings:........................................................................................................................................... 22 How satisfied are residents with complaint handling? What processes do RSLs use to deal with resident dissatisfaction?.................................................................................................................... 23 Complaint procedures.................................................................................................................................... 23 Training and guidance ................................................................................................................................... 26 Time limits for responding and acknowledging complaints.......................................................................... 27 Complaint outcomes...................................................................................................................................... 27 Customer satisfaction with complaint handling............................................................................................. 28 Action taken to resolve a complaint .............................................................................................................. 30 Access and publicity...................................................................................................................................... 32 Reporting....................................................................................................................................................... 34 What do residents want?................................................................................................................................ 35 What are RSLs doing to improve complaint handling?................................................................................. 37 SETTING THE STANDARD – THE DISCUSSION GROUPS........................................................................... 39 Our key findings................................................................................................................................ 39 What are the existing requirements for landlord complaint procedures?....................................................... 40 The Discussion Groups ..................................................................................................................... 40 1 What do residents want from a complaints procedure? ....................................................................... 40 Why do people complain? …and why don’t they complain? ........................................................................ 40 Accessing a complaint procedure .................................................................................................................. 40 Customer care................................................................................................................................................ 41 Housing co-operatives................................................................................................................................... 42 Customer expectations and responses to complaints ..................................................................................... 42 Publicising a complaint procedure ................................................................................................................ 43 Complaint leaflets ......................................................................................................................................... 44 Copyright © CPA 2002 page 2
  • 3. Access to Complaints Procedures for RSL residents Caroline Pickering Associates What makes a successful complaint procedure?............................................................................................ 44 Stages of complaint ....................................................................................................................................... 45 Panel hearings ............................................................................................................................................... 45 A model complaint procedure ....................................................................................................................... 46 Some other comments ................................................................................................................................... 47 Conclusion – Residents groups ..................................................................................................................... 47 2 What do RSLs want from a complaint procedure? .............................................................................. 48 Organisational culture ................................................................................................................................... 48 Who can complain?....................................................................................................................................... 49 What is a complaint? ..................................................................................................................................... 49 Recording all complaints............................................................................................................................... 49 On-the-spot resolutions – informal vs. formal complaints ............................................................................ 50 Management Information .............................................................................................................................. 50 Recognising employees ................................................................................................................................. 50 Audit ............................................................................................................................................................. 51 Responding to complaints ............................................................................................................................. 51 Compensation................................................................................................................................................ 51 Customer satisfaction .................................................................................................................................... 52 Publishing information about changes made following investigation of complaints..................................... 52 Central contact point for complaints ............................................................................................................. 52 Helping customers to complain ..................................................................................................................... 52 Publicising the procedure .............................................................................................................................. 53 Training......................................................................................................................................................... 53 A model complaint procedure ....................................................................................................................... 53 Panel or committee stage............................................................................................................................... 54 Conclusion – RSLs groups ............................................................................................................................ 54 THE DRAFT BEST PRACTICE GUIDELINES ............................................................................................... 56 Residents’ assessments of the draft Guidelines................................................................................. 63 Overall perceptions ....................................................................................................................................... 63 Positive comments included:......................................................................................................................... 63 3-stage procedure .......................................................................................................................................... 64 8-week time limit .......................................................................................................................................... 64 Investigation of complaints at the final stage ................................................................................................ 64 Choice of complaining in person to a panel .................................................................................................. 64 Suggestions for improving the management and handling of complaints ..................................................... 65 RSLs’ assessments of the draft Guidelines........................................................................................ 66 Overall perceptions ....................................................................................................................................... 66 Criticisms of the guidelines........................................................................................................................... 66 3-stage procedure .......................................................................................................................................... 67 8-week time limit .......................................................................................................................................... 68 Investigation of complaints at the final stage ................................................................................................ 68 Choice of complaining in person to a panel .................................................................................................. 68 Suggestions for improving the management and handling of complaints ..................................................... 69 Representative bodies’ views ........................................................................................................................ 69 4 APPENDICES ................................................................................................................................ 70 APPENDIX A: REFERENCES ................................................................................................................... 70 Local Authority complaint procedures and policies ......................................................................... 71 RSL complaint procedures and policies............................................................................................ 71 Private Sector Complaint procedures and policies........................................................................... 72 APPENDIX B: PROFILE OF RESPONDENTS ............................................................................................... 73 RSLs:................................................................................................................................................. 73 Residents:.......................................................................................................................................... 73 Gender .............................................................................................................................................. 74 Disability........................................................................................................................................... 74 Age .................................................................................................................................................... 74 APPENDIX C: RESIDENTS’ REASONS FOR DISSATISFACTION WITH COMPLAINTS HANDLING ................... 75 APPENDIX D: RESIDENTS’ EXPECTATIONS WHEN MAKING A COMPLAINT .............................................. 76 APPENDIX E: RESIDENTS’ DISLIKES AND LIKES OF COMPLAINTS HANDLING .......................................... 77 APPENDIX F: RSLS INVOLVED IN THE PROJECT...................................................................................... 78 APPENDIX G: CONSULTATION QUESTIONNAIRES ................................................................................... 86 GLOSSARY OF TERMS...................................................................................................................... 101 Copyright © CPA 2002 page 3
  • 4. Access to Complaints Procedures for RSL residents Introduction 1 INTRODUCTION COMMISSIONING AND BRIEF Caroline Pickering Associates were commissioned in 2001 by the Independent Housing Ombudsman Ltd and the Housing Corporation to undertake a study (as the first part of a two-part project) with the aim of : Ø establishing what is current good practice in complaints management in the public and private sectors Ø assessing the extent to which current practice in RSL complaints management – as reported by tenants who have complained and by RSLs themselves – demonstrates best practice Ø creating a set of criteria for best practice Ø recommending how any gap between current practice in the RSL sector and best practice can be addressed METHODS To answer the questions posed by the brief we carried out the following (reported in full under “Findings in Detail”): Ø A review of current literature and research about complaints management in the public and private sectors, especially amongst Registered Social Landlords (RSLs) and their residents. Ø A questionnaire survey of RSL Chief Executives (or their nominated representative) and complainants. More than 200 questionnaires were distributed to RSLs, who distributed more than 600 questionnaires to their resident complainants. Ø Discussion groups involving more than 30 participants including both resident complainants and employees with responsibility for complaint procedures. Ø A survey of resident complainants, RSL employees and representative groups on our “Best Practice Guidance for Complaint Procedures”. Copyright This report is copyright to Caroline Pickering Associates. Extracts may be used without specific permission so long as they give a true account of the Report’s findings, are verbatim, and acknowledge their source . Copyright © CPA 2002 page 4
  • 5. Access to Complaints Procedures for RSL tenants Executive Summary and Recommendations – A Mandate for Change 2 EXECUTIVE SUMMARY AND RECOMMENDATIONS – A MANDATE FOR CHANGE “It is expected that the improvements in their handling of complaints will lead to a growing number of complaints being satisfactorily resolved by housing associations.” (Housing Corporation, 1993) HEADLINES 1 RSLs’ complaints procedures – with a few honourable exceptions – fall well below the standard of other sectors in the public and private sectors, and consistently fail to meet good practice 2 Residents and RSLs recognise the value of excellence in complaints management, and have overwhelmingly welcomed the draft ‘Best Practice Guidelines’ 2 Residents – and to a lesser extent RSLs – wish the ‘Best Practice Guidelines’ to be mandatory. 3 The manifest need for improvement in the way the RSL sector manages complaints and treats complainants, the call from residents for this improvement, and RSLs’ readiness to change, are why we have called this report “A Mandate For Change”. 4 A Mandate for Change is what we believe the Ombudsman and the Corporation have been given. The rest of this report documents: Ø why the changes are needed, Ø what the changes should achieve, and Ø how they might be brought about. OVERALL RECOMMENDATIONS 5 Our overall recommendation is that the Best Practice Guidelines – slightly modified to take account of the helpful suggestions that came from residents and RSLs – should be made a requirement: the Corporation and the Ombudsman should require RSLs to implement and operate the Guidelines as quickly as can be achieved. The key features of best practice in complaints management for RSLs are set out in the “eight Golden Rules” below. 6 Other sectors now see complaint handling as a key regulatory area. The Financial Services Authority (FSA) has both requirements and guidance for banks and has recently issued requirements and guidance for credit unions. Other regulatory bodies are moving in the same direction in recognition that protection of the consumer’s right to complain can be one of the most effective ways of protecting the consumer’s interests and bringing improvements to services. Copyright © CPA 2002 page 5
  • 6. Access to Complaints Procedures for RSL tenants Executive Summary and Recommendations – A Mandate for Change SPECIFIC RECOMMENDATIONS 7 Justice delayed is justice denied. Residents and RSLs want speedier processes and the guidance must be clear on the number of stages and should also suggest appropriate time limits for different stages. 8 At the final stage, complainants should be offered the alternatives of Ø an impartial and representative panel hearing (giving regard to the possible implications of Beeson vs Dorset County Council) with no restrictions for the complainant (such as time limit on presentation), or Ø an investigation by an impartial and professional investigator. 9 Small community-based RSLs and housing co-operatives will need to consider whether a third stage is appropriate when housing stock is managed by residents and confidentiality of complainants cannot be guaranteed: § Option 1: Umbrella groups (or partnerships of local RSLs) organise and recruit independent panel hearings at third stage § Option 2: No third stage – complainant goes direct to IHOS. 10 Finally, the features of best practice in complaints management for the RSL sector are set out in the Best Practice Guidelines and the “eight golden rules” below. SUMMARY OF FINDINGS Complaints are good for residents and RSLs - the review of literature and research. 11 “Handling complaints properly shows how important customer care is to your organisation. It shows that you: Ø Listen to your users; Ø Learn from your mistakes; and Ø Are continually trying to improve your service.” (Service First Unit, 1999) 12 Complaints are a positive source of feedback and learning opportunities. 13 A healthy level of complaints can be an indicator of an effective service provider – we found that those RSLs who record a high level of complaints tend to have the highest customer satisfaction. The 30 RSLs who recorded the highest number of complaints: § Recorded 57% of all complaints registered by the 152 RSLs who completed our questionnaire § Manage 17.5% of all properties managed by RSLs who completed our questionnaire. § 51% of their residents were satisfied with complaint handling § Only 4% of these satisfied residents said that they needed to complain to a senior manager, a councillor or MP before getting satisfaction. § 43% of their residents were satisfied with the outcome of their complaint Copyright © CPA 2002 page 6
  • 7. Access to Complaints Procedures for RSL tenants Executive Summary and Recommendations – A Mandate for Change The other 122 RSLs: § Recorded 43% of all complaints registered by the 152 participating RSLs § Manage 82.5% of all properties managed by RSLs who completed our questionnaire. § 17% of their residents were satisfied with complaint handling § 24% of these satisfied residents said that they needed to complain to a senior manager, councillor or MP before getting satisfaction. § 21% of their residents were satisfied with the outcome of their complaint Modern complaints management shows a number of other common features: § It has left behind the idea of formal and informal complaint processes and, instead, utilises simple, streamlined feedback processes that deal with any dissatisfaction. § Speed is of the essence in complaints handling - the longer a complaint runs on, the more dissatisfied customers get: best practice organisations aim to complete all internal stages within eight weeks. § Best practice organisations are dedicated to integrating complaint data in to regular management processes to initiate improvements and use complaint data in almost every area of the organisation. § The level of effective complaint handling training contributes significantly to employees’ overall level of satisfaction with a complaints process. Only a quarter of the sample RSLs who replied to the first survey said they had provided any complaint-handling or customer care training to employees during the last year. § Employees should have clear guidance on what they should do to put things right when mistakes are made. Tenants’ and RSLs’ experience - the first survey of residents and RSLs. 14 Few residents are said to complain and those who have aren’t impressed by the RSL’s attempts to resolve any concerns; 15 With notable exceptions, RSLs’ complaints procedures don’t measure up to good practice. § Only 1.6% of residents are recognised by our sample RSLs as having complained in the last year- yet during 1995, according to the MORI survey, 15% of RSL residents said they had made a formal complaint. A significant number of RSLs said that they receive no complaints (!). § The number of procedures with four or more stages has fallen greatly since 1995 but this reduction has not kept pace with the equivalent reduction in the number of local authorities procedures with four or five stages. § Many RSLs require final stage complainants to present – often with a 10 or 20 minute time limit - to the board or committee and a few will arrange a complaints panel (with clear guidelines on composition and role). Some residents and RSLs were concerned that these hearings can be intimidating for some people. § 57.4% of residents are dissatisfied with the outcome of making a complaint to their landlord (Table 10a – 10c). Only 26.3% are satisfied (this is very Copyright © CPA 2002 page 7
  • 8. Access to Complaints Procedures for RSL tenants Executive Summary and Recommendations – A Mandate for Change similar to National Health Service (NHS) complainants where 26% are satisfied with the outcome). § Only 23% of residents stated that they were satisfied with the way their complaint was handled and 61% were dissatisfied (Table 11a – 11e). Local authority surveys show that 36% of respondents are satisfied and 55% are dissatisfied and the recent NHS review of satisfaction with complaint handling found 30.3% satisfied and 49.4% dissatisfied with complaint handling. § Satisfaction among black and minority ethnic residents has marginally improved but dissatisfaction has increased from 43% to 64%. § Only 14.5% of respondents aged 45 or under are satisfied with complaint handling compared to 37% of respondents aged over 60. § Only 35% of RSLs will accept non-written complaints at all stages of the complaint procedure. § Most RSLs publicise their complaint procedure through a statement in their Residents Handbook. Only 2.5% of residents said they knew how to complain by reading the handbook. § When residents complain, financial compensation is low on the list of outcomes they want: putting something right and an apology is at the top. § Most RSLs were unable to say what compensation they had paid to complainants or what other practical actions they had taken in response to complaints. How to achieve the change - the Best Practice Guidance 16 Only 3% of tenants and 6% of RSLs said any of our suggestions was a “bad idea”. • The Guidelines met with much positive comment, and little negative comment, from residents and RSLs. • Several RSLs have said that complaints can be unjustified – an attitude that fails to realise that customers tend not to complain and the importance of discovering the cause of dissatisfaction. • Some smaller RSLs are concerned about how applicable the guidance is to them. Eight ‘golden rules’ for RSLs’ complaints management I Value complaints as an opportunity to learn and improve - use complaints data at all levels of the organisation II Have no more than three stages to your complaints procedure, and make no distinction between ‘informal’ and ‘formal’ complaints III Make sure your complaints procedure is widely publicised in appropriate languages, formats and media IV Try to resolve complaints on the spot – and offer to meet in person all complainants where this hasn’t been achieved V Apologise, provide a clear explanation of your response, and give full compensation where it is deserved Copyright © CPA 2002 page 8
  • 9. Access to Complaints Procedures for RSL tenants Executive Summary and Recommendations – A Mandate for Change VI Aim to take no more than eight weeks for complaints to complete all internal stages VII Train employees to be positive about complaints and manage them skilfully VIII Give complainants an opportunity to complain in person to a panel of three impartial people at the final stage of the complaint procedure. Copyright © CPA 2002 page 9
  • 10. Access to Complaints Procedures for RSL residents Findings in detail 3 OUR FINDINGS IN DETAIL THE WIDER CONTEXT Why Complaints are Good for Residents and RSLs What is good practice in complaint management? – The Literature Review Overview 17 This review reports on 37 documents we have looked at (listed in the bibliography). The salient findings are here presented under the headings of the Cabinet Office’s essential points for complaint procedures. Introduction “Next time I will contact my councillor and ring the local newspaper.” 18 The National Complaints Culture Survey 20011 found that 50% of customers complain all or most of the time when they are unhappy with the way they have been treated by an organisation. The private sector recognises that dissatisfied customers tell 10-25 others about a poor service experience and go elsewhere for the service in future. Also, a customer who has a complaint satisfactorily resolved will be more likely to purchase products or services in future than a satisfied customer who never complains. Customers accept that things go wrong but expect that something will be done to put things right and prevent the same problem happening again. 19 Customers of public services, generally, have limited choice but customers may lose confidence in services and go elsewhere – Ombudsman, councillors, Members of Parliament – or may “shop the system” contacting several services and agencies for the right answer. During 1999, the Local Government Ombudsman’ carried out a study of complaint handling that found only 13% satisfaction with complaint handling where a customer had been referred back to a local authority’s complaint procedure after making a complaint to the Ombudsman’s offices – compared to a national average of 36% satisfaction with local authority complaint handling. ORC International’s research (ORC, 2000) into complaints made following contact with the Independent Housing Ombudsman Service found that 60% of RSL Residents considered that the relationship with their landlord worsened after making a complaint. 20 Dissatisfied customers of social housing providers may delay or withhold payment of rent or service charges imposing extra collection expense on their landlord. A study in the private sector showed that satisfied customers pay on average 14 days earlier than dissatisfied customers. 21 Poor complaint handling can cause the organisation to develop a poor image – dissatisfied customers spread bad news by ‘word of mouth’ or contact the local press. Registered Social RSLs participating in stock transfer programmes may well find prospective Residents giving some thought to their landlord’s “image” before voting for or against the transfer. 1 References are listed in the Bibliography Copyright © CPA 2002 page 10
  • 11. Access to Complaints Procedures for RSL residents Findings in detail 22 Public services also need to be aware that unresponsive, difficult-to-access processes create “difficult” customers who become costly, time-consuming customers with low expectations and a lack of understanding of the processes they are required to follow. But these “difficult” customers can be turned into very effective exposers of flaws in the organisations services and policies. The benefits of effective complaint management 23 An effective complaint scheme will develop a culture of continuous improvement across services. The best organisations, in the public and private sectors, are recognising that improving systems for capturing complaints data provides information about every part of the organisation. Ben Page (Director of Government Research, MORI) has commented that an effective complaint scheme can be more effective than a Best Value regime because of this (MORI, 2000). 24 An effective scheme also: q Improves both customer confidence and satisfaction q Improves credibility and image q Improves employee morale through empowerment and recognition 25 Customers can be better educated about an organisation’s processes – a complaint may be an opportunity for a customer to learn about how an application form should be completed (reducing the costs of processing incomplete forms in future). 26 Some other benefits of effective complaint management are: q Early warning of service breakdown q Prevention of repeat problems q Free consultation q Reduced costs of litigation q Improved targeting of resources and lower costs of service delivery q Increased customer loyalty o Customers loyal to the company and spreading “good news stories” o Helping to attract investment o Helping to attract Government funding for ‘top performers’ in social housing Common Features 27 All effective complaints systems have some essential points in common. The Citizens Charter Complaints Task Force summarised these as follows: “Complaints systems should: § be easily accessible and well publicised; § be simple to understand and use; § allow speedy handling, with established time limits for action, and keep people informed of progress; § ensure a full and fair investigation; § respect people’s desire for confidentiality; § address all the points at issue, and provide an effective response and appropriate redress; § provide information to management so that services can be improved.” (CITIZENS CHARTER COMPLAINTS TASK FORCE, 1995) Copyright © CPA 2002 page 11
  • 12. Access to Complaints Procedures for RSL residents Findings in detail 28 Other elements such as independence, accountability, training and review might also be considered as essential to an effective social housing complaint handling system. Quality Assurance 29 The Financial Services Authority (FSA) has been encouraging regulated companies under its control to use the British Standard for complaint management (BS8600) as a guide for developing effective complaint handling processes (FSA, 2000). 30 The British Standard (BSI, 1999) suggests that complaint procedures should provide: § Adequate resources to deal with the complaints received. § Employee training to make sure those who deal with customers understand the procedures and operate them properly. § Delegation and responsibility to enable employees to deal quickly and efficiently with routine complaints. § Escalation procedures to ensure that in the event of a serious complaint, key employees are alerted and the problem is dealt with by whoever has the appropriate expertise. § External review mechanism to be available where internal procedures are deadlocked. § Follow-up action to ensure that the company learns from any mistakes, and improves products and services and the complaints system where necessary. (These features are consistent with the Citizens Charter Task Force’s ‘essential points’.) 31 The accredited version of the British Standards Institute’s complaint management standard (CMSAS 86:2000) ensures that an organisation’s complaints management achieves an acceptable minimum standard, and the requirement for annual checks ensures that this standard is continuously maintained (BSI, 2000). In Australia, AS 4269 – the Australian equivalent to the British complaint management standard – is a required standard for many monopoly service providers (such as utilities and government departments and agencies). Government Ombudsmen are promoting the adoption of the Standard as a means of promoting a customer-friendly culture and to have a responsive complaints handling procedure at the source. Australian Financial Service providers are required by law and regulations to have an AS 4269 system in place. Australia has a number of industry based dispute resolution schemes, for example, in banking, insurance and telecommunications and participants are required to have complaints systems meeting the standard (Australian Standards, 2001). Definition of a complaint The public sector has long debated the definition of a complaint. This is in stark contrast to most of the private sector where customers simply “complain”. The British Standard requires that all complaints should be logged – however made (BSI, 1999). Guidance for Charter Mark applications states that organisations should “keep records of the number and types of complaints you have received, Copyright © CPA 2002 page 12
  • 13. Access to Complaints Procedures for RSL residents Findings in detail including informal complaints, and how quickly you have dealt with them” (Citizens Charter Complaints Taskforce, 1995). The reality has been that in the public sector often only formal complaints are logged – unlike the private sector where all complaints can be opportunities to increase customer loyalty and ensure repeat business. Avis, the car hire company, advises employees to log all contact whether written or on the telephone. The company’s complaint codes include personal service delivery issues such as telephone problems (engaged, no answer or too may transfers) and process issues such as reservations, check in and check out and insurance. The collected data is used to monitor trends and identify root causes. 32 The Department of Health’s current review of Social Services complaint procedures recognises that informal suggests a lack of seriousness about the complaints and proposes that the word “informal” is not used in the new procedures (DoH, 2001) 33 Discussions about “formal” and “informal” complaints are rarely found outside the public sector – customers complain and the best companies want to know about that feedback and feed it into the quality assurance process - and a web search on “informal complaints” will generate a list of public service complaint procedures. The analysis of RSL complaint systems has shown that most follow the traditional public sector method of distinguishing between “informal“ complaints – that are not recorded - and “formal” complaints. Some RSL complaint procedures encourage customers to complain informally before making a formal complaint but other RSLs have stage 1 as an “informal” stage. 34 Most complaint systems that recognise “informal” complaints define an “informal” complaint as a complaint that is immediately resolved. However, several RSLs’ complaint procedures gave a timescale for handling an “informal” complaint that can range from 7 to 14 days. One complaint leaflet reviewed also stated that “you do not need to use the complaint procedure if you have only a small criticism” of the RSL. 35 Some RSLs have a “grievance procedure” instead of a complaint procedure. The word grievance suggests – unhelpfully - that complaints should be directed at personnel. 36 The National Consumer Council’s 1991 report on social housing complaint procedures found that 90% of housing complaints are made informally to front-line employees (NCC, 1991). The National Consumer Council commented “unfortunately, many public services seem to regard the role of front-line staff in this informal procedure as not part of their complaints procedure… it does nothing for the large bulk of complaints ‘business’ which is carried out by front-line staff.” 37 If a customer is dissatisfied and their dissatisfaction is not responded to, it will turn into a complaint. If they didn’t think they had a serious complaint but their comment was responded to positively with a consequent service improvement, they will be delighted. More and more organisations are now taking a positive approach by telling employees: "If you have to ask, treat it as a complaint”. Northamptonshire County Council has recently introduced a new complaint policy that gives customers the right to decide whether the matter is a complaint. 38 The London Borough of Wandsworth also follows this principle and has been recording 25,000 complaints each year. This is the highest number of Copyright © CPA 2002 page 13
  • 14. Access to Complaints Procedures for RSL residents Findings in detail complaints recorded by a local authority, yet Wandsworth also have more Charter Mark awards than any other public service. 39 The British Standard for complaint management embraces this approach by defining a complaint as “any dissatisfaction (with an organisation) whether justified or not” (BSI, 1999). Access 40 Organisations that are committed to customer service encourage customers to use their complaints system. A report commissioned by the Association of British Insurers found that customers generally shy away when faced by a formal complaint procedure. They may grumble but they don’t like making too much of a fuss (ABI, 1998). 41 A complaint system can only be effective it is used. If the system is to be used, customers need to know about it and find it easy to get their complaint started and progress it through the process. Any complaint procedure should be well publicised. Customers prefer to have a choice of complaint method. Some customers prefer to complain in writing but others may prefer to complain by phone or in person. More customers are using the accessibility of the Internet to make a complaint. The London Borough of Camden has a guide to complaining on their web site that gives local residents advice on how to complain about a RSL and allows them to complain online about several local RSLs. 42 Many RSLs require formal complaints to be put in writing. Most RSLs will respond to an “informal” complaint however made. A few RSLs have produced publicity that positively encourages feedback from customers. 43 Barber and Møller say that a written complaint is a “red flag” and provide the following list of reasons why people will put a complaint in writing: § The customer is upset (it takes effort to write a letter although many who say they will write a letter of complaint do not follow through). § The customer is dissatisfied with the outcome of a verbal complaint (many people only complain in writing after trying some other method to resolve the problem). § The customer is building a paper trail in preparation for legal action (needing to create evidence that they gave the company a chance to fix their complaint). § The customer was not able to find someone to complain to in person § The customer feels uncomfortable with face-to-face complaining § The customer has a personal reason why they could not or did not want to complain at the time § The customer has been told to complain in writing (Barber and Møller, 1996) 44 One RSL allows complaints to be made using a form (with Crystal Mark recognition of the plain language used), in writing to a Freepost address, by phone, by Minicom, by fax, by email or in person. A telephone number is also advertised (in partnership with a local authority) for getting information in large print or Braille or accessing a translation service. Copyright © CPA 2002 page 14
  • 15. Access to Complaints Procedures for RSL residents Findings in detail 45 OFGEM, the regulatory body for the gas and electricity markets, requires all companies to submit their complaint handling code for approval (following consultation with the consumer body, energywatch) before giving them a licence. 46 The code has a number of requirements for companies including: § Provision of details of how a customer can contact the company to make a complaint, including any special arrangements for customers who are of pensionable age, disabled or chronically sick, and those whose first language is not English § Provision of details of advice agencies and other organisations able to help the customer pursue his or her complaint 47 Some RSLs restrict access to a complaints system. Some only allow direct customers, such as tenants or leaseholders, to complain whereas others allow tenants, leaseholders, housing applicants, members of the public, contractors, suppliers and other organisations to complain. 48 Other RSLs have restricted access by excluding certain types of complaints. One RSL reviewed does not allow customers to complain about policies because “policies have been carefully considered and help the organisation to achieve objectives”. 49 Many RSLs do not allow anonymous complaints and state in their publicity that they will not be considered. However, a pattern of anonymous complaints may highlight a problem with customer perceptions of a service or raise a “whistle blowing” issue that needs to be followed up. An organisation that disregards anonymous complaints will miss out on these opportunities. Northamptonshire Social Care and Health Services advise their employees to investigate an anonymous complaint in a similar way to any other complaint. 50 The Office of Fair Trading advises that a company should do its best to pursue even anonymous complaints but recognises that there may be practical difficulties in doing so where full information is not available and clarification cannot be sought from the complainant. 51 Research (TARP, 1997) has shown that a freepost or freephone facility for complainants installs greater confidence in customers who consequently recognise the willingness of the organisation to put things right when they go wrong. A report commissioned by the British Association of Insurers in 1998 stated that companies with a freephone or freepost facility for services, but not complaints, could not claim to take complaints seriously (AIB, 1998). 52 Just like any service or product, a complaints system needs to be accompanied by regular, good-quality publicity. Some organisations will do this by putting details on invoices or with mailshots, articles in newsletters or magazines describing positive complaint outcomes and attractive leaflets and posters in highly visible areas of customer access areas. The National Housing Federation’s guide to dealing with complaints and compensation mentioned that maintenance orders give a good opportunity to get tenant feedback (NHF, 1994). Simplicity 53 Some organisations have got rather carried away in designing complaints systems – and for the best possible motives. They have allowed their systems to Copyright © CPA 2002 page 15
  • 16. Access to Complaints Procedures for RSL residents Findings in detail become more and more complex, rules introduced to deal with abuse, procedures changed to accommodate special cases, additional routes of appeal provided to prevent injustice, and so on. To those used to the mechanics of procedures and paperwork, it may seem that complainants are being provided with the best possible service but to complainants themselves the whole business can be alienating. Surveys show that complainants are less happy with multi- stage procedures with many stages of appeal than they are with simpler set-ups. Speed 54 The Office of Fair Trading (OFT) conducted a survey that found that complaints resolved in less than three weeks have a net balance of satisfied customers but dissatisfaction grows steadily when more than three weeks pass by before resolution. Speed is of the essence in complaints handling. The longer a complaint runs on, the more dissatisfied customers get – and with good reason (OFT, 1999). 55 The National Complaints Culture Survey found that customers expect an acknowledgement by return of post. Customers want an acknowledgement of their complaint as soon as possible – unless the complaint can be resolved immediately (TMI/Institute of Customer Service, 2001). 56 Customers want to be kept informed about the progress of a complaint. Sometimes an interim response can reassure a customer that their problem is being dealt with even if a full response will take some time. Response times should be clearly set out in leaflets outlining the complaints procedure and resources should be made available to ensure that the targets are met. 57 The Financial Services Ombudsman Service introduced a maximum time limit of eight weeks for a company or credit union to resolve a complaint (FSA, 2000). The Local Government Ombudsman has introduced an initial twelve-week time limit for local authorities to handle a complaint but will be reducing this to eight weeks from 1 April 2002. Both schemes allow a customer to complain to the Ombudsman if the complaint is not handled within the time limit2. Fairness 58 The National Consumer Council’s report (NCC, 1991) on housing complaint procedures stated that: “those who operate the system must be seen to be as impartial and objective as possible. The complaints system is likely to fail unless this can be achieved.” 59 RSLs follow a wide range of approaches to achieving fairness. The Housing Corporation’s Performance Standard G6 requires that a complaint procedure “should include a personal appeal to the governing body, which would involve one or more of its members”. Most RSLs do this by requiring complainants to present a complaint to board or committee members and some to a complaints 2 This power, and the Ombudsmens’ ability to choose to accept and investigate complaints before they have been through the entirety of a company’s or Council’s complaints procedures, have proved to be powerful levers of change and improvement. Copyright © CPA 2002 page 16
  • 17. Access to Complaints Procedures for RSL residents Findings in detail panel that may include someone independent of the organisation (such as a tenant from another RSL). 60 In fact, however, research has shown that what complainants have been shown to want is the opportunity to discuss their complaint in person at the beginning of the process, not at the end. 61 The Local Government Ombudsman’s “Devising a complaints system” booklet states that someone investigating a complaint should contact the customer to: • Clarify the complaint; • Clarify the outcome sought; • Check whether he or she needs support of any kind, whether he or she has poor sight or hearing, or a language need; • Check what he or she needs to understand the discussion properly; and • Explain the investigation procedure. (CLA, 1993) 62 A complaint procedure should put the complaint handler in a position where they can judge fairly from all the information whether or not a complaint is valid (they will also require the appropriate skills to ensure that they implement the system properly – see Training below). Complaint handlers should be looking to engage with a customer at the earliest possible opportunity. 63 Our study of complaint procedures has shown that many RSL procedures have the focus on direct contact with a customer at the end of the process. RSL’s do have a variety of approaches to giving a customer an opportunity to discuss their complaint. One of the RSL complaint procedures described a complaints panel of board members that is convened at the end of the complaint procedure. The panel can be convened within six weeks and will communicate a decision within two weeks of the hearing – a total of eight weeks before a response is given to the customer. Another RSL’s complaint procedure reduces the possibility of delay at the panel stage by immediately referring a complaint to the Complaints Panel if not upheld by the Director at stage two. 64 The London Borough of Camden’s Housing department has guidelines that require an employee to visit any customer who complains about delay or quality of repairs. 65 Many complaint systems try to make sure that the people who make the decision can realistically be seen as fair and impartial – for example by ensuring that complaints are never investigated by the individual or group against whom the complaint is made. It is harder to establish the independence of internal arbitrators. The best that can be done is to explain to complainants that someone independent of the original decision on their complaint can carry out a review. If an appeal is made, the results of the appeal should be set out with detailed reasons for them in a clear letter that explains the result as impartially as possible. 66 The FSA’s complaint handling requirements state that a letter giving a final response on a complaint must inform the complainant of a right to go to an ombudsman and include a copy of the Financial Services Ombudsman’s leaflet. This helps to reassure complainants that the organisation is trying to be fair (FSA, 2000). Copyright © CPA 2002 page 17
  • 18. Access to Complaints Procedures for RSL residents Findings in detail 67 Most RSL complaint procedures give the contact details of the Independent Housing Ombudsman Service but some refer to the Housing Corporation as the “final stage” or as another option for the complainant. One RSL’s complaint procedure states “if tenants are unhappy with the RSL after exhausting the appeals and complaints procedure, they can ask the Housing Corporation, the Government body which monitors us, to investigate the complaint.” 68 The Independent Housing Ombudsman Service encourages RSLs to use alternative dispute resolution methods. One RSL’s complaint procedure has a mediation service built into their complaint procedure. 69 The Walsall Mediation Service wrote: “A complaint is a situation that involves a person who believes that they have been aggrieved and it requires a response which will provide some kind of redress. This type of situation normally lends itself to successful resolution following a traditional complaint procedure. A dispute has no clear definition. Allegations are often met by counter allegations. Facts are often subjective, proof difficult to substantiate and there is no conclusive evidence about who is right or wrong. Following a traditional complaint procedure is not appropriate for disputes.” 70 The British Standard’s guidance is that mediation or arbitration is available as an independent service where the internal complaint procedure has been exhausted. The standard also suggests that an Ombudsman scheme should try and mediate a resolution before carrying out an independent review of a complaint (BSI, 1999). 71 The FSA’s guidelines advise companies to consider alternative dispute resolution schemes, such as mediation or arbitration, where the complaints are outside of the Ombudsman Service’s jurisdiction (FSA, 2000). Confidentiality 72 Social Services departments are required to employ a designated complaints officer to provide such a role - and manage the operation of the procedure. One of the RSLs reviewed did advise customers to contact a Customer Relations Team if they are concerned about making a complaint direct to the service provider. 73 The FSA requires all authorised companies to have a single contact point for customers to contact and get advice. The NFH guide to complaint handling suggested that RSLs could follow the designated complaints officer model (NFH, 1994). One RSL’s complaint procedure mentions a complaints officer but gives no means of phoning this officer. 74 Customers want to be reassured that there will be no adverse consequences because of a complaint - such as taking a service away from them. These assurances can be included in literature produced about the complaints scheme. Customers should be given an opportunity to complain in confidence. Copyright © CPA 2002 page 18
  • 19. Access to Complaints Procedures for RSL residents Findings in detail An effective response 75 Research carried out for the Cabinet Office, by MORI, into public sector complaint handling has shown that a rapid response is more likely to lead to a satisfactory resolution than the same response made later (MORI, 2000). The research also highlighted that the importance of a proper apology should not be forgotten even where the complaint may be due to a misunderstanding rather than a mistake. 76 The British Standard stresses that, if procedures are changed because of the complaint, the complainant should be told about what has been done - and thanked for helping the organisation to improve (BSI, 1999). 77 Empowering junior employees to make immediate ex gratia payouts is not only effective but saves on administrative costs. The National Consumer Council’s 1996 report (NCC, 1996) on public service complaint procedures commented “front-line staff should be delegated as much discretion as is appropriate to help them resolve complaints… this may include a power to provide ‘ex gratia’ payments.” 78 The Association of British Insurers’ report on complaint handling procedures comments: “if a mistake that has had an adverse affect on the customer then compensation or some other benefit should be considered in order to put them into the position they would have been in had the mistake not occurred” (AIB, 1998). The assessment should include an element for the inconvenience of having to make a complaint. The Local Government Ombudsman has produced a good practice guide on remedies that includes advice on assessing a payment for inconvenience and time and trouble. 79 The Housing Corporation requires RSLs to have procedures for dealing with: 80 complaints about services including an appeal to the governing body; and claims for compensation for service failures. 81 Some RSLs have taken this literally and set up separate procedures for dealing with complaints and requests for compensation. Therefore, a customer can receive a response to a complaint accepting that a mistake has been made and then have to go through another procedure to get compensation. 82 One RSL reviewed requires complainants to make a claim for compensation in writing to the Housing Manager who will consider the claim in consultation with the Director. Another landlord had a separate policy for dealing with claims for compensation but a customer can use the complaints procedure if they are unhappy with a decision made on a claim for compensation! 83 We also found a RSL that stated that compensation could only be claimed if no legal remedy is available to the customer – preventing themselves from benefiting by resolving a case before legal proceedings are instigated by the customer. 84 We did find a landlord that took a more positive approach by publishing a statement that advises customers that compensation will be considered when appropriate even where the customer has not specifically requested this. Management Information 85 The American Productivity and Quality Centre carried out a benchmarking exercise to assess the complaint handling processes of best-practice Copyright © CPA 2002 page 19
  • 20. Access to Complaints Procedures for RSL residents Findings in detail organisations in the United States. They found that these organisations were dedicated to integrating complaint data in to regular management processes to initiate improvements and that complaint data was used in almost every area of the organisation (APQC, 2000). 86 The best organisations also monitor customer satisfaction with the complaint handling process. The Audit Commission has introduced a performance indicator for customer satisfaction with local authority complaint handling. The results have shown that 66% of customers dissatisfied with complaint handling were dissatisfied with the overall level of service (MORI, 2001). 87 Management information can also be used to discover patterns and trends of groups of customers who access a complaint scheme – or don’t. A complaint procedure integrated into the overall business so that all information from dissatisfied customers can be routinely used to guide future decision-making and can be especially important in a regulated industry like social housing. 88 Two RSLs do monitor complainants by gender, age, ethnicity and disability to establish whether all sections of their customers have equally easy access to the complaints procedure. However, these were the only RSLs that appeared to be doing this valuable analysis. This ‘profiling’ of customers can be used effectively to make sure that the scheme is widely accessible and identify whether any further development or community outreach work is required to make sure all customers understand that complaining is important to the organisation. 89 The Financial Services Authority requires financial services providers to provide a bi-annual report to the Financial Services Ombudsman. Companies are required to provide a detailed breakdown of complaint data to allow the industry’s regulators to be well informed of consumer concerns (FSA, 2000). 90 The recent review of the National Health Service complaint procedures has recommended that NHS organisations are required to provide a quarterly report analysing complaint trends, causes and action taken to prevent recurrence to both the board of management and copied to the local health council and the proposed Patients’ Forum (DoH, 2001). 91 The Office of the Rail Regulator is currently planning to pursue improvements to the quality of complaint data provided by train operators that is already published in an annual report, and to require annual audits of the data provided (ORR, 2001). Training 92 The British Standard lists training as a primary requirement of any complaint scheme and requires that training requirements have been set and achieved (BSI, 1999). However excellent an organisation’s complaints procedure, the quality of the complaints management will also depend crucially upon the skills of the employees who implement it. These skills can be to a certain extent imparted via regular and general customer care training, but there is also a need for specialist training in, for example, investigation skills. 93 TXU Energi are implementing a “Living the Service Excellence Culture” programme. The programme, for all employees, includes a Service Excellence Complaints Workshop that includes the following sessions: Copyright © CPA 2002 page 20
  • 21. Access to Complaints Procedures for RSL residents Findings in detail • Dealing with the industry’s escalated complaints handler (energywatch) • “Prevention (escalated complaints procedure)” • “Complaints (timescales and costs)” • “Complaints procedure – Service Excellence” • “No quibble” – session focusing on style of response letters. • Questions and Answers session 94 This programme is in addition to Complaint Handling training and a monthly clinic session where employees can get advice on resolving complaints made to the industry’s consumer watchdog, energywatch. 95 The provision of complaint handling training for RSLs appears to be confined to a session within a general customer care package although the Chartered Institute of Housing does provide an annual Complaints Policy and Strategy training event that focuses on: • Why people complain and how to obtain constructive feedback • Anticipating how employees may react to complaints and identifying ways to change this • Examining barriers to developing and implementing effective complaints procedures • Involving employees, residents and members in the development of a policy • Dealing with complaints within the context of Best Value 96 The National Complaints Culture Survey 2000 found that the level of effective complaint handling training contributes significantly to employees’ overall level of satisfaction with a complaints process. Public services topped the league of employee dissatisfaction with the level of training provided to complaint handlers (TMI/Institute of Customer Service, 2000). Copyright © CPA 2002 page 21
  • 22. Access to Complaints Procedures for RSL residents Findings in detail CURRENT EXPERIENCE The first questionnaires to residents and RSLs. 97 152 of the 200 questionnaires (65%) sent out to RSLs were returned. 69 (45%) of these questionnaires arrived after the closing date of 14th September 2000. 98 These RSLs posted out 541 resident questionnaires (out of a possible 650). Some RSLs sent out fewer than the required 5 questionnaires because they had received fewer than 5 (in some cases zero) complaints in the last few years. 99 338 residents (55.2%) completed and returned a resident questionnaire. This was a very good response to the questionnaire (the recent NHS review achieved a complainant response rate of 31%) and shows the high level of interest in this project. Our key findings: § 57.4% of residents are dissatisfied with the outcome of making a complaint to their landlord. Only 26.3% are satisfied (this is very similar to NHS complainants where 26% are satisfied with the outcome). A comparison with the 1995 MORI RSL study shows that satisfaction has reduced and dissatisfaction has increased. § Only 1.6% of residents are reported by RSLs to have complained in the last year. During 1995, MORI found that 15% of RSL residents said they had made a formal complaint. § The number of procedures with four or more stages has fallen greatly since Lickiss and Karn’s study in 1995 but this reduction has not kept pace with the equivalent reduction in the number of local authorities procedures with four or five stages. • There is little consistency in RSLs’ approaches to giving residents an opportunity to present their complaint in person at the final stage. • 40 RSLs (26%) said they had provided complaint-handling or customer care training to a total of 853 employees during the last year. • Only 3% of RSLs did not have a documented complaint procedure. • Only 23% of residents stated that they were satisfied with the way their complaint was handled. Recent local authority surveys showed that 36% of respondents were satisfied and 55% were dissatisfied. The recent National Health Service review of satisfaction with complaint handling found 30.3% satisfied and 49.4% dissatisfied with complaint handling. • Resident complainants are most likely to want something put right, or an apology, than to want compensation. § Black and black British residents are more likely to be dissatisfied with the handling of a complaint than other ethnic groups. Asian and Asian British residents are more likely to be satisfied with complaint handling. § Satisfaction among black and minority ethnic residents has marginally improved but dissatisfaction has increased from 43% to 64%. § Only 19% of male respondents are satisfied with the handling of their complaint compared to 25% of female respondents. § Only 14.5% of respondents aged 45 or under are satisfied with complaint handling compared to 37% of respondents aged over 60. Copyright © CPA 2002 page 22
  • 23. Access to Complaints Procedures for RSL residents Findings in detail § There is little difference between the satisfaction of respondents who have long-term illness, health problem or disability that limits their daily activities or the work they do and respondents who do not. § Only 40% of residents found the process of making a complaint to a landlord to be easy. § Analysis of compensation payments shows that the average compensation award rises from £140.55 under an internal complaint procedure to £2,507.39 where payment is agreed following legal proceedings. § Only 35% of RSLs will accept non-written complaints at all stages of the complaint procedure. Several RSLs had stated on the questionnaire that non-written complaints are accepted whereas a check of their complaint literature showed that residents are still told to put a complaint in writing. § Most RSLs publicise their complaint procedure through a statement in their Residents Handbook. Only 2.5% of residents said they knew how to complain by reading the handbook. § 83% of RSLs say that board (or management committee) members are provided with reports of complaints but over half of service managers do not get information about complaints. 67% of service managers working for RSLs managing more than 10,000 properties receive no information about complaints. § 66% of RSLs record and analyse complaints by using manual, paper- based processes. How satisfied are residents with complaint handling? What processes do RSLs use to deal with resident dissatisfaction? Complaint procedures 100 5 (3%) of RSLs did not have a documented complaint procedure (3 large, 1 small and 1 specialist landlord). 101Table 1 shows the number of properties managed by the sample group of RSLs and the number of complaints registered at each stage of the complaint procedure (including Ombudsman). Table 1: Number of properties managed and numbers of complainants at each stage Number of properties managed by sample RSL group: Number of rented properties 378,418 Number of leasehold properties 40,494 Property total 418,912 Stage Number of complainants % of property total One 5,983 1.428% Two 1,342 0.32% Three 346 0.082% Four 47 0.011% Five 13 0.003% Ombudsman 64 0.015% MPs and Councillors 94 0.022% Copyright © CPA 2002 page 23
  • 24. Access to Complaints Procedures for RSL residents Findings in detail 102According to RSLs, 5,983 residents (1.4% of residents) had accessed a complaint procedure in the last year (64 complaints to the IHOS were recorded) whereas MORI found that in 1995. 15% of RSL Residents said they had made a formal complaint. Some of the RSLs involved in the survey do not have a distinction between “informal” and “formal” complaints and log all complaints received. Other RSLs will only record those complaints that are formal complaints made in writing. 103 Four RSLs, who were rated highly on complaint handling – 82% of complainants satisfied opposed to only 6% dissatisfied - accounted for 36% of the total number of complaints recorded but manage only 7% of the properties represented in this survey. 104 Table 2 shows that most landlord complaint procedures allow any individual or group of persons affected by a service or a policy to make a complaint. Table 2: Eligible complainants No of procedures % of procedures Resident 150 99% Applicant for housing 143 94% Resident’s group 125 82% Affected member of 134 88% the public Affected organisation 119 78% No reply 2 1% 105 All landlord complaint procedures included in the sample study had a number of escalation stages. The number of procedures with four or more stages has fallen greatly since Lickiss and Karn’s study (Lickiss and Karn, 1995). Table 3: Number of stages in complaint procedures No of 1995 2001 stages No of % of procedures No of % of procedures procedures procedures One 2 1 0 0 Two 10 6 8 5 Three 41 25 82 54 Four 76 47 49 32 Five 30 18 13 9 Six or 5 3 0 0 more Total 164 100 152 100 106The number of procedures with four or five stages is still higher than local authority equivalents. Before the Local Government Ombudsman recently introduced an eight- week time limit for completing all stages of a complaint procedure, only 10% of local authorities had four or five stages and 26% had only two stages. 107 Some final stages of landlord complaint procedures could have been considered as two stages. Complaint literature reviews showed that some of the sampled procedures allowed a director to review the complaint at the final stage and then progress the complaint to a panel if not upheld (still at the same stage). 108 Although the number of procedures with four or five stages has fallen, the time taken to complete all stages appears to have increased since 1995. Copyright © CPA 2002 page 24
  • 25. Access to Complaints Procedures for RSL residents Findings in detail Table 4: Time taken to complete all stages of procedure Number of 1995 2001 working days: No of % of No of % of procedures procedures procedures procedures Less than two 0 0 8 6 weeks Two to three 17 18 20 14 weeks Four to five weeks 35 38 27 19 Six to seven 20 22 32 23 weeks Eight to twenty- 20 22 53 38 two weeks Total 92 100 141 100 109Table 4 shows that 38% of landlord complaint procedures have timescales that total between eight and twenty-two weeks compared to only 22% in 1995. 110The survey also showed that 84% of the complaints made to the IHOS were by residents who had used a complaint procedure with three or less stages 111Table 5 shows the responsibility for resolving and responding to complaints at each stage of a landlord’s complaint procedure. The table highlights the procedures where an on-the-spot or informal resolution is included in the process (i.e. any employee can handle the complaint) and those procedures that do not include this type of resolution (i.e. management responsibility at the outset). Table 5: Responsibility for resolving complaints Person(s) responsible: Stage 1 Stage 2 Stage 3 Stage 4 Stage 5 Any employee 28 1 Officer 39 Matron or warden 6 Customer service 2 adviser Manager 59 33 Senior Manager 19 4 1 Management Team 2 Customer Relations or 3 1 Complaints Manager Investigating Officer 1 Director 9 46 18 4 Chief Executive 1 22 29 4 Chair 3 8 19 5 Sub-Committee or Panel 2 10 43 20 4 Clerk or Nominated 3 Trustee General Meeting 1 1 Management Committee 1 23 24 7 or Board National or Regional 3 Office Secretary 2 Managing Agent 1 Copyright © CPA 2002 page 25
  • 26. Access to Complaints Procedures for RSL residents Findings in detail Independent Arbitor 1 No reply 2 2 Total 152 152 141 60 12 11223% of RSLs who responded said that they have not reviewed their complaint procedure for more than two years. 31% have not reviewed the operation of the procedure and policies. 11352% of RSLs did not publish information about the operation of their scheme. Most of the RSLs that publish information use their annual report to notify residents of the results. Many RSLs mentioned that they did not publish any information because they received no or too few complaints. Table 6a: Review of complaint policy and procedures Last review of policy and procedures: No of % of procedures procedures Less than 6 months ago 37 24% 6 to 12 months ago 38 25% 1 to 2 years ago 42 28% More than 2 years ago 29 19% Never 6 4% Total 152 100% Table 6b: Review of the operation of the complaint policy and procedures Last review of operation: No of % of procedures procedures Less than 1 year ago 67 44% 1 to 2 years ago 38 25% More than 2 years ago 18 12% Never 27 18% No reply 2 1% Total 152 100% 114 Tables 6a and 6b show that while just under half of RSLs reviewed their complaints policy or procedures in the last year, one third hadnot reviewed its operation within the last two years. Training and guidance 115Only 40 RSLs (26%) said they had provided complaint-handling or customer care training during the last year (to 853 employees). 116Table 7 shows that 54% of RSLs have produced guidance for employees on the handling of complaints within the last two years. Table 7: Employee guidance on complaint handling Last guidance produced: No of % of procedures procedures Less than 6 months ago 22 14% Copyright © CPA 2002 page 26
  • 27. Access to Complaints Procedures for RSL residents Findings in detail 6 to 12 months ago 25 16% 1 to 2 years ago 36 24% More than 2 years ago 39 26% No guidance 30 20% Total 152 100% Time limits for responding and acknowledging complaints 117 Many RSLs do not monitor their performance in acknowledging or responding to complaints. Time limits for acknowledging receipt of a complaint vary from 3 hours to 15 working days. Time limits for responding to a stage 1 complaint vary from 12 hours to 30 working days. Panel hearings can be arranged in 3 to 40 working days. Table 8: Response performance Stage: Procedures Average time Procedures Performance with time limits monitoring limits performance Acknowledging 138 4 working days 99 93.2% Stage 1 134 9 working days 93 88.1% Stage 2 128 12 working days 81 89.6% Stage 3 96 14 working days 54 93.4% Panel hearings 41 20 working days 22 86.8% Complaint outcomes 118 72% of RSLs were able to provide information about the outcome of complaints received during the last year. Table 9: Complaints upheld or justified Stage: Percentage upheld Stage 1 45.4% Stage 2 47.9% Stage 3 44.6% Stage 4 31.1% Ombudsman 22.3% All stages 46.5% 118.1 Appendix D shows resident expectations when making a complaint to their landlord. Many residents simply wanted the landlord to provide a service such as carrying out a repair or dealing with neighbour nuisance. The chart shows that younger residents are more likely to want to see the landlord improve procedures and customer care, apologise and, where necessary, pay compensation. Table 10a: Resident satisfaction with outcome of complaint Satisfied Dissatisfied RSL type No of % of No of % of respondents respondents respondents respondents Small 16 48.5% 12 36.4% Large 37 19.8% 121 64.7% LSVT 11 29.7% 21 56.7% BME 1 6.7% 14 93.4% Specialist 8 36.3% 10 45.5% Rural 2 40% 1 20% Copyright © CPA 2002 page 27
  • 28. Access to Complaints Procedures for RSL residents Findings in detail Community 6 19.4% 20 64.5% Almshouse 4 80% 0 0% Not known 0 0% 0 0% ALL 78 26.3% 210 57.4% 118.2 Resident satisfaction with the outcome of a complaint is low but marginally higher than satisfaction with complaint handling. 119 57.4% of residents are dissatisfied with the outcome of making a complaint to their landlord. Only 26.3% are satisfied. This is very similar to NHS complainants where 26% are satisfied with the outcome (DoH, 2001). Table 10b compares satisfaction with complaint outcome to data collected by MORI (MORI, 1995). The comparison shows that satisfaction with complaint outcome has fallen and dissatisfaction has increased since that survey was carried out. Table 10b: Resident satisfaction with outcome of complaint 1995 2001 No of % of No of % of respondents respondents respondents respondents Satisfied 48 32% 78 26% Dissatisfied 67 45% 210 57% Total 149 338 120 During 1995, black and minority ethnic resident satisfaction with complaint outcomes was lower than the overall rating3. The satisfaction rating has now marginally improved but dissatisfaction has increased from 43% to 64%. Table 10c: Black and minority ethnic resident satisfaction with outcome of complaint 1995 2001 No of % of No of % of respondents respondents respondents respondents Satisfied 27 20% 8 22% Dissatisfied 58 43% 23 64% Total 134 36 Customer satisfaction with complaint handling 121 Only 9% of RSLs were able to provide information about the level of customer satisfaction with complaint handling during the last year; these RSLs had higher than average levels of complainant satisfaction. § An average of 65% of complainants they surveyed were satisfied with complaint handling. § An average of 19.5% were dissatisfied. RSLs who monitored customer satisfaction had upheld 51% of the complaints they received. 122 Table 11a shows how greatly this differs from overall resident satisfaction with complaint handling. Only 23% of residents stated that they were satisfied with the way their complaint was handled. During 2000, all local authorities carried out surveys of satisfaction with complaint handling. The surveys showed Copyright © CPA 2002 page 28
  • 29. Access to Complaints Procedures for RSL residents Findings in detail that 36% of respondents were satisfied and 55% were dissatisfied. The new unitary authorities rated 43% satisfaction and inner London boroughs rated only 25% satisfaction (ALG, 2001). The recent National Health Service review of satisfaction with complaint handling found 30.3% satisfied and 49.4% dissatisfied with complaint handling (DoH, 2001). Table 11a: Resident satisfaction with handling of complaint Satisfied Dissatisfied RSL type No of % of No of % of respondents respondents respondents respondents Small 16 48.5% 12 36.4% Large 34 18.2% 124 66.4% LSVT 7 18.9% 27 72.9% BME 1 6.7% 13 86.7% Specialist 8 36.3% 10 45.5% Rural 2 40% 2 40% Community 5 16.2% 22 70.9% Almshouse 4 80% 0 0% Not known 1 0% 0 0% ALL 78 23% 210 62.1% 123 28% of complainants who contact the IHO when making a complaint are satisfied and 62% are dissatisfied (ORC International, 2000). 124 Our comparative analysis of resident satisfaction by ethnicity, gender, disability and age shows: § Black and black British are more likely to be dissatisfied with the handling of a complaint than other ethnic groups (table 11b). § Asian and Asian British are more likely to be satisfied with complaint handling than other ethnic groups (table 11b). § Only 19% of male respondents are satisfied compared to 25% of female respondents (table 11d). § Only 14.5% of respondents aged 45 or under are satisfied with complaint handling compared to 37% of respondents aged over 60 (table 11c). § Little difference between respondents who have long-term illness, health problem or disability that limits their daily activities or the work they do and respondents who do not (table 11d). Table 11b: Resident satisfaction with handling of complaint and ethnicity of respondents Satisfied Dissatisfied Ethnicity of No of % of No of % of respondents respondents respondents respondents respondents White British 66 24.2% 164 60.1% Black or Black 1 7.1% 12 85.7% British Asian or Asian 4 33.3% 8 66.6% British Mixed parentage 0 0% 5 71.4% Other 1 33.3% 2 66.3% Not known 6 22.2% 19 70.4% ALL 78 23% 210 62.1% Table 11c: Resident satisfaction with handling of complaint and gender of respondents Satisfied Dissatisfied Copyright © CPA 2002 page 29
  • 30. Access to Complaints Procedures for RSL residents Findings in detail Gender of No of % of No of % of respondents respondents respondents respondents respondents Male 25 18.9% 87 65.9% Female 45 24.7% 106 61.6% Male & Female 1 11.1% 5 55.5% Not known 7 30.4% 12 52.2% ALL 78 23% 210 62.1% Table 11d: Resident satisfaction with handling of complaint and age of respondents Satisfied Dissatisfied Age of No of % of No of % of respondents respondents respondents respondents respondents Under 21 1 50% 1 50% 21-30 9 18.7% 36 75% 31-45 12 12.6% 67 70.5% 46-60 19 23.2% 50 61% Over 60 32 37.2% 40 46.5% Not known 5 21.7% 16 69.5% ALL 78 23% 210 62.1% Table 11e: Resident satisfaction with handling of complaint and disability of respondents (includes all respondents who said they have a long-term illness, health problem or disability that limits their daily activities or the work they do) Satisfied Dissatisfied Respondent No of % of No of % of disabled? respondents respondents respondents respondents Yes 24 20.2% 75 63% No 43 24% 112 62.6% Not known 11 28.9% 23 60.5% Wheelchair user 6 22.2% 17 65.4% in household 125 Appendix C shows the reasons for resident dissatisfaction with the handling or outcome of their complaint. 10% of the residents who said that they were satisfied with complaint handling mentioned that they became satisfied with the process after contacting the landlord’s head office or an elected representative or the Ombudsman. Action taken to resolve a complaint 126 Most RSLs were unable to provide any information on compensation paid to residents or other practical action taken to resolve complaints. The 49 RSLs who did, paid compensation to residents in 591 cases (9% of complaints). 20% of resident respondents said they had wanted their landlord to pay compensation to them. 65% of these respondents were dissatisfied with the outcome and 81.5% dissatisfied with the handling of the complaint. 127 Our analysis of compensation payments (table 12) shows how the average compensation award rises from £140.55 under an internal complaint procedure to £2,507.39 where payment is agreed following legal proceedings. Table 12: Compensation payments Number of complainants receiving compensation 591 Copyright © CPA 2002 page 30
  • 31. Access to Complaints Procedures for RSL residents Findings in detail Percentage of complainants receiving compensation 9% Process Number of procedures Average payment where payment made Complaint procedure 49 £140.55 Compensation policy 22 £225.28 Ombudsman 7 £1244.64 Legal proceedings 3 £2507.39 Table 12a: Resident expectations and satisfaction with compensation No of % of respondents respondents Number of respondents who expected a refund 21 6% Number of residents who requested a refund and were 6 2% satisfied with outcome of complaint Number of respondents who requested compensation 69 20% Number of residents who requested compensation and 7 2% were satisfied with outcome of complaint Number of respondents who were dissatisfied because 55 16% no compensation was paid to them Number of respondents who were dissatisfied because 20 6% not enough compensation was paid to them 128 Many resident respondents wanted their landlord to take some practical action to resolve the complaint, such as carrying out a repair, or take some action to prevent the mistake from happening again. 129 53% of respondents said they had complained because they wanted their landlord to provide a service such as carrying out a repair or taking action on neighbour nuisance. Only 20% of residents wanted compensation and many of these only wanted compensation because of the landlord’s poor handling of their complaint. • 58% of these were dissatisfied with the outcome of their complaint. • 61% were dissatisfied with the handling of the complaint. • 32% complained because they wanted the landlord to improve a procedure. • 64.5% were dissatisfied with the outcome of their complaint. • 67% were dissatisfied with the handling of the complaint. • 29% complained because they wanted the landlord to improve customer care. • 76% were dissatisfied with the outcome of their complaint. • 77.5% were dissatisfied with the handling of the complaint. • 23% complained because they wanted an apology from the landlord. • 68% of these were dissatisfied with the outcome of their complaint. • 76.5%% were dissatisfied with the handling of the complaint. • 19.5% complained because they wanted the landlord to pay compensation to them. • 65% of these were dissatisfied with their outcome. • 81.5% were dissatisfied with the handling of the complaint. • 19% complained because they wanted the landlord to explain a decision. • 71% of these were dissatisfied with the outcome of their complaint. • 68.3% were dissatisfied with the handling of the complaint. Copyright © CPA 2002 page 31
  • 32. Access to Complaints Procedures for RSL residents Findings in detail Table 13: Practical action taken by RSLs to resolve complaints Action taken: Number of % of complaints complainants Service provided 4,366 66% Information provided 297 4.5% Procedures reviewed 88 1.3% Policy reviewed 18 0.3% Training for employees 26 0.4% Table 13a: Practical action residents expect to be taken when making a complaint Action taken: Number of % of respondents respondents Service provided 180 53% Information provided 83 24.5% Procedures reviewed 101 30% Policy reviewed 40 12% ‘Customer care’ improved 96 28% Access and publicity 130 Accessibility of landlord complaint procedures has improved only slightly since Lickiss and Karn’s study (Lickiss and Karn, 1995). Only 35% of RSLs will accept non-written complaints at all stages of the complaint procedure. Several RSLs had stated on the questionnaire that non-written complaints are accepted but a check of their complaint literature showed that residents are still told to put a complaint in writing. Table 14a: Access for making non-written complaints Non-written 1995 2001 complaints accepted No of % of No of % of at: procedures procedures procedures procedures All stages 50 30 53 35 First stage only 57 35 48 31 More than one stage but 28 17 33 22 not all No stages 23 14 18 12 No details given 6 4 0 0 Total 164 100 152 100 131 Many residents used more than one method to communicate their complaint to the landlord. Most resident respondents had complained to their landlord in writing and/or by phone. Table 14b shows that respondents want a choice in how they make a complaint. Significantly more respondents would prefer to complain in person, by email or using an email than those who had actually used those methods. Table 14b: Method of complaint Method of complaint: No of No of respondents respondents who did who would complain prefer In writing 73.9% 56.2% Using a complaint form 18.6% 20.4% Copyright © CPA 2002 page 32
  • 33. Access to Complaints Procedures for RSL residents Findings in detail By fax 3.8% 4.7% In person 47.9% 56.2% By phone 65% 45.5% By email 1.4% 7.6% Using a web form 0.5% 4.4% 132 Satisfied residents used an average of 1.7 contact methods to make a complaint. § 65% complained by phone § 48% complained in writing § 41% complained in person § 9% complained using a complaint form § 4% complained by email or web site form 133 Dissatisfied residents used an average of 2.4 contact methods to make a complaint. § 87% complained in writing § 71% complained by phone § 49% complained in person § 24% complained using a complaint form § 2% complained by email or web site form Table 15: Publicity methods System: No of % of procedures procedures Residents Handbook 137 90% Leaflets 95 62% Newsletters 95 62% Posters 21 14% Web site 18 12% Rent statements 2 1% Table 15a: How did residents find out how to complain? System: No of % of procedures respondents Employee 97 29% “Knew my rights” 73 21.5% Leaflets 69 20% Residents Association 54 16% IHO 18 5% Elected Representative 10 3% Advice Agency 10 3% Residents Handbook 9 2.5% Friend or relative 7 2% 134 Most RSLs publicise their complaint procedure through a statement in their Residents Handbook. Only 2.5% of residents said they knew how to complain by reading the handbook. 135 ORC International’s research found that many residents who contacted the IHO were able to easily find information on how to complain (74% finding information on the complaint procedure displayed in the landlord’s offices and Copyright © CPA 2002 page 33
  • 34. Access to Complaints Procedures for RSL residents Findings in detail 63% finding information on how to complain to the IHO was displayed in offices). Residents in this survey had a different experience. Many of those involved in the discussion groups said they would find making a complaint to an Ombudsman too daunting or too formal for the issue they were unhappy about (ORC International, 2000). 136 Only 40% of residents found the process of making a complaint to a landlord to be easy. This is similar to ORC International’s research that found 37% of complainants who contacted the IHO found their landlord’s complaint procedure easy to use. Camden Housing - a local housing authority accredited to the British Standard – carried out a survey during 2000 where 70% of respondents said making a complaint was easy. 137 30% of residents would like an employee to be available to help them when making a complaint and 29.5% of residents would prefer someone independent to help. Only 4.5% said they would like another tenant to help them. 138 18% of residents would like a leaflet explaining how a complaint should be made to a landlord and 14% would like a leaflet explaining the service they had complained about. 139 38% of Residents knew that they could complain to the Independent Housing Ombudsman and 18% knew they could complain to the local council. Reporting 140 Complaints can be useful indicators of performance and customer expectations. Table 16 shows that 83% of RSLs say that board (or management committee) members are provided with reports of complaints but over half of service managers do not get information about complaints. 67% of service managers working for RSLs managing more than 10,000 properties receive no information about complaints. Table 16: Use of complaints as management information Information provided to: No of % of procedures procedures Service managers 73 48% Senior management 95 62.5% Board 126 83% 141Table 17 shows the regularity of reporting information about complaints. Most board members receive reports of complaint information either quarterly or annually. This table also shows that many RSLs who say that service managers receive information about complaints do not provide any regular reports (73 RSLs said that service managers receive information but less than 60 gave any information about the regularity of reports). This can also apply to senior management and board members. Table 17: Regularity of reporting of management information Information provided to: Weekly Monthly Quarterly Annually Service managers 13 22 16 9 Senior management 14 42 35 17 Board 3 16 61 57 Copyright © CPA 2002 page 34
  • 35. Access to Complaints Procedures for RSL residents Findings in detail No reporting 124 88 72 88 142 Table 6 shows that most RSLs use paper-based systems to log and analyse complaint information. Table 18: Logging and management system System: No of % of procedures procedures Paper-based 100 66% In-house database or spreadsheet 44 28% Complaint management software 4 3% No reply 4 3% Total 152 100% What do residents want? 143 Residents gave many suggestions on how complaint handling can be improved. The majority of the suggestions made were in very similar to our findings when researching best practices in complaint handling. 144 Residents want improved access to complaint procedures: § “On first receiving a complaint, immediately put into complaint process.” § “No-one told me how to make a complaint despite my many phone calls - listen - sort out face to face - have someone who will be able to deal with complaint throughout and be able to phone.” § “We knew they prefer complaints in writing.” § “Should take every complaint seriously. I made many phone calls before being told that I had to make my complaint in writing. I have found them very unhelpful.” § “Landlord didn't tell me they had a complaint procedure and nobody took any notice when I did complain.” § “It would be a good idea to have a special phone number for complaints.” § “Have staff on reception who clearly understand complaints procedure and who can accept paperwork.” § “Had to use a complaint form as nothing happened from phone calls.” § “Very difficult to complain by phone – it does get easier when complaint is put in writing. § “They need a complete change of attitude and complaint procedure is very unhelpful for many tenants who are not as articulate as I am.” § “I had no information of who to complain to or what the complaint procedure was. I am unaware of any such leaflet though I daresay that it is in existence. I was also told that the only customer feedback was in the form of complaints.” § “I would suggest be given a chance to discuss complaint in person with a member of staff.” § “Having a complaint officer who can visit tenants and discuss problems and see if anything can be done to help.” 145 Many residents wanted prompt acknowledgement of complaints: § “They could acknowledge the complaint and inform people what is being done about it.” Copyright © CPA 2002 page 35
  • 36. Access to Complaints Procedures for RSL residents Findings in detail § “Acknowledge that a complaint has been made; keep the tenant informed at all stages about the progress of the complaint; and the landlord must carry out agreed action within an agreed timescale.” 146 The speed of resolution was also an important issue: § “Record the date, time and nature of complaint and act on it within a reasonable time.” § “They should considerably reduce the length of time - the number of stages is quite ridiculous and they should keep an open mind about whether someone is telling the truth.” § “Prompt reply to letters - deal with as a priority - more feedback on complaints.” § “Prompt effective action” 147 Also important to residents is the need for systems that empower the person dealing with the complaint: § “People who deal with complaints must be capable of making decisions.” § “To have the right people dealing with complaints and deal with straight away.” § “It would be nice if the person you write to replied to you rather than passing on to someone else.” 148 A significant number of satisfied residents were concerned that resolution was achieved only after escalating the complaint or going to an independent organisation to get help. § “I bypassed the complaint procedure and went straight to the Managing Director.” § “The procedure took too long and was drawn out. I had to get Shelter to help me.” 149 One resident highlighted what can happen when complaints are not handled well: § “Next time I will contact my councillor and ring the local newspaper.” 150 A recurring theme was the importance of listening to complaints and taking effective action: § “Listen to tenants and residents, know policies and how to implement them, give feedback to complainant and monitor progress.” § “Listen to tenants and do not sweep problems under the carpet. Take action when a complaint is made.” § “Just listen - find where system is inadequate and act accordingly.” § “Listen to tenants and have better communication procedure so that you know a) they understand the problem and b) are doing something about it or give an explanation of why not. Quick responses would result in less need for official procedures.” 151 Another recurring theme was the need for more personal interaction between the complainant and organisation: § “Deal with complaint on a face-to-face basis, visit the property to discuss problem and see for themselves.” § “They should talk to tenants.” Copyright © CPA 2002 page 36
  • 37. Access to Complaints Procedures for RSL residents Findings in detail 152 Many residents stated a concern with the culture of the organisation they had complained to: § “Become a professional organisation rather than a family business!” § “Have better attitude towards tenants.” § “Homeowners have a right to a fair hearing on complaints. They should treat tenants as they would like to be treated themselves.” § “They should listen - they shouldn't make you look stupid just because you live in an RSL property.” § “Complaints Panel members are interested in the commercial concerns of the RSL and do not have a positive attitude to customer concerns. The complaints process can be wonderful but has little effect if culture of organisation is not customer-friendly.” 153 Several residents from housing co-operatives or community-based organisations were concerned about the confidentiality of complaining to people who may be too close to the complaint: § “Because we use a small co-operative, local complaints can affect social networks and therefore early stage complaints should be passed to an independent body.” 154 Some residents showed that a successful complaint procedure is achievable: § “Very good process, unable to improve.” § “They handled my complaint perfectly in every way - unfortunately, the world is not like this.” 155 Other residents suggested some key principles for improved management of complaints: § “They should follow the complaint through and remedy the problem. One complaint should be enough, especially when I have made dozens of requests for the same thing. An acknowledgement isn't enough.” § “Clear procedure - written procedure with names and contact numbers - time scale - keep complainant informed - take phone calls - return phone calls - apologise when paying compensation - don't blame complainant” § “The complaint procedure must be simple, easy to understand and should be structured with defined escalation points. It should allow the collection of meaningful statistics. What are RSLs doing to improve complaint handling? We asked RSLs to give us information about any reviews carried out of their management and handling of complaints. Many told us that they do not receive complaints and therefore have no need to take action to improve. A specialist landlord was said they were concerned about the lack of complaints: ”how difficult it is for tenants to think of complaining formally.” Several said their review identified a need for procedure (as no procedure had been in place before). Many said their review had show that the procedure was “working correctly” and no improvement was needed. It is surprising that complaint management is looked on as an area that is exempt from a continuous improvement approach. 156 Some RSLs did find room for improvement. One landlord told us that their review had shown a need to: Copyright © CPA 2002 page 37
  • 38. Access to Complaints Procedures for RSL residents Findings in detail § Improve recording of ethnicity § Improve speed of processing § Emphasise to employees the importance of logging complaints § Monitor levels of tenant satisfaction Copyright © CPA 2002 page 38
  • 39. SETTING THE STANDARD SETTING THE STANDARD – THE DISCUSSION GROUPS Our key findings 157 Residents say a great degree of determination is needed to complain and achieve a satisfactory resolution. § Residents are confident about making a complaint when an RSL is known to be responsive § RSLs recognised the importance of organisational commitment and culture in developing a positive approach to complaints § Many RSLs fail to recognise the importance of complaints as management information § Residents highlighted cultural and age differences in complaining and raised a concern about the accessibility of complaint procedures for ethnic minority residents particularly where an emphasis is placed on written complaints. § Residents say that RSLs need to improve their overall approach to customer care. § RSLs say employees need to be well trained in complaint handling and customer care ethos. § Residents had some concerns about panel hearings. Some liked the idea but others considered a panel hearing would be daunting for some residents and would even deter many residents from pursuing a complaint. Residents favoured better personal interaction over formal hearings. § RSLs believe responses can be improved by increasing interaction with customers at an early stage § Residents had concerns about the impartiality of panels particularly where the landlord was small. § RSLs also had some concerns about whether panels were appropriate for all complaints or all complainants. § Residents gave call centres the ‘thumbs down’ for dealing with complaints § RSLs want to see monitoring customer satisfaction with complaint handling and a move away from measuring performance based on complaint numbers. § RSLs recognise the need to log more than just those complaints where customer says they are making a formal or official complaint 158 Residents want: § More choice in how to complain § Positive publicity to encourage residents to complain and to show that things can change when people complain but RSLs are concerned about encouraging too many complaints § Prompt acknowledgements of complaints to reassure complainants § Quicker responses to complaints (between one and two weeks) and an early apology § Better ownership – an employee deals with the complaint and responds in person (i.e. response not signed “on behalf of” or “pp”) § Fewer stages § Speedier processes (for example, all stages can be completed in eight weeks) § Single point of contact for advice and assistance when making a complaint but some RSLs want localised complaint handling (although they recognise that this does have difficulties in coordinating and bringing consistency to the complaint procedure) Copyright © CPA 2002 page 39
  • 40. SETTING THE STANDARD What are the existing requirements for landlord complaint procedures? 159 The existing guidelines require.. 160 The Housing Corporations consultation document, “The Regulatory Code: Guidance”, proposes that “residents, housing applicants and others have ready access to an effective complaints and compensation policy. Complaints are dealt with effectively and Independent Housing Ombudsman recommendations are implemented.” The Discussion Groups 161 We used the returned resident and landlord questionnaires to recruit participants for four resident discussion groups and two landlord discussion groups. 162 The four resident discussion groups were held in north London, south London, Liverpool and Birmingham. 163 The two landlord discussion groups were held in London and Manchester. 1 What do residents want from a complaints procedure? 164 Participants were all given an opportunity to talk about their individual complaints but asked to focus on the good and bad things about the RSL’s response. Participants were also encouraged to discuss questions such as “Why don’t people complain?” and “What do people want when they do complain?” Finally, participants were asked to give their views on what are the elements of an effective complaint procedure. Why do people complain? …and why don’t they complain? 165 The groups recognised that you have to be determined to get anywhere with a complaint. The groups did also talk about why people don’t complain. One Liverpool participant stated that: “with most people it’s just too much trouble”. Another Liverpool participant said: “they’re not going to do anything about it so why complain.” One Birmingham participant explained that when an RSL is responsive people “do not have any qualms about complaining”. 166 A north London participant said: “By my complaining things have moved on and they have taken notice and things are a lot better at the moment. It’s taken a long time – I had to threaten with the Ombudsman and then everything exploded. I said you have taken no notice of me. I don’t like being nasty but often you have to be nasty to get anywhere”. 167 Another Birmingham participant said that “lack of communication” was a common problem across public services. She also believed that other factors stopped some people from complaining: ”I do think it is cultural - black people won’t complain as much as white people – cultural reasons such as grammar – you have to write a letter to get noticed”. Accessing a complaint procedure 168 The groups looked at the problems in getting a complaint heard. One Liverpool participant mentioned that they were helped when the RSL sent them a leaflet explaining the complaint process. One participant responded by telling us that: “my Copyright © CPA 2002 page 40
  • 41. SETTING THE STANDARD mum asked for a copy of the complaint procedure – nothing was sent except right at the last minute.” Another participant said: “we did not know who to complain to.” 169 The participants were in agreement that RSLs should “constantly remind tenants of the complaint procedure”. 170 Several participants were concerned about the lack of personal interface when making a complaint. One Liverpool participant mentioned that: “they should come out and see what is happening”. Another stated that the executive manager of the RSL visited him after he had written to his Member of Parliament about the problem he was experiencing. 171 A north London participant explained the process for accessing his RSL’s complaint procedure: “Complain first of all in person to your housing officer – they don’t take a lot of notice so fill out a complaint form saying I have dealt with it in person at stage 1”. 172 Some participants were strongly in favour of being able to complain by phone. One Birmingham participant said the process should be: “when you phone – you get through – when you get through they deal with your complaint and get back to you when it is not sorted in the timescale – there should be a follow-up phone call anyway.” Another Birmingham participant noted that: “if they have a complaint in writing it appears to me that will respond to a degree - they have it [a complaint] verbally they tend not to count it as a complaint – it is not accepted as a complaint – it is not actioned.” 173 One south London participant said that he was from a “different generation” to older people who preferred to complain in writing. He said: “emails are brilliant – a lot quicker [than using the post]” and noted that he had not seen “email addresses or fax numbers” advertised by RSLs as a way of complaining. He also explained: “I’d rather speak to someone on the phone because I’m actually interacting and getting a bit of a response – I hate filling in forms.” Another participant said: “writing letters used up a lot of my frustration – did me good, but everyone is different.” 174 Some Liverpool participants spoke about the introduction of call centres but noted that this meant that you can “complain by phone but can’t go in person”. Another participant said that complaining to a call centre was less effective because you “never get to speak to same person twice”. A Birmingham participant said that she either could not get through to the call centre or no-one called back once a message was left with them. 175 A Liverpool participant told us that: “all of the sudden things go wrong and nobody has got a clue.” Participants were concerned that many people would have difficulty accessing a complaint procedure. One Liverpool participant mentioned that: “some people unable to do something because of a disability or mental health issues.” 176 A north London participant said you don’t get anywhere “unless you know how the system works but a lot of people don’t now how to start”. Customer care 177 Some of the issues raised were about the overall customer care of the RSL typified by the following comment: “[when you phone them] they don’t say who Copyright © CPA 2002 page 41
  • 42. SETTING THE STANDARD they are but ask you for your full name!” The participants spoke about the attitude of employees towards people who complain. Several participants believed that complainants are discriminated against. One stated that their RSL was “vetting calls – obviously got a list of complainants” to prevent them from contacting managers. 178 A north London participant noted that it could be “harder to get to team leader than it is to get to the managing director.” He said that the team leader will ask: “who are you – what do you want to talk about?” 179 Participants were also concerned about the result of making a complaint. One Liverpool participant told us that: “it gets worse when you complain”. Another Liverpool participant said that they “get no feedback from them” after complaining. 180 One Liverpool participant spoke about the growth of their RSL and how the focus on increasing their housing stock was often at the expense of customer service. “[My RSL is] just getting too big. They have taken over where council have left off – how are they going to cope when they get so big.” A Birmingham participant complained about “glossy brochures advertising new developments” when existing properties were not being properly maintained. Another Liverpool participant told us that: “customer care is falling way behind because of the need for properties.” 181 Interestingly, one Liverpool participant commented that it is “not the houses that make a nice place - it’s the people.” The participant went on to explain that “the people” included residents and the RSL’s employees. Housing co-operatives 182 A Liverpool participant from a housing co-operative spoke about the unique problems faced when complaining about a tenant-managed organisation. She said there was a gap between those actively involved and those who are not. She told us that the management committee can “take on a group entity – creates a them and us.” She also commented that it was not a healthy situation to have a committee where members are the same year on year and suggested that “four [members] should be seconded from something like CDS” to make sure the housing officer is not being manipulated. Customer expectations and responses to complaints 183 The participants focused on what people want when they complain. They all agreed that they wanted RSLs to treat people fairly and with respect. They said they complained to get something done. One Liverpool participant said that an apology from the RSL is “not too much to ask”. A south London participant said: “what is apologetic in [the RSL’s] diary!” One Birmingham participant told us that the Chief Executive of her RSL said: “we don’t apologise”. 184 Another Liverpool participant said that apologies can be meaningless – “who means it?” – and suggested that the tone of the letter should be apologetic and not just have a sentence of apology. Another Liverpool participant said that “apologies can be manipulative – I want actions and explanations.” 185 But participants generally agreed that getting an apology was a good thing. One Liverpool participant said that “you should get it [apology]” and another said that Copyright © CPA 2002 page 42
  • 43. SETTING THE STANDARD “saying sorry’ takes you off-guard” implying that you don’t expect to get an apology when you make a complaint. 186 On participant, who works for a bank, said: “we have to be apologetic no matter who comes in to the branch to complain – we know that our customers can go to the Banking Ombudsman and they don’t have to go through all the stages that we [ RSL residents] do”. 187 A south London participant gave an account of a complaint he had made about a take-way restaurant: “I complained to McDonalds. They got me the manager. He was very apologetic – made me feel good and gave me money back and vouchers for another day. He said ‘we are sorry and will make sure it won’t happen again’”. Another participant added: “Supermarkets are like that as well”. 188 A Liverpool participant said that: “I want explanations.” She said she complained: ”so it doesn’t happen to other people.” 189 One Liverpool participant spoke about her dissatisfaction at receiving a standard response after her complaint. She said that people “can tell when a standard letter”. She told us that standard letters do not say what your complaint was and are impersonal. Participants agreed that they want to know that someone has actually looked at the complaint. A Birmingham participant told us “I’ve been totally ignored – I’ve given up”. 190 South London participants said that a satisfactory resolution could be achieved but were unhappy about the “hassle of getting it done”. They also spoke about the need to get someone else involved and one participant said: “only got resolved because I got someone else involved”. Another participant said: “got my MP with me now – next step that I am taking”. 191 South London participants were unhappy about the frequent use of “pp or on behalf of” on complaint responses. One participant said that this meant that he didn’t know whom he was dealing with and another participant commented that “a secretary” must have done the response. 192 Other participants were unhappy with the time taken to respond to complaints. One north London participant said: “They take so long to answer. They want three weeks before letting you know what’s happening”. Another participant said an initial response should be given in “one week”. A participant said that complaint responses “should be done within a week”. He noted that: “each stage takes longer – they say this is because they need to investigate – it’s rubbish because they should deal with small things quickly and take their time on more complicated things”. Publicising a complaint procedure 193 Participants considered that the right to complain can be made clear by better publicity of the complaint procedure. One Liverpool participant told us that “if it is well-publicised - newsletters and the like – [the RSL] can’t say where did you get the information from – can’t dispute it.” A south London participant said she had been complaining for some time before a “new recruit responded to me saying ‘you do know that we have a complaint procedure’ – this was the first I knew about the complaint procedure”. Copyright © CPA 2002 page 43
  • 44. SETTING THE STANDARD 194 Participants spoke about publicising the complaint procedure in the Residents Handbook. One participant said that the handbook had some information on how to complain but no phone number to call - “Just like emergency numbers in handbook – list of numbers to ring”. Another participant said that: “we complained to the Ombudsman first because we didn’t know the RSL had one [complaint procedure] – housing officer wouldn’t tell us.” 195 Participants suggested that RSLs should do more than having a statement about the procedure in the handbook. A participant said that sending out a “complaint form with rent statements is a good one or include a complaint form with the handbook.” 196 A north London participant explained how he “tried to find out whom I can complain to” but his co-operative wouldn’t give him any information. He said: “posters should be in reception with details of people you can contact to get help – ‘call this number’.” 197 A south London participant said RSLs should actually ask people if they have any problems. A Liverpool participant said that RSLs should “send out [information] every six months”. One participant noted that sometimes problems are experienced in getting newsletters because of problems with the post service. 198 One participant said: “there are independent people who can help – but you don’t know about them.” He said that RSLs should “publicise these people.” Complaint leaflets 199 We asked participants to look at an RSL’s (not included in the pilot study) complaint leaflet. On Liverpool participant mentioned that: “There are only 3 stages which is good and then you can take it to the Housing Ombudsman”. 200 Participants did not know that all RSL residents have the right complain to the Independent Housing Ombudsman. One Liverpool participant said that: “not everyone knows about the Ombudsman – I didn’t know about it”. A north London participant said that his RSL “had the wrong address for the Ombudsman”. 201 Birmingham participants were concerned about the leaflets inaccessibility to customers who may not speak English or have impaired vision (the leaflet had community languages and large print advice in the middle section). 202 Participants suggested that rather than asking what do you want us to do to put things right that “different tick boxes for different things you want them to do” should be used”. Another participant suggested that a “different form for nuisance – completely different from other issues – again with tick boxes.” What makes a successful complaint procedure? 203 Participants spoke about what makes a successful complaints procedure. One Liverpool participant said they have rules but they don’t follow them and therefore RSLs should “stick to their own rules”. Another Liverpool participant commented: “it’s simple – isn’t it?” 204 A Birmingham participant spoke about the importance of getting residents involved in the design of the complaint procedure. She said her RSL’s complaint Copyright © CPA 2002 page 44
  • 45. SETTING THE STANDARD procedure involved tenants and this resulted in a speedy complaint procedure with only two stages. 205 One south London participant said that: “you never end up speaking to the right person” and mentioned that “it would help if you had one person you can contact all the way through.” Another participant said that our discussion group invite letter was an example of good practice because “you were good enough to say get in touch with you if any problems – we knew who we were dealing with.” 206 Some of the participants spoke about how the complaint becomes more complex the longer the RSL takes and the more stages that are followed. A participant said that: “as it passed from stage to stage you want to them to explain a previous decision – you’re adding bits all the time.” Stages of complaint 207 A south London participant said that stages gave the RSL a reason to “drag it on” and said: “two stages would be feasible”. Another participant said his experience was: “Complaint procedure 1, complaint procedure 2, complaint procedure 3. You think that by 3, in writing – black and white – you think you’re half way up there – complaint procedure 4 and you’re still not getting there – they’re fobbing you off.” He also said that after the receiving the “3rd or 4th letter, your mind is boggling”. Another participant said: “after so many stages I got so fed up”. 208 A Liverpool participant said that unnecessary stages were an example of the RSL “passing the buck”. Again, participants spoke about the need for personal contact at an early stage. One Liverpool participant said that “once you put in a complaint, someone should come ‘round”. Another Liverpool participant said that someone from the RSL should “listen then come back and say something” suggesting that discussion should be held before the complaint is investigated. 209 A north London participant noted how employees on the frontline were unable to deal with complaints He said: “People are frightened to do anything (on the frontline). Frightened that people up top will say you are not doing your job properly – it’s wrong”. Panel hearings 210 The participants spoke about panel hearings. They said that a panel hearing could only be effective if it was impartial. One Liverpool participant said that “board members live on the estate” and a panel of board members would be inappropriate to consider his complaint. Another Liverpool participant was concerned about the confidentiality of a panel and said that “leaks from committee” was not uncommon. A Birmingham participant said that board members were too close to the Chief Executive. 211 A north London participant said that a panel should be independent because his co-operative was a small organisation and may people know each other. 212 A south London participant who had attended a panel hearing said it “felt like I was at the Old Bailey being tried and tested and waiting for the jury to come down on their side”. Another participant said: “I’m quite a strong character but I wouldn’t like that – like you’re being on trial”. Copyright © CPA 2002 page 45
  • 46. SETTING THE STANDARD 213 A participant suggested that a “panel from a estate on another side of town” might work better. 214 A Birmingham participant said that: “a personal approach is needed. Someone to come ‘round and talk things through”. A north London participant said that the managing director visited him when he threatened to take his complaint to the panel stage. He said: “I had the managing director with me for two hours. I gave him a sheet of problems and a sheet of what should be done about them and what the RSL should do to make things better. It took me a long time to get to him but everything got resolved.” A model complaint procedure 215 The group agreed that minimum standards for RSLs were a good thing. One participant remarked that RSLs have “so many differences – stick by their standards”. 216 Birmingham participants talked about RSLs having: “someone totally separate from housing management like a customer relations person” who you could talk to in confidence. 217 A north London participant said about his RSL: ”You’ve got what they call Customer Relations, the complaints team… they are well trained – it’s like they’ve had legal training”. He was so impressed that he told another participant: “You should talk to Customer Relations about your problem – tell them your problem – they handle it all and tell you what to do about it”. 218 A south London participant said that: “you have to go through so many channels and you have to chase them all the time”. Another participant said: “eight or ten people could be dealing with the complaint. It would be nice to have one person or team who deal with complaints.” 219 The groups were unanimous in their support of a time limit on completing a complaints process. Participants considered that an 8-week time limit was reasonable. A Birmingham participant said “it sound about right” and another participant said her tenant-managed RSL had based the complaint procedure on an 8-week time limit. One Liverpool participant commented that the “eight week time limit should be definitely highlighted.” 220 A south London participant said that: “I got so fed up – I just gave up in the end”. Another participant said: “there should be a penalty clause for every day that the response is late – this will make the RSL get their act together”. 221 Another participant commented that: “I’ve been waiting two months over the last complaint I made”. Another Liverpool participant suggested that RSLs should “tell us why if you’re going to take longer”. A Birmingham participant said that “a prompt acknowledgement is needed” and explained that people need to know that the complaint has been received by the RSL. 222 One participant questioned why RSL performance is not regulated in the same way as the health service and education. She said that someone should “name and shame – I think housing offices should be assessed on how they are doing their job”. Copyright © CPA 2002 page 46
  • 47. SETTING THE STANDARD 223 Participants spoke about the importance of being able to take a complaint to someone independent where the RSL is unwilling to deal with problem. One participant said that too often “basically, you get the run around”. Another Liverpool participant said: “you ring up with a complaint – it’s legitimate but you get passed round like you don’t count.” And another Liverpool participant said that RSLs “should give you more advice – let you know who can help you when they can’t.” 224 Participants recognised the importance for RSLs to deliver good customer service. One Liverpool participant said: “Next flat that I get – I’ll try and get one like his [a satisfied participant in the group]. When you hear about better service you’ll go actually go for it.” A north London participant commented that he spoke frequently about the good service he got from his RSL’s Customer Relations team and said that a “friend with another RSL said ‘ours is a different world to yours’”. A Liverpool participant said: “surely it pays them dividends to have an official complaints department and deal with them.” A Birmingham participant said: “customer care – that’s what it boils down to.” Some other comments § “Housing is critical – it is our home.” § “Co-operatives belong to another era – need something a bit more professional.” “I’ve had complaints but they are saints compared to others represented here” “forms remind me of school trips with their tear-off slips” § “Housing Ombudsman process is a waste of time” § “Mediation should be used in nuisance disputes – housing co-operative didn’t want to do it” § “People sometimes think they’re complaints are petty” § “I’m told I’m confrontational because I want to know an answer” § “Who better to care for the community than your RSL?” § “They just put something in writing but don’t get back to you” § “People like us have enough on our plate without dealing with those sort of people” § “RSL thinks ‘just petty’ but you are living with it on a day and night basis” § “Quite scary to think about dealing with an Ombudsman” § “Depends on who they pass the buck to” § “I have complained bitterly at times” § “I went to my MP” § ”I’m going to see a solicitor” Conclusion – Residents groups Copyright © CPA 2002 page 47
  • 48. SETTING THE STANDARD 225 The discussion groups showed that residents appear to need a great degree of determination to complain and achieve a satisfactory resolution. Even those who were satisfied with the outcome of their complaint told us that they let the RSL know that they would not be giving up or got the outcome they wanted because they knew how to manipulate the system. 226 The groups did also highlight cultural and age differences in complaining. Concerns were raised about the accessibility of complaint procedures for ethnic minority residents particularly where emphasis is placed on written complaints. Also, age differences were highlighted to show that younger people prefer to complain by phone or by using new technology like email. 227 Overall, the discussion groups showed the importance of giving residents a choice of how to complain. 228 The groups also discussed the importance of positive publicity to encourage residents to complain and to show that things can change if people complain. 229 All groups believed that customer care is an important factor in making sure that complaints are heard at an early stage. Participants were concerned about a perceived unwillingness of employees to talk to people who had a complaint about the RSL. 230 The groups wanted any “model complaint procedure” to include: § Prompt acknowledgement of complaints to reassure the resident that the complaint had been received § Quicker responses to complaints (between one and two weeks) and an early apology § Greater ownership – an employee deals with the complaint and responds in person (i.e. response not signed “on behalf of” or “pp”) § Fewer stages § Speedier process (for example, all stages can be completed in eight weeks) § A single point of contact for advice and assistance when making a complaint 231 The groups did express some concern about panel hearings. A few participants did like the idea but others considered a panel hearing would be daunting for some residents and would even put people off from pursuing a complaint. Participants favoured more personal interaction over formal hearings. 232 The groups also had concerns about the impartiality of panels particularly where the RSL was small. 2 What do RSLs want from a complaint procedure? 233 All Participants were given an opportunity to talk about their own RSL’s approach to complaint handling. Participants were also asked to look at the draft evaluation criteria and discuss the feasibility of introducing a set of requirements for RSL complaint procedures. Organisational culture 234 Participants discussed the importance of the organisation’s commitment to delivering good customer service. One larger RSL participant noted that his RSL Copyright © CPA 2002 page 48
  • 49. SETTING THE STANDARD “used to have a director of operations but now have a director of customer services”. 235 A larger RSL participant said that “complaints much more integral to what we do”. A participant added that “we work in a complicated business” – “not just rent collection and occasionally carrying out a repair anymore”. She added, with the agreement of the rest of the group, that “we want to keep our customers – we want people to transfer from one RSL to our RSL”. 236 A smaller RSL participant noted that: “our customers are captured customers”. Who can complain? 237 Participants said that their RSLs had no limit on who can use the complaint procedure. 238 One smaller RSL participant said that: “with leaseholders we have the most tricky time”. Participants in both groups said that leaseholders often had higher expectations of service than tenants. What is a complaint? 239 All participants did talk about a need for a clear definition of a complaint. 240 One smaller RSL participant said that RSLs “can’t settle criteria by what someone is complaining about” as some people are aggrieved by what is seen to be a minor problem. 241 One smaller RSL participant said that complaints about a policy or standard are excluded from the complaint process. Another participant said that his RSL has “very clear and we have standards” for services but sometimes customers are saying: “something wrong with the system – we don’t like the policies”. 242 Another smaller RSL participant said that their RSL did not exclude complaints about a policy or standard: “we would treat that as a complaint because it is dissatisfaction”. Another participant said regular surveys should pick up any dissatisfaction with a service. 243 One participant spoke about how his RSL’s complaint procedure defined a complaint as a failure to provide a service to a published standard and, for example, would not accept a complaint about a delay in carrying out a repair when it had been carried out within the relevant time limit. However, he noted that often the definition depended on a “whoever shouts loudest” approach – some people could complain about anything and it would be accepted if they shouted loud enough. Recording all complaints 244 One smaller RSL participant said that complaints are only recorded if the customer writes in or they phone and say they are making a complaint. She said that they encourage employees to resolve complaints “then and there rather than going through a formal process.” Another said that a tenant would say: “I wish to complain formally”. Copyright © CPA 2002 page 49
  • 50. SETTING THE STANDARD 245 Participants commented that past performance indicators (PIs) for monitoring complaint performance were not helpful by being numbers based but could also show that there was no comprehensive system for logging details of complaints. One participant noted that “a rush around at the end of May” would produce a figure of complaints received but “weren’t sure if you had 5 or 55… bit of a finger in the air job”. 246 Another participant from a LSVT RSL said: “we have a central logging system that we inherited from the local authority” that helped them to analyse complaint data. 247 One participant commented that: “We rely on staff acknowledging that it’s a complaint”. 248 One larger RSL participant said that “tenants write to the top – miss out other levels [of the organisation]” and explained that this was difficult to manage. 249 Another participant commented that only “head office logged complaints but local offices also dealt with complaints but they are not logged”. 250 A larger RSLs participant noted that “only count ones that get past first level” and another participant said some complaints are logged but “others are lost”. 251 Residents “go to person who they know best”. 252 One larger RSL group participant said that: “board members pick up complaints at the annual general meeting”. Another participant said that actually they “have a help desk/complaints desk at the general meeting”. On-the-spot resolutions – informal vs. formal complaints 253 One larger RSL participant said the RSL was looking to “empower staff to apologise and make small payments”. Another participant commented that being empowered to resolve complaints “must make job easier” for employees. 254 A smaller RSL participant explained that his RSL was reviewing their four-stage process because: “we’re not getting that many complaints – formally anyway”. He said the Best Value Review of Customer Services found that “we actually had complaints but they were being expressed in other ways – comments about services”. Management Information 255 One larger RSL participant said that complaint information is “supposed to feedback to board”. Another larger RSL participant explained that the RSL’s complaint procedure stated that “quarterly report goes to the board but I don’t think we have ever done one”. 256 One participant said: “it’s a numbers thing, how many we get about repairs and so on” but “presenting it in a way that is meaningful – don’t know how we do that”. The participant explained that “definitions need to be more precise – for example, day-to-day repair or programmed repair” to make sure that information is meaningful. Recognising employees Copyright © CPA 2002 page 50
  • 51. SETTING THE STANDARD 257 One larger RSL participant said that the RSL has a “standing item on staff team briefing to have a selection of compliments to improve staff morale”. Audit 258 One larger RSL participant said that the RSL had organised a group of tenants to carry out a “mystery shopper programme” and the Chief Executive writes to congratulate employees who had performed well. Responding to complaints 259 One smaller RSL participant had helped a friend to complain about another RSL and noted that: “I have experience of both sides – it’s not [an issue of getting] money - it’s just about getting the problem resolved. It’s more frustrating on this side trying to get a response [than in his own role of dealing with complaints]”. 260 One larger RSL participant said that employees would need to be able to “explain why you can’t do something”. Another participant commented that: “that’s half the battle – if you can get that right first time round you won’t be dealing with expectations that you cannot manage”. 261 One larger RSL said that employees are encouraged to respond in writing or by phone but employees would “confirm response in writing”. Another participant noted that it is “crucial” to ask the customer what action is required to put things right. 262 One smaller RSL participant talked about the importance of treating all complaints “sensitively” and added that complaints about transfers often need clear information to be given to resolve the matter. 263 A larger RSL participant said: “I phone and say ‘I’ve got your letter – can I make sure that I understand what the problem is before I start my investigation’”. She said that this means that you “start off on the right footing” and have a “chance to clarify” what the complaint is about – another participant said this “saves time in the long run”. Other participants commented that this approach “diffuses the situation” and “makes a difference”. A smaller RSL participant said that visiting a customer could be very revealing as often “you realise they are right”. 264 A smaller RSL participant said that “one reason why we don’t get many formal complaints is that somebody will be prepared to sit and spends how ever long it takes just to talk it over right at the beginning and that’s the stage we say sorry that this has happened – normally that’s the end of it.” 265 One larger RSL participant said that RSLs “need more staff to talk to customers when dealing with a complaint”. Another mentioned that: “we don’t keep customers informed about action taken”. Compensation 266 One smaller RSL participant mentioned that having “a compensation policy” could encourage more people to request compensation. Another participant said that this was “why we have a compensation policy because it sets out clearly when compensation will be paid and means that people can’t just claim for anything”. Copyright © CPA 2002 page 51
  • 52. SETTING THE STANDARD 267 Another participant said that “we don’t need complex policies – need to be able to sort out there and then”. Customer satisfaction 268 One larger RSL participant recognised that “loyalty and tenant satisfaction is a big measure” of performance. Another participant recognised that customer satisfaction “should be measured through customer satisfaction surveys as well” as complaints. 269 One participant said that they don’t proactively check whether the customer is satisfied with a response as they “assume they are satisfied or have given up”. 270 Another participant said: “I would like to do a post-complaint survey” to go out with the response to complaints. Publishing information about changes made following investigation of complaints 271One larger RSL participant said: “it would be good to do” and another commented that: “we try to learn from what we’ve done”. Another participant noted that this might encourage more people to complain: “we don’t go around looking for more complaints”. Central contact point for complaints 272 One larger RSL participant said that they acted as the RSL’s complaints officer and were responsible for “monitoring responses and helping customers to access the procedure”. They said that they were empowered to get employees to take action where necessary but their main role was to ensure the effective operation of the procedure. 273 Another larger RSL participant said that the RSL’s procedure made “each area responsible – report annually to area committee”. He said that the RSL had “no-one looking at complaints overall” and “no central person to link information”. 274 One participant advised that: “problems where people complain to the local office – not everyone wants to”. The participant explained that: “some [tenants] want confidence to complain to impartial team who will monitor even though [the team] don’t reply themselves – [this] satisfies tenants”. 275 Another participant said that the “advantages of having somebody central is that they can complain to someone they perceive as independent”. 276 One participant disagreed and said that his RSL’s “procedure stays local” and said that his organisation “hadn’t experienced people having a problem with local office”. Helping customers to complain 277 Participants agreed that employees would help residents to make a complaint. Copyright © CPA 2002 page 52
  • 53. SETTING THE STANDARD 278 One larger RSL participant said that employees “don’t direct people [to an advocate]”. Another participant said that “we do encourage the use of advocates in our formal process – we have strong links with local advice agencies”. 279 A larger RSL participant said that they have a complaints officer who is the advertised contact for all escalated complaints. 280 A smaller RSL participant said the procedure says that customers should complain in writing but they will help a customer if contacted. Another participant mentioned that this “was a degree of ceremony really”. Publicising the procedure 281 One larger RSL participant said that she made sure that there was “a poster and information leaflets in every reception area”. Training 282 One larger RSL participant said that: “we have been looking at Virgin Mobile – they record all of the telephone calls. The team leader spends half an hour a day reviewing them”. He explained that: “we are thinking about recording call for training purposes”. 283 One larger RSL participant stressed the importance of training as RSLs still had “many ‘jobsworths’ around”. 284 Another participant said that RSLs did not always recognise the importance of complaints and support for the process was “lacking in resources – got to make sure that we get the message across – complaints need to be looked at positively”. 285 One larger RSL participant said that “training focused on culture” of the organisation. 286 Another participant considered that “inevitably, comes down to having well- trained staff who can deal with query first time - we will fail if we don’t have well- trained staff in the complaints process”. A model complaint procedure 287 One larger RSL participant said that: “tenants should have a general process for making a complaint”. 288 Participants agreed that “minimum standards” could be applied to complaint handling but one participant did note that any regulation “would have to bring added value”. The participant said that any standard “needs flexibility”. 289 A larger RSL participant said that “minimum standards and guidance” would be helpful. 290 A smaller RSL participant did note that sometimes more than one RSL may be involved in one complaint procedure (for example, one may act as a managing agent for another) and that this was “a nightmare”. 291 Larger RSL participants said that the following should be included in any standard: Copyright © CPA 2002 page 53
  • 54. SETTING THE STANDARD • number of stages • independence • what is a complaint • timescale (response time) • customer satisfaction • training 292 A larger RSL participant said that “8 weeks is reasonable” for completing the complaint procedure. The participants discussed the difficulty of organising panel hearings to meet this time limit. One participant explained that it could be “difficult to get a representative panel in time” and gave an example of a complaint about racial discrimination where the panel needed to be representative to be fair. 293 One smaller RSL participant said about stages: “We have four [stages] and it’s just encouraging people to come back and back”. Participants noted that “it would actually be less work” to have less stages. 294 A smaller RSL participant said: “requiring people to fill out forms and go through stages is incredibly bureaucratic.” Panel or committee stage 295 One smaller RSL participant spoke about his own experience of making a complaint to a committee. He said that you: “have to submit complaint in writing to chair – even though you had complained in writing before.” He noted that the organising of a hearing took several months and the hearing was: “very adversarial – you’ve got ten minutes each. For some people very imposing situation. You against them. Abhorrent to me. Year long going through situation and then you’ve got ten minutes.” Participants said that many people: “don’t care about going to committee – better to spend some time talking to an officer and get issue thrashed out and problem resolved. [panel hearing] puts people off.” 296 A smaller RSL participant did not recognise the term ‘panel’ and said that she always understood that this was the “committee stage”. 297 Another participant said that: “only Leaseholders get as far as committee and are able to hold their own and say their bit – no problem at all for them.” 298 One participant suggested that independent arbitration could be a better alternative “or some form of independent person. Panels are inevitably influenced by what the officers say”. 299 Another smaller RSL participant said that making a complaint is often about “getting to the person who has the power to change something – more useful to pinpoint procedure around people who have power to change rather than having a set stage process.” Conclusion – RSLs groups 300 These discussion groups highlighted the importance of: § Organisational commitment and culture § A consistent approach to what is a complaint (wide definition Vs strict criteria) and who can complain Copyright © CPA 2002 page 54
  • 55. SETTING THE STANDARD § Linking definition to the need to log more than just those complaints where customer says they are making a formal or official complaint § Employees well-trained in complaint handling and customer care ethos § Improving responses by increasing interaction with customer at an early stage § Flexible approach to compensation payments § Monitoring customer satisfaction with complaint handling § Publishing more than just numbers of complaints - but some concern about encouraging too many complaints § Debating a central contact point for complainants – some see great benefits but others want localised complaint handling but recognised that this does have difficulties in coordinating and bringing consistency to the complaint procedure § Employees giving help to customers - but some recognise also the importance of advocates 301 The discussion groups also accepted that many RSLs fail to recognise the importance of complaints as management information 302 Both groups did consider that “minimum standards and guidance” could be helpful. The following were considered to be elements that could be included: • Number of stages • Independence • Complaint definition • Timescale (response time) • Customer satisfaction • Training 303 The groups also highlighted a need for greater definition of the role of complaints panels and some concern was raised about whether panels were appropriate for all complaints or all complainants. Copyright © CPA 2002 page 55
  • 56. THE DRAFT BEST PRACTICE GUIDELINES THE DRAFT BEST PRACTICE GUIDELINES The following document is the “draft Best Practice Guidelines” as it was sent out for comment. Copyright © CPA 2002 page 56
  • 57. THE DRAFT BEST PRACTICE GUIDELINES Simplicity, speed, fairness and confidentiality AIM The complaints policy and procedures should be simple, speedy, fair and confidential. The landlord should make sure that: § Time limits are set for acknowledging and responding to complaints at any stage of the complaints procedure. § An employee (of sufficient competence who, where appropriate, was not directly involved in the subject matter) investigates a complaint. § Any response to a complaint informs the customer about their right to escalate to the next stage. § Responses to complaints are translated into appropriate language where requested. § Any final response informs the resident about their right to complain to the Independent Housing Ombudsman and includes the latest version of the IHOS leaflet. § A final response (after any escalation) is given no more than 8 weeks after receipt of a complaint, except in exceptional circumstances. GOOD PRACTICE GUIDANCE A good landlord’s publicity includes a statement that positively welcomes complaints. The landlord’s senior management is given responsibility for the performance of the complaints policy and supports employees in the operation of the policy and procedures. The landlord encourages on-the-spot resolution of complaints and uses plain language in responses and publicity. The customer is given an opportunity to meet or talk with a senior officer when an employee is unable to resolve a complaint on the spot. The landlord’s investigation of a complaint is open and impartial. The customer is given easy access to all relevant information. The landlord has a system in place to make sure customer confidentiality is maintained. A customer is kept informed when the association needs to take longer than the published response standard to deal with complaints. A customer, at the final stage of the Sandwell Metropolitan Borough Council procedure, is given a choice between has a pool of independent people who making their complaint in person to an investigate complaints at the final stage impartial panel or requesting an impartial of the customer feedback procedure. investigation of the complaint. Copyright © CPA 2002 page 57
  • 58. THE DRAFT BEST PRACTICE GUIDELINES Denplan Limited set up an arbitration scheme to consider complaints that cannot be resolved through their own complaint handling procedure. The landlord prepares an action plan when things go wrong and makes sure that any proposed action to put things right and prevent recurrence is carried out and closely monitored. The landlord monitors performance in responding to complaints. The landlord The London Borough of Camden’s Central Complaints Unit regularly surveys investigates complaints at the final stage of the complaint the views of procedure and has achieved 50% customer satisfaction with customers who complaint handling – the same rating as the Local Government make complaints. Ombudsman. The landlord gets customer’s views and opinions of the complaints policy. The level of satisfaction with the complaints procedure is regularly reported to senior management, the board and residents. Customers are confident that no “comeback” will occur as a result of making a complaint. The landlord promotes the customer’s right to escalate a complaint and monitors “no comeback” by effective use of customer satisfaction checks. The landlord has a system for maintaining the confidentiality of customers who complain. MEASURES FOR ASSESSMENT The landlord’s: § Performance in meeting response targets § Percentage of complaints resolved on the spot § Customer satisfaction with complaint handling § Customer compliments and suggestions § Reports to management and the board on the operation of the policy Copyright © CPA 2002 page 58
  • 59. THE DRAFT BEST PRACTICE GUIDELINES An effective and informative response and outcome Aim Landlords should: § Keep a log of all complaints – no matter how received § Have procedures that allow action to be taken to restore affected customers to a position before the service failure (including customer payments or compensation) § Have procedures in place to aggregate complaints and support an external review by the Independent Housing Ombudsman GOOD PRACTICE GUIDANCE A good landlord’s responses to complaints show regret and give an explanation. The landlord always apologises when things go wrong or misunderstandings occur. The landlord should: § Have a comprehensive redress or remedy menu that clearly advises your employees on the actions that can be taken to resolve a complaint § Keep detailed information about customers and their complaints § Regularly analyse complaint information and use information about complaints when reviewing and assessing policies § Have procedures in place to allow the exchange of information between departments or partner organisations where customers are affected by cross- service issues The role of the Ombudsman is clearly defined and is understood by all Brent Housing Services have developed a employees. set of protocols for handling complaints about temporary housing managed by local The landlord has resources available housing associations. to support external review processes. Measures for assessment The landlord’s: § Aggregated complaints data by key service areas, especially analysis of outcomes, escalation and remedies § Effectiveness is dealing with complaints as evidenced by the results of complaints investigated by the IHOS. Copyright © CPA 2002 page 59
  • 60. THE DRAFT BEST PRACTICE GUIDELINES MANAGEMENT INFORMATION Aim Landlords should provide, annually, the Independent Housing Ombudsman Service with statistics showing key areas of complaint. Landlords should publish, at least annually, information about complaints performance, trends and action taken to improve service delivery. GOOD PRACTICE GUIDANCE A good landlord keeps information about volumes, costs and resources involved in complaint management. Landlords categorise and analyse feedback. Trends Bristol and West plc’s Customer Relations Centre are reviewed and acted on. produces a monthly digest for employees called “It’s About Complaints” showing trends of complaint, Complaint information is action taken to resolve complaints and action taken spread widely across the to prevent repeat complaints. organisation and discussed with employees. Customers and employees are informed about any action initiated. Landlords produce statistics showing trends of complaints and the demographics of customers who make complaints and those who do not. Good landlords use complaints as a source of learning about the organisation’s strengths and weaknesses in order to improve services MEASURES FOR ASSESSMENT The landlord’s: § Aggregated complaints data by key service areas, especially analysis of outcomes, escalation and remedies Copyright © CPA 2002 page 60
  • 61. THE DRAFT BEST PRACTICE GUIDELINES AUDIT Aim Landlords should regularly audit the operation of the complaints policy and procedures. Good practice guidance A good landlord regularly samples complaint responses to check compliance with policy and procedures. The landlord also uses the opportunity to check on what has been learnt from complaints and action taken to prevent recurrence. The landlord arranges regular Jephson Housing formed a group of active ‘mystery shopping’ exercises residents who regularly carry out ‘mystery to assess accessibility. shopping’ exercises to check their customer care standards. Measures for assessment § Overall complaints monitoring especially numbers of complaints § Customer satisfaction surveys § Diversity monitoring of complaints § Performance in meeting response targets § Percentage of complaints resolved on the spot. § Customer satisfaction with complaint handling § Customer compliments and suggestions § Reports to management and the board on the operation of the policy § Aggregated complaints data by key service areas, especially analysis of outcomes, escalation and remedies § Results of mystery shopping exercises Copyright © CPA 2002 page 61
  • 62. THE DRAFT BEST PRACTICE GUIDELINES EXTERNAL VALIDATION Aim Landlords should be accredited with the British Standard for complaints management (CMSAS 86:2000) to ensure continuous improvement of complaint handling processes. GOOD PRACTICE GUIDANCE A good landlord will set themselves a realistic and challenging timetable for achieving and then maintaining CMSAS 86:2000 accreditation. Measures for assessment § Overall complaints monitoring especially numbers of complaints § Customer satisfaction surveys § Diversity monitoring of complaints § Performance in meeting response targets § Percentage of complaints resolved on the spot. § Customer satisfaction with complaint handling § Customer compliments and suggestions § Reports to management and the board on the operation of the policy § Aggregated complaints data by key service areas, especially analysis of outcomes, escalation and remedies § Results of mystery shopping exercises Copyright © CPA 2002 page 62
  • 63. BEST PRACTICE GUIDANCE FOR RSL COMPLAINT PROCEDURES Residents’ assessments of the draft Guidelines Residents Good Okay Not Bad idea idea sure idea RSLs should not have more than 3 stages of 31 2 1 1 complaint RSLs should usually issue a final response to a 27 3 1 4 complaint within 8 weeks of the resident's first complaint. RSLs should make sure that whoever investigates 32 3 complaints at the final stage is trained in putting things right for the customer. RSLs should give customers an opportunity to 26 4 4 1 present their present their complaint in person to a panel of board or committee members. Overall perceptions The great majority of residents considered that the best practice guidelines were a good idea. One resident summed up the benefits of the guidance when commenting: “any complaints are treated as criticism by our landlord and not with the intention of improvement and likewise are given negative responses.” Positive comments included: § “You have struck a good balance.” § “These suggestions should go some way to improve, develop more improvements.” § “Appears to cover all aspects.” § “Your best practice guidance is excellent.” § “We would like your best practice guidance here!” § “People need to feel they are listened to and kept informed.” § “These guidelines are excellent in theory.” Several residents were concerned that we are only proposing guidelines to bring improvements to RSL complaint procedures: Copyright © CPA 2002 page 63
  • 64. 5.BEST PRACTICE GUIDANCE § “You should make them do this.” § “These should be more than just suggestions.” § “How do you know RSLs will abide by this best practice?” § “Landlords MUST do these things!” § “These guidelines should be mandatory.” § “It needs to be put into practice now!” § “Landlords only pay lip service to the idea of resolving complaints.” 3-stage procedure Residents were supportive of our proposal to limit the number of stages to three. A small minority said three stages are still too many. One commented: “3 stages can mean decision is dragged out over a long period.” 8-week time limit Most residents supported a time limit. One resident commented: “landlords should make sure complaints are dealt with in fastest time possible”. Residents who liked the idea of a time limit said: “Placing time constraints on the complaint procedure has to be good for all those involved.” “Need final response within shortest time otherwise complainant becomes angry.” “Fast response to a complaint is a good service.” Residents who said the 8-week time limit was a bad idea were concerned that the proposed time limit is too long. These residents said: “Should take less than 8 weeks.” “A final response needs to be sooner.” “8 weeks far too long - shorten period to six weeks.” Investigation of complaints at the final stage This was the most popular idea amongst residents who supported being given the option an investigation by someone trained in putting things right. Residents who liked the idea made comments such as: “Staff training is important”. One resident commented: “One member of staff to be allocated to see the complaint through from start to finish”. Choice of complaining in person to a panel Residents generally liked the idea of being given the option of making a complaint to a panel. Some residents had concerns about this idea: § “Too many complaints are diverted before panel stage.” § “Board members are not independent and may know people on the estate.” § “We have a poor and weak committee.” § “Complainants may feel intimidated in front of a board or committee.” One resident commented that: “Tenants should be given an opportunity to have their "full say in person" to a panel”. This comment highlights a practice of some RSLs to limit the time allowed to present to a panel to 20 or even only 10 minutes. Another resident suggested: “Tenants should be given the opportunity for another person to attend complaint meetings.” One resident suggested that the “Board should be made aware of investigations at final stage” instead of actually dealing with individual complaints. Some residents also suggested that complaint handlers should contact the customer when the complaint is received. One resident said: “Complainants should Copyright © CPA 2002 page 64
  • 65. 5.BEST PRACTICE GUIDANCE be able to discuss their complaint at an early stage”. Other residents suggested: “more personal contact” and: “more meetings to take place.” Suggestions for improving the management and handling of complaints Residents gave many suggestions for improving the handling of complaints: § “Multiple complaints about the same issue should be given priority.” § “Help should be given to people who want to complain.” § “An annual report of how complaints are dealt with should be published by the landlord.” § “Complaints should be acknowledged quickly.” § “Procedure should be checked by a small group of tenants (from various backgrounds and age groups) and be checked by the Plain English Campaign and a complaint should keep a single reference number.” § “Landlords should help the tenants as much as possible.” § “Keep a log of complaint no matter how received.” § “Make sure staff are trained and can act quickly.” § “Tenants to be kept informed by way of a newsletter.” § “Make sure that tenant does not feel put off from making a complaint.” § “Make sure that landlord is aware of some tenants' vulnerability.” § “Make it easier for tenants to complain and be listened to without being wrongly judged.” § “Better monitoring of complaints performance.” § “Should include a disability audit to make sure process is fully accessible.“ § “Procedures should be simple and uncomplicated.” § “More advertisement is needed in town halls, libraries and CABs. Tenants should have a place where they can go and get satisfaction.” Copyright © CPA 2002 page 65
  • 66. 5.BEST PRACTICE GUIDANCE RSLs’ assessments of the draft Guidelines RSLs Good Okay Not Bad idea idea sure idea RSLs should not have more than 3 stages of complaint 39 3 2 1 RSLs should usually issue a final response to a 24 15 4 2 complaint within 8 weeks of the resident's first complaint. RSLs should make sure that whoever investigates 25 12 7 1 complaints at the final stage is trained in putting things right for the customer. RSLs should give customers an opportunity to present 25 11 8 1 their present their complaint in person to a panel of board or committee members. Overall perceptions The majority of RSLs considered that the best practice guidelines were a good idea. One landlord recognised the importance of the guidance and usefully commented that this is “a cultural thing”. Positive comments included: § “All essential ingredients.” § “Organisations should give priority to complaints.” § “In areas of low demand - a good procedure can send a positive message to prospective tenants.” § “These guidelines are a very useful tool.” § “The guidelines are very good and very welcome.” § “The good practice examples are a good idea.” Criticisms of the guidelines § “Sometimes legal reasons for not apologising to customers.” Copyright © CPA 2002 page 66
  • 67. 5.BEST PRACTICE GUIDANCE § “(The guidelines are) sometimes overly sympathetic to customer.” § “Not feasible to train all staff involved in complaint handling.” § “Guidance comes from perspective that all complaints can be resolved as they are all justified.” § “Too much emphasis on putting things right.” § “Will add a tier of bureaucracy to dealing with complaints informally.” § “The guidance does not seem to take account of the size of the organisation - it may lead to tenants of smaller organisations believing that they are receiving a second rate service.” One landlord was concerned that our proposal for appraising the performance of employees in dealing with complaints, stating: “singling out complaint handling from other aspects of customer contact seems divisive - the skills of listening and responding to customers should be an essential tool for all staff.” Another landlord responded by saying that the board were asked to consider our proposed guidance but they did not see any point in commenting because their existing procedure had already been agreed by the Housing Corporation and was “Best Value”. Some RSLs were concerned whether the guidance should be applied to all RSLs. Some comments included: § “Being a rural HA causes separate issues.” § “Not sure if guidelines cover specialist agendas.” § “Make it more compressed and digestible for smaller RSLs.” § “Not sure how relevant the Ombudsman report back is for small RSLs” Some RSLs wanted more information on the benefits of gaining accreditation to the British Standard. One landlord commented that they were: “not sure about recognition on complaints standard, this can be another tick box exercise – Business Excellence Model (BEM) might be better in getting a cultural change in place.” 3-stage procedure Most RSLs were supportive of our proposal to limit the number of stages to three. One landlord commented that: “more than 3 stages is cumbersome”. A small minority said three stages were too restrictive. Comments included: § “Prolonging complaints processes just adds to the stress and frustration for all concerned.” § “The less stages the better.” § “More than 3 stages will have no credibility with the complainant.” § “3-stage approach is clear and straightforward.“ § “A limited number of stages should speed up the process and reduce frustration for users of the procedure.” Some RSLs said they already had a 3-stage procedure and an informal stage - not understanding that we are proposing that the three-stage process should include all complaints and remove any informal stage. One landlord commented: “3 stages in addition to informal stage which should be recorded.” Another landlord was concerned about when to treat a complaint as a complaint and commented: “practical difficulties in determining when an enquiry is a complaint.” Copyright © CPA 2002 page 67
  • 68. 5.BEST PRACTICE GUIDANCE One landlord fully understood our approach and commented: “There is a real emphasis on the first stage as the one for 'sorting the problem' rather than in traditional multi-stage systems where there's almost the implication ‘this probably won't work but it doesn't matter because there's another stage where you can try again!’”. But another landlord said the guidance had: “not enough guidance on how to resolve a complaint when first made - concentrates on procedure.” 8-week time limit Most RSLs supported a time limit. RSLs who liked the idea of a time limit said: “8 weeks is plenty of time to establish facts”, “It is important that complaints are resolved promptly” and “speed is important in resolving complaints - if disputes drag on a complaints culture might well develop.” RSLs who said the 8-week time limit was a bad idea were concerned that the proposed time limit is too short. These RSLs said: § “More important to keep complainant informed than keep to a pre-determined time limit.” § “Difficult to complete in 8 weeks when reference to management committee is needed.” One landlord suggested: “Perhaps a percentage target of 90% resolved within the timescale plus a review of the reasons why cases were not completed in time.“ Another landlord commented: “I like the principle of limiting the timescale to 8 weeks but I am not sure it is entirely practical, especially if the final stage is the board - committee cycles may prove difficult”. Investigation of complaints at the final stage Overall, RSLs supported giving residents the option of requesting an investigation at the final stage of the procedure. One landlord suggested that: “investigators should be given appropriate authority to resolve” and another commented: “Final stage must be investigated by Officers, which are empowered to resolve issue”. Some RSLs were concerned about the reference to ‘putting things right’. Comments included: “putting things right is not always the solution depending on whether the complaint is justified” and “putting things right implies that we can satisfy the customer”. One landlord commented: “It is more important that somebody investigating complaints at the early stages is trained in putting things right for the customer.” Choice of complaining in person to a panel RSLs generally gave support to panel hearings. Some had similar concerns to residents about this idea. One landlord commented that: “the customer may be nervous of appearing before a panel” and a specialist RSL said that “panels can be intimidating”. One landlord suggested that emphasis should be placed on giving residents an opportunity to discuss concerns and: “residents need to be able to complain in person on neutral ground or in their home”. Another landlord suggested that the: “final stage should allow a variety of ways to handle the complaint.” Copyright © CPA 2002 page 68
  • 69. 5.BEST PRACTICE GUIDANCE A few RSLs made suggestions on improving existing procedures for setting-up panel hearings. Suggestions included: “panel should include a tenant rep”, “panel members should be trained” and “final stage should be independent review”. Suggestions for improving the management and handling of complaints RSLs gave suggestions for improving the handling of complaints: § “There needs to be separate targets for each stage.” § “Check with customer to see if they are satisfied.” § “Good practice advice on ‘vexatious’ complainants is needed.” § “It is often difficult to separate a complaint about the organisation from a complaint where personal, domestic or neighbour problems exist.“ § “Customers with a learning disability need independent support.” § “Must include guidance on complaints being pursued in an unreasonable manner or are frivolous or vexatious.” § “The procedure should be as straight forward as possible for both customers and employees.“ § “Complaints are a source of customer feedback, along with tenants surveys, focus groups etc. that can be used to identify areas of service provision that may require improvement. Should also log compliments and use information” RSLs also gave some suggestions on improving the guidance document: § “Add contact details for best practice organisations.“ § “Some of the good practice guidance seems to be in the wrong sections.” § “Take out the good practice examples” § “Clarify the role of the complaints officer.” § “It would also be useful to have an example of a remedy/redress menu.” § “It would be useful if there was a recognised definition of a complaint which all RSLs used (this would assist in benchmarking performance).” Representative bodies’ views (Still waiting for National Housing Federation’s comments) Copyright © CPA 2002 page 69
  • 70. Appendix A: References 4 APPENDICES APPENDIX A: REFERENCES “A complaint is a gift”, Janelle Barlow and Claus Møller, Berrett-Koehler (1996) “A Good Practice Guide for Effective Complaint Handling”, Commonwealth Ombudsman's Office, Canberra (1997) “An Alternative Means to Resolving Disputes”, Walsall Mediation Service (1999) “CMSAS 86:2000 Complaint Management Scheme Assessment Standard”, British Standards Institute (2000) “Complaining Survey”, Which? (January 2001) “Complaint Management and Service Recovery”, American Productivity & Quality Center (2000) “Complaints Review Panels. A Good Practice Guide”, National Social Services Complaints Officers Group (March 1998) “Complaint handling by firms”, Financial Services Authority (2000) “Complaint handling by credit unions”, Financial Services Authority (2002) “Complaint Handling Procedures”, Association of British Insurers (July 1998) “Consumer Detriment”, Office of Fair Trading (1999) “Customers Mean Business”, James A Unruh, Unisys (1996) “Dealing with Complaints and Compensation. A Guide for Housing Associations”, National Federation of Housing Associations (1994) “Devising A Complaint System. Guidance on Good Practice”, The Commission for Local Administration in England (February 1992) “Feedback on the handling of complaints for the Independent Housing Ombudsman Service”, ORC International (December 2000) “Housing Association complaint procedures. An analysis of recent practice”, Rachel Lickiss (June 1995) “Housing complaint procedures: principles of good practice for social landlords”, National Consumers Council (1991) “How Good Is Your Service? And in a Monopolistic Environment, Does It Really Matter?”, TARP (1997) “How to deal with complaints”, Service First Unit (1999) “National Complaints Culture Survey 2000”, Institute of Customer Service & TMI (2000) Copyright © CPA 2002 page 70
  • 71. Appendix A: References “National Complaints Culture Survey 2001”, Institute of Customer Service & TMI (2001) “NHS Complaints Procedure National Evaluation”, Department of Health (2001) “Putting It Right For Consumers. A Review of Complaints and Redress Procedures in Public Services”, National Consumers Council (1996) “Putting Things Right”, Citizen’s Charter Complaints Task Force (1995) “Remedies. Guidance on Good Practice”, The Commission for Local Administration in England (September 1997) “The operation and impact of the Ombudsman service for tenants of Registered Social Landlords”, Valerie Karn and Rachel Lickiss (1999) “Using Complaints for Quality, Service, and Marketing Decisions”, e-Satisfy/TARP (2001) “When a complaint is a gift”, Bill Dee, Australian Standards (2001) Local Authority complaint procedures and policies London Borough of Camden London Borough of Wandsworth Northamptonshire County Council RSL complaint procedures and policies Abbeyfield Society ASRA Battersea Churches and Chelsea Housing Trust Bourne Housing Society Ltd Broomleigh Housing Association Carr-Gomm Housing Association Chantry Housing Association Christian Action (Enfield) HA Ltd Devon and Cornwall Housing East Thames Housing Group Granta HA Hallmark Community HA John Grooms Housing Association King Street Housing Society Leeds Housing Association Leeds and Yorkshire Housing Association Manningham Housing Association Macintyre Housing Association Network Housing Association North British Housing Northern Counties Housing Association ODU-DUA HA Ltd Riverside Housing Association The Guiness Trust Group Toynbee Housing Association Watford YMCA Copyright © CPA 2002 page 71
  • 72. Appendix A: References Private Sector Complaint procedures and policies Avis Denplan Hyundai TXU Energi Copyright © CPA 2002 page 72
  • 73. Appendix B: Profile of Respondents APPENDIX B: PROFILE OF RESPONDENTS RSLs: RSL category Number of % of respondents respondents Abbeyfield 5 3.3% Almshouse Charity 3 2.0% BME RSL 8 5.3% Community Based RSL 7 4.6% Large RSL 77 50.7% LSVT 14 9.2% Rural RSL 3 2.0% Small RSL 22 14.5% Specialist RSL 13 8.6% Total 152 100.0% Residents: Ethnicity of respondents Number of % of respondents respondents Asian or Asian British Afghani 1 0.3% Bangladeshi 1 0.3% Indian 10 3.2% Total for Asian or Asian British 12 3.9% Black or Black British African 4 1.3% Caribbean 9 2.9% Other 1 0.3% Total for Black or Black British 14 4.5% Mixed parentage Other mixed background Asian and Black Caribbean 1 0.3% White and Japanese 1 0.3% White and Asian 3 1.0% White and Black African 2 0.6% Total for Mixed parentage 7 2.3% Other Arab 1 0.3% Greek 1 0.3% Turkish Cypriot 1 0.3% Total for Other 3 1.0% White British 240 77.7% Irish 23 7.4% Other 3 1.0% Australian 1 0.3% French and Irish 1 0.3% Portuguese 1 0.3% Scottish 2 0.6% Copyright © CPA 2002 page 73
  • 74. Appendix B: Profile of Respondents Spanish 1 0.3% Welsh 1 0.3% Total for White 273 88.3% Total 309 100.0% No reply 29 Total number of respondents 338 Gender § 49% were female § 40.7% male Disability § 37.6% have a long-term illness, health problem or disability that limits their daily activities or the work they do § 9% lived in a household where someone uses a wheelchair Age § 0.7% were aged under 21 years § 12.1% were aged between 21 and 30 years § 28.3% were aged between 30 and 45 years § 24.1% were aged between 45 and 60 years § 27% were aged over 60 years Copyright © CPA 2002 page 74
  • 75. Appendix C: Residents’ reasons for dissatisfaction with complaint handling APPENDIX C: RESIDENTS’ REASONS FOR DISSATISFACTION WITH COMPLAINTS HANDLING The process (71) Delay in acting (155) Still ongoing (111) Too little action taken Unhelpful staff (139) (108) Poor explanation given Lack of follow-up action (118) (128) Copyright © CPA 2002 page 75
  • 76. Appendix D: Residents’ expectations when making a complaint to their landlord APPENDIX D: RESIDENTS’ EXPECTATIONS WHEN MAKING A COMPLAINT Refund Compensation Change a policy Improve customer care Over 60s Improve procedures Under 30s All Explain a decision A service Information Apologise 0% 10% 20% 30% 40% 50% 60% 70% Copyright © CPA 2002 page 76
  • 77. Appendix E: Chart showing residents’ dislikes and likes with complaint handling APPENDIX E: RESIDENTS’ 140 DISLIKES AND LIKES OF COMPLAINTS HANDLING 120 100 80 Negative Positive 60 40 20 0 Speedy A clear A fair Quick reply C lear reply Apology Helpful staff Listened The procedure procedure procedure quickly outcome Copyright © CPA 2002 page 77
  • 78. Appendix F: Landlords involved in this project APPENDIX F: RSLS INVOLVED IN THE PROJECT The following table sets out those RSLs involved in this project, with information about the number of residents they have, the number of tenant/complainant questionnaires they sent out, and their tenant/complainants rating of their complaints handling. Copyright © CPA 2002 page 78
  • 79. Appendix F: Landlords involved in this project RSL Correspondence name Complaints 2000/01 RSL form Tenant Tenant Consult- Satisfaction Code Complaints Residents % IHO returned Forms Forms ation Handling Outcome Cases ? Sent Returned response LH2174 Ability Housing Association 4 312 1.28% 0 Yes 5 3 66% 66% SL3605 Access Homes Housing Association Limited L0732 Airways Housing Society Limited 3 33% 33% H3720 Alcohol Recovery Project 1 133 0.75% 1 Yes 5 3 0% 33% L3713 Arawak Walton Housing Association Limited 3 33% 0% L0249 Arcon Housing Association Limited 12 1230 0.98% 0 Yes 5 0 Yes LH3811 Arhag Housing Association Limited 1 560 0.18% 3 Yes 0 0 LH3913 Ashiana Housing Association 0 1369 0.00% 0 Yes 5 0 LH4034 Ashram Group 4 780 0.51% 1 Yes 3 0 L4199 Ashton Pioneer Homes Limited 3 900 0.33% 0 Yes 5 2 50% 50% L3534 ASRA Greater London Housing Association Limited 52 1950 2.67% 0 Yes 5 5 20% 20% L3533 ASRA Midlands Housing Association Limited L0395 Axiom Housing Association Limited 19 1703 1.12% 0 Yes 5 2 Yes 50% 50% LH3966 Basildon Community Housing Association Limited 113 3350 3.37% 0 Yes 5 4 25% 25% LH0103 Battersea Churches and Chelsea Housing Trust Ltd 7 1625 0.43% 0 Yes 5 1 0% 0% LH1649 Bedford Citizens Housing Association Limited 1 225 0.44% 0 Yes 0 0 L4096 Beechdale Community Housing Association Limited 1 1382 0.07% 0 Yes 5 1 0% 0% L4167 Bentilee Community Housing Limited 1 953 0.10% 0 Yes 5 1 0% 0% L1668 Black Country Housing & Community Services Group 6 1206 0.50% 0 Yes 4 4 0% 0% Ltd L1408 Bourne Housing Society Limited 9 1719 0.52% 1 Yes 5 2 0% 0% H3835 Brighton YMCA L1990 Bristowe (Fair Rent) Housing Association Limited 0 57 0.00% 0 Yes 0 0 L4218 Broadening Choices for Older People 1 219 0.46% 0 Yes 1 1 100% 100% L0026 Broadland Housing Association Limited 6 3239 0.19% 0 Yes 5 3 Yes 33% 33% L3979 Broomleigh Housing Association Limited Withdrew Yes LH0269 Brunelcare 1 0% 0% L2007 Buckinghamshire Housing Association Limited 0 365 0.00% 0 Yes 5 0 C1981 Canning Housing Co-operative Limited 0 119 0.00% 0 Yes 5 3 33% 33% L4118 Castle Vale Community Housing Association Limited 3 629 0.48% 0 Yes 4 2 50% 50% LH1557 Chantry Housing Association Limited 3 2450 0.12% 0 Yes 5 1 0% 0% SL3212 Cherwell Family Housing Association Limited 5 285 1.75% 0 Yes 5 1 0% 0% LH0391 Cherwell Housing Trust 13 1769 0.73% 0 Yes 5 3 0% 0% H1957 Cherwell Housing Trust See below Copyright © CPA 2002 page 79
  • 80. Appendix F: Landlords involved in this project below L0862 Cheviot Housing Association Limited 13 4618 0.28% 0 Yes 5 3 33% 66% LH4138 Chiltern Hundreds Charitable Housing Ass Ltd 49 7800 0.63% 0 Yes 5 2 0% 50% L1444 Cirencester Housing Society Limited 14 130 10.77% 0 Yes 5 1 0% 0% L1445 Collingwood Housing Association 69 5500 1.25% 0 Yes 5 2 50% 50% LH1651 Colne Housing Society Limited 9 1500 0.60% 0 Yes 5 4 0% 0% LH0170 Co-operative Development Society Limited 38 2952 1.29% 1 Yes 5 4 0% 0% C3675 Co-operative Home Services (Home Counties) 30 1700 1.76% 0 Yes 5 2 0% 50% Limited LH0495 Croydon Churches Housing Association Limited 1 0% 0% SL3118 Crystal Palace Housing Association Limited 330 10227 3.23% 2 Yes 5 3 Yes 0% 0% LH4146 Cygnet Housing Association Limited 12 240 5.00% 0 Yes 3 0 C2695 Cyron Housing Co-operative Limited 2 53 3.77% 0 Yes 5 0 LH2346 Darlington Housing Association Limited 4 244 1.64% 1 Yes 3 2 100% 50% LH4213 Derwent and Solway Housing Association Limited 18 3679 0.49% 0 Yes 5 3 33% 0% L3791 Devon & Cornwall Counties Housing Association Ltd 3 0% 66% L0133 Devon Community Housing Society Limited 3 1068 0.28% 0 Yes 3 2 0% 50% L0307 Duncane Housing Association Limited 1 232 0.43% 0 Yes 5 1 Yes 0% 0% L4201 East Lindsey Partnership Housing 22 5111 0.43% 1 Yes 5 2 0% 50% LH1985 East Midlands Housing Association Limited 58 4923 1.18% 1 Yes 5 3 Yes 66% 33% LH2833 East Thames Housing Association Limited 248 8689 2.85% 10 Yes 5 4 Yes 75% 25% L4140 Eden Housing Association Limited 7 1488 0.47% 1 Yes 5 3 Yes 33% 33% LH3940 Ekaya Housing Association Limited 4 240 1.67% 0 Yes 5 2 0% 0% C3609 Eldonian Community Based Housing Association Ltd Yes LH0977 Elim Housing Association Limited 4 305 1.31% 0 Yes 2 0 LH0084 Endeavour Housing Association Limited 12 1300 0.92% 0 Yes 5 2 Yes 0% 50% L4004 English Rural Housing Association Limited 1 313 0.32% 0 Yes 1 1 0% 100% LH2200 Enterprise 5 Housing Association Limited 3 Yes 0% 33% L1236 Family HA (Birkenhead & Wirral) Limited 1 376 0.27% 0 Yes 5 2 Declined 50% 50% LH0131 Family Housing Association (Manchester) Limited 2 0% 0% LH0413 FCH Housing and Care 2 Yes 0% 100% L2195 Five Villages Home Association Limited 3 51 5.88% 0 Yes 3 0 L0087 Forest Housing Association Limited 0 122 0.00% 0 Yes 0 0 L4168 Fortunegate Community Housing Limited 105 1459 7.20% 1 Yes 5 4 25% 25% LH4120 Fosseway Housing Association Limited 26 4147 0.63% 1 Yes 5 3 0% 0% L4204 Frontis Homes Limited 0 742 0.00% 0 Yes 5 0 LH2213 Fry Housing Trust 3 208 1.44% 0 Yes 0 0 Copyright © CPA 2002 page 80
  • 81. Appendix F: Landlords involved in this project L4127 Girls Friendly Society in England & Wales 1 100% 100% LH1831 Granta Housing Society Limited 3 Yes 0% 33% LH0870 Gravesend Churches Housing Association Limited A0846 Great Hospital LH2066 Griffin Housing Association Limited 0 360 0.00% 0 Yes 0 0 Yes LH0971 Guildford Sunset Homes 6 1535 0.39% Yes 5 2 0% 0% L1410 Haig Homes 2 1198 0.17% 0 Yes 5 3 0% 0% LH3941 Hallmark Community Housing Association Limited 0 576 0.00% 0 Yes 5 4 0% 0% L0523 Harden Housing Association (Midlands) Limited 5 0% 0% L0293 Harewood Housing Society Limited 1 0% 0% L0860 Harlington Rectory Housing Association Limited LH1004 Havelok Housing Association Limited 9 14735 0.06% 0 Yes 5 3 33% 33% C3963 Hazel Housing Co-operative Limited L2179 Hightown Praetorian Housing Association Limited 3 Yes 0% 0% LH4176 Home Housing Association Limited 42 24731 0.17% 1 Yes 5 3 0% 0% H0995 Hornsey (North London) YMCA Housing Society Ltd 25 158 15.82% 0 Yes 4 2 100% 100% A1571 Hospital of St John the Baptist and Others 1 86 1.16% 0 Yes 0 0 L2027 Housing Partnership (London) Limited 170 859 19.79% 0 Yes 5 4 Yes 100% 100% LH4253 Huntingdonshire Housing Partnership Limited 8 6748 0.12% 0 Yes 5 2 Yes 0% 0% LH3829 Innisfree Housing Association Limited 5 350 1.43% 0 Yes 5 2 Yes 0% 0% H1313 Irish Centre Housing Limited 6 340 1.76% 0 Yes 3 0 L0457 Islington and Shoreditch Housing Association Ltd 16 1038 1.54% 0 Yes 5 3 Yes 0% 0% L0288 Jephson Housing Association Limited 58 10299 0.56% 1 Yes 5 4 Yes 50% 0% L1688 John Grooms Housing Association 0 1057 0.00% 0 Yes 5 1 Yes 100% 100% L1965 Keniston Housing Association Limited 6 741 0.81% 0 Yes 5 1 0% 0% L0993 King Street Housing Society Limited 2 533 0.38% 0 Yes 2 2 0% 0% LH4078 Kingston YMCA 6 120 5.00% 1 Yes 4 1 100% 0% L3930 Knightstone Community Homes Limited 0 183 0.00% 0 Yes 0 0 L0291 Knightstone Housing Association Limited 1 183 0.55% 0 Yes 5 5 20% 0% L4195 Leasowe Community Homes 3 1079 0.28% 1 Yes 5 1 0% 0% LH0704 Leeds and Yorkshire Housing Association Ltd 10 1051 0.95% 0 Yes 5 4 0% 0% LH0714 Leicester Newarke Housing Association Limited 8 482 1.66% 0 Yes 5 1 0% 0% L1700 Liver Housing Association Limited 2 12161 0.02% 0 Yes 5 4 0% 0% C0508 Lodge Lane East Co-operative Housing Limited L4059 MacIntyre Housing Association Limited 0 137 0.00% 0 Yes 0 0 L1423 Manchester and District Housing Association Ltd 175 8123 2.15% 1 Yes 5 5 20% 0% Copyright © CPA 2002 page 81
  • 82. Appendix F: Landlords involved in this project L3736 Manningham Housing Association Limited 2 50% 50% Maritime Housing Association 1 0% 100% L3900 Medina Housing Association Limited Yes L1542 Minster General Housing Association Limited 20 1743 1.15% 0 Yes 5 3 Yes 0% 0% L0386 Moat Housing Society Limited 153 4300 3.56% 1 Yes 5 2 50% 50% L0975 Mosscare Housing Limited 24 2448 0.98% 0 Yes 5 2 50% 0% H2030 Nacro Community Enterprises Limited 77 449 17.15% 0 Yes 5 1 0% 0% L0525 Network Housing Association Limited 1 0% 0% LH4267 New Charter Housing (South) Limited 1118 16181 6.91% 0 Yes 5 4 Yes 75% 75% LH4308 New Dimensions Group Limited Yes LH2270 New Era Housing Association Limited LH0242 New Islington and Hackney Housing Association 288 5233 5.50% 2 Yes 5 2 50% 50% L4238 Newcastle-under-Lyme Limited 75 9690 0.77% 0 Yes 5 1 0% 0% L0006 Newlon Housing Trust L1229 North Cheshire Housing Association 43 3887 1.11% 0 Yes 5 2 Yes 0% 50% LH3859 North London Muslim Housing Association Limited 1 0% 0% SL3152 Northcote Housing Association Limited 12 2000 0.60% 0 Yes 5 2 0% 0% Northern Counties Housing Association Yes A0485 Norwich Consolidated Charities 0 58 0.00% 0 Yes 0 0 L0035 Notting Hill Housing Trust 320 17466 1.83% 10 Yes 5 3 Yes 0% 33% L4221 Old Ford Housing Association 76 1552 4.90% 0 Yes 5 2 50% 50% L4123 Orbit First Step Housing Association Limited 6 2600 0.23% 1 Yes 5 2 Yes 100% 100% L0847 Palatine Home Ownership Limited A4020 Pickering and Ferens Homes 9 1122 0.80% 1 Yes 5 3 33% 0% L1001 Pierhead Housing Association Limited 1 0% A0822 Pilgrim Homes 2 31 6.45% 0 Yes 0 0 L1393 Pinecroft Housing Association (SE) Limited 0 174 0.00% 0 Yes 0 0 L4154 Pollards Hill Housing Association Limited 18 960 1.88% 0 Yes 5 2 0% 0% LH4188 Progress Care Housing Association Limited 50 3306 1.51% 1 Yes 5 2 Yes 0% 0% L2159 Radcliffe Housing Society Limited 11 263 4.18% 0 Yes 5 4 75% 75% L1556 Raglan Housing Association Limited 192 9022 2.13% 2 Yes 5 3 0% 0% A1855 Railway Housing Association and Benefit Fund LH4248 Restormel Housing Trust Limited 2 3440 0.06% 0 Yes 5 5 20% 20% L2033 Rodney Housing Association Limited 2 1024 0.20% 0 Yes 5 0 LH4026 Rosebery Housing Association Limited 20 2050 0.98% 2 Yes 5 1 0% 0% L1297 Selhal Community Housing Limited 13 2500 0.52% 0 Yes 5 3 0% 0% Copyright © CPA 2002 page 82
  • 83. Appendix F: Landlords involved in this project L4064 Shaftesbury Housing 121 7414 1.63% 0 Yes 5 1 0% 0% LH4035 SHAL Housing Limited 2 578 0.35% 0 Yes 1 1 100% 100% C3236 Shearwood Housing Co-operative Limited LH0050 Shepherds Bush Housing Association Limited 170 2812 6.05% 1 Yes 2 1 0% 0% L1505 Shropshire Rural Housing Association Limited 4 181 2.21% 0 Yes 4 3 Yes 33% 33% L3915 Signpost Housing Association Limited 2 9100 0.02% 2 Yes 5 3 0% 0% L2349 Solon Co-operative Housing Services Limited 9 817 1.10% 0 Yes 0 0 LH3253 Solon Wandsworth Housing Association Limited L4230 South Liverpool Housing Limited 2 Yes 0% 0% LH4200 South Somerset Homes Limited 29 8670 0.33% 1 Yes 5 1 Yes 0% 0% LH4121 South Staffordshire Housing Association Limited 59 5340 1.10% 0 Yes 5 2 0% 0% LH3898 South Wight Housing Association Limited 4 Yes 25% 50% L1829 Southdown Housing Association Limited 2 281 0.71% 0 Yes 5 2 100% 100% LH1662 Southern Home Ownership 14 4051 0.35% 2 Yes 5 2 0% 50% L0899 Spenborough Flower Fund Homes Limited 8 52 15.38% 0 Yes 5 2 100% 100% C3022 Spitalfields Housing Association Limited 12 408 2.94% 0 Yes 5 1 0% 0% LH0121 Springboard Housing Association Limited 150 6500 2.31% 0 Yes 5 2 50% 0% H3158 St Annes Shelter and Housing Action 3 250 1.20% 0 Yes 3 0 LH1422 Stonham Housing Association Limited 167 4118 4.06% 0 Yes 5 1 100% 0% C2436 Stroud Green Housing Co-operative Limited 1 64 1.56% 0 Yes 5 3 0% 0% L1659 Suffolk Housing Society Limited 15 1200 1.25% 0 Yes 5 2 0% 0% L1872 Tees Valley Housing Group Limited 1 0% 0% L0514 Thames Valley Housing Association Limited 20 4153 0.48% 0 Yes 5 3 0% 33% H0827 The Abbeyfield Amersham Society Limited 0 40 0.00% 0 Yes 0 0 H0227 The Abbeyfield Bradford Society Limited 0 40 0.00% 0 Yes 0 0 H0315 The Abbeyfield Bristol Society Limited 1 40 2.50% 1 Yes 0 0 Yes H2668 The Abbeyfield Coventry Society Limited 0 77 0.00% 0 Yes 0 0 H2854 The Abbeyfield Hoylake and West Kirby Society Ltd 0 54 0.00% 0 Yes 0 0 H0374 The Abbeyfield Portsmouth Society Limited The Abbeyfield Society Yes The Almshouse Association Yes A0099 The Almshouse Charity of Arthur Winsley and Others LH0526 The Enham Trust 0 171 0.00% 0 Yes 0 0 A0489 The French Hospital 8 54 14.81% 0 Yes 5 5 80% 80% L2441 The Guinness Housing Association Limited 260 20300 1.28% 1 Yes 5 1 0% 0% LH0682 The Hampshire Voluntary Housing Society 12 1199 1.00% 0 Yes 5 3 33% 33% Copyright © CPA 2002 page 83
  • 84. Appendix F: Landlords involved in this project L0266 The Industrial Dwellings Society (1885) Ltd H2025 The Richmond Fellowship Limited L2285 The Ridings Housing Association Limited 64 2077 3.08% 1 Yes 5 2 Yes 0% 0% L1218 The Square Building Trust Limited 0 90 0.00% 0 Yes 0 0 H1011 The Trustees & Members of the Watford & District 0 203 0.00% 0 Yes 5 0 YMCA L3417 The Villages Housing Association Limited 3 1870 0.16% 0 Yes 5 4 0% 0% SL3364 Tower Homes Limited LH3958 Town and Country Housing Group 12 6118 0.20% 0 Yes 5 4 0% 0% L0425 Toynbee Housing Association Limited 12 2486 0.48% 2 Yes 5 4 25% 75% A0349 Trustees of the Liversage Charity H2509 Turning Point 13 56 23.21% 0 Yes 5 0 L3886 Twynham Housing Association Limited LH2967 Ujima Housing Association Limited LH4061 Vale Housing Association Limited 10 5200 0.19% 1 Yes 5 3 0% 66% L1227 Venture Housing Association Limited 21 1250 1.68% 1 Yes 5 1 0% 0% LH4231 Villages Community Housing Association Limited 3 154 1.95% 0 Yes 2 0 L4143 Waltham Forest CBHA 3 Yes 0% 0% L0518 Warrington Housing Association Limited 17 1112 1.53% 0 Yes 5 3 66% 66% L3881 Warwickshire Rural Housing Association Limited Yes C3069 Wearmouth Housing Co-operative Limited 6 67 8.96% 0 Yes 5 3 33% 33% L0252 West Pennine Housing Association Limited 22 2506 0.88% 0 Yes 5 2 50% 50% L3629 West Somerset Rural Housing Association Limited L0259 Westfield Housing Association Limited 10 445 2.25% 0 Yes 5 3 33% 33% LH0052 William Sutton Trust 168 15800 1.06% 1 Yes 5 4 0% 0% L1971 Windmill Housing Association Ltd 0 650 0.00% 0 Yes 5 4 0% 0% L1548 Women's Pioneer Housing Limited 3 1100 0.27% 0 Yes 5 1 0% 0% L1665 Worcestershire Housing Association Limited 16 2200 0.73% 0 Yes 5 2 50% 50% LH1704 Workington and Carlisle Diocesan Housing Ass Ltd L1019 York Housing Association Limited 3 580 0.52% 0 Yes 5 4 50% 25% LH3929 Yorkshire Community Housing Limited 88 9073 0.97% 0 Yes 5 1 0% 0% 5983 409309 64 612 334 RSL not stated 4 25% 25% 338 All satisfied complainants said they were satisfied ONLY AFTER going to Head Office, MP or Councillor. Copyright © CPA 2002 page 84
  • 85. Appendix F: Landlords involved in this project Some satisfied complainants said they were satisfied ONLY AFTER going to Head Office, MP or Councillor. Top 30 for recording complaints 3414 71924 4.75% 131 63 51% 43% Remaining 122 respondents 2569 337385 0.76% 481 275 17% 21% Satisfied without going elsewhere for help 49% Satisfied without going elsewhere for help 13% Copyright © CPA 2002 page 85
  • 86. Appendix G (a): Residents Questionnaire APPENDIX G: CONSULTATION QUESTIONNAIRES The following pages contain the two questionnaires used in our first survey of RSLs and tenant complainants. Appendix G (a) contains the questionnaire sent by RSLs to tenant complainants, and appendix G (b) contains the questionnaire sent to the sample of RSLs Copyright © CPA 2002 page 86
  • 87. Appendix G (a): Residents Questionnaire Strictly confidential and protected under the Data Protection Act 1998 When answering these questions, please would you think about the last complaint you made to your landlord. 1 Who is your landlord? 2 What was the reason for your complaint? (Please tick as many as apply) DAY-TO-DAY REPAIRS HARASSMENT/NUISANCE Major repairs Cleanliness of estate Communal repairs Service charge Arrears/rent account Parking Transfer/re-housing Other (please tell us) ……………………………………………………………………………………………………………………………………………. 3 What did you want your landlord to do to put things right? (Please tick as many as apply) APOLOGISE TO YOU PROVIDE A SERVICE TO YOU Give you some information (i.e. carry out a repair) Explain a decision Improve procedures Refund money owed to you Change a policy Pay compensation Improve customer care Other (please tell us) ……………………………………………………………………………………………………………………………………………. 4 How did you complain to your landlord? (Please tick as many as apply) IN PERSON BY PHONE In writing Using a complaint form By email Using a web site form By fax By Minicom or TypeTalk In Braille In your language Other (please tell us) ……………………………………………………………………………………………………………………………………………. 5 How easy did you find the process of making your complaint? (Please tick one only) Very easy Easy Neither easy nor difficult Difficult Very difficult Copyright © CPA 2002 page 87
  • 88. Appendix G (a): Residents Questionnaire 6 How would you prefer to complain? (Please tick as many as apply) IN PERSON BY PHONE In writing Using a complaint form By email Using a web site form By fax By Minicom or TypeTalk In Braille In your language Other (please tell us) ……………………………………………………………………………………………………………………………………………. 7 How satisfied were you with the way your landlord handled your complaint? (Please tick one only) Very satisfied Satisfied Neither satisfied or dissatisfied Dissatisfied Very dissatisfied 8 How satisfied were you with the outcome of your complaint? (Please tick one only) Very satisfied Satisfied Neither satisfied or dissatisfied Dissatisfied Very dissatisfied 9 If you were dissatisfied or very dissatisfied with either of the above, why was this: (Please tick as many as apply) They did not accept my complaint No or little action taken THE DELAY IN ACTING THE PROCESS Didn’t talk to you about the complaint No compensation Not enough compensation Lack of alternative remedies Poor explanation given Lack of follow-up action NO FEEDBACK ON ACTION TAKEN UNHELPFUL ATTITUDE OF STAFF STILL ONGOING Other (please tell us) ……………………………………………………………………………………………………………………………………………. 10 What help would you have liked when making your complaint? (Please tick as many as apply) A member of staff to help you make the complaint Another tenant to help you make the complaint Someone independent to help you make the complaint A leaflet on how to make a complaint A leaflet explaining the service you complained about Information in your language Information in large print Information on audio-cassette or video or CD-ROM Information on a web site Other (please tell us) ……………………………………………………………………………………………………………………………………………. Copyright © CPA 2002 page 88
  • 89. Appendix G (a): Residents Questionnaire 11 What did you like about the way your landlord handled the complaint? (Please tick as many as apply) A SPEEDY COMPLAINT PROCEDURE A CLEAR COMPLAINT PROCEDURE A fair complaint procedure They listened straight away Quick reply to your complaint Clear reply The outcome or result An apology Helpful attitude of staff NOTHING Other (please tell us) ……………………………………………………………………………………………………………………………………………. 12 What didn’t you like about the way your landlord handled the complaint? (Please tick as many as apply) A long, drawn out complaint procedure An unclear complaint procedure An unfair complaint procedure They took too long to listen Late reply to your complaint Unclear reply THE OUTCOME OR RESULT NO APOLOGY UNHELPFUL ATTITUDE OF STAFF NOTHING Other (please tell us) ……………………………………………………………………………………………………………………………………………. 13 Did you know you could complain to: Independent Housing Ombudsman? ..and did you complain to anyone else? E.g. Your local council? Your local councillor? Your Member of Parliament? (Please tick as many as apply) 14 Where did you find information about how to make a complaint? (Please tick as many as apply) Member of staff Tenants & Residents Association Complaints booklet or poster Councillor or Member of Parliament Independent Housing Ombudsman Other (please tell us) ……………………………………………………………………………………………………………………………………………. 15 Do you have any suggestions on how your landlord can improve the way they deal with complaints? ……………………………………………………………………………………………………………………………………………. ……………………………………………………………………………………………………………………………………………. ……………………………………………………………………………………………………………………………………………. ……………………………………………………………………………………………………………………………………………. ……………………………………………………………………………………………………………………………………………. Copyright © CPA 2002 page 89
  • 90. Appendix G (a): Residents Questionnaire Helpline If you would like help with filling in this questionnaire, you can ring 01953 717 978. Leave your name, phone number and a time when you would like to be called and we will call you back. Please put the completed questionnaire in the enclosed envelope (you do not need a stamp) and return by 14 September 2001 to: Michael Hill 35 Lincoln Court London Road Enfield EN2 6EW Thank you for your help and time in completing this questionnaire for our survey. The prize draw will be made on 22 October 2001. ARE YOU WILLING TO SUPPLY US WITH YOUR DETAILS? YOUR NAME: YOUR ADDRESS: POST CODE: YOUR PHONE NUMBER: Your e-mail address if you have one: WOULD YOU BE WILLING FOR US TO PHONE YOU TO TALK ABOUT YOUR EXPERIENCE OF YOUR LANDLORD’S COMPLAINT PROCEDURE? YES, I WOULD BE WILLING TO TALK TO YOU ON THE PHONE. Would you be willing to take part in a local discussion group to talk about complaints? Yes, I would like to part in a local discussion group. YOUR CHANCE TO WIN £50!! WOULD YOU LIKE US TO ENTER YOUR NAME IN TO OUR PRIZE DRAW? YOU COULD WIN A CHEQUE FOR £50. YES, I WOULD LIKE YOU ENTER MY DETAILS IN TO YOUR PRIZE DRAW Copyright © CPA 2002 page 90
  • 91. Appendix G (a): Residents Questionnaire CONFIDENTIAL You do not need to complete this section but by answering the following questions, you will help us to make sure that our survey fairly represents the views of tenants of Registered Social Landlords. To which of these groups do you consider you belong: White British Irish Any other White background (please tick and write in) Mixed White and Black Caribbean White and Black African White and Asian Any other mixed background (please tick and write in) ………………………….. Asian or Asian British Indian Pakistani Bangladeshi Any other Asian background (please tick and write in) ………………………….. Black or Black British Caribbean African Any other Black background (please tick and write in) ………………………….. Chinese Other (please tick and write in) ………………………….. Are you: male? female? Do you have any long-term illness, health problem or disability that limits your daily activities or the work you can do? Yes No Does anyone in your household use a wheelchair? Yes No Are you: Under 21 21-30 31-45 46-60 Over 60 Copyright © CPA 2002 page 91
  • 92. Appendix G (b): Landlord Questionnaire The following is the questionnaire to RSLs. Copyright © CPA 2002 page 92
  • 93. Appendix G (b): Landlord Questionnaire Your organisation 1. What category of RSL would your organisation be classed as? Large RSL (more than 250 properties) ? Small RSL (250 or less properties) ? LSVT ? Community based RSL ? Black and Minority Ethnic RSL ? Rural RSL ? Specialist RSL ? Other (Please tell us) ______________________________________ 2. How many rented properties do you own or manage? ______________ 3. How many leasehold properties do you manage? ______________ Your policy and procedures 4. What is your definition of a complaint? "Any expression of dissatisfaction whether justified or not" ? "Any expression of dissatisfaction requiring a response" ? Other (please tell us) ___________________________________ ___________________________________ ___________________________________ ___________________________________ ____________________ 5. Do you have a documented complaints or customer feedback policy? Yes ? No ? 6. Who will you accept a complaint from? (please tick all that apply) Tenant ? Leaseholder ? Applicant for housing ? Tenant's group ? Member of the public affected by your work, such as a neighbour of one of your ? properties An organisation affected by your work, such a private landlord ? Other (please tell us) ________________________________ 7. How many stages are there to your complaint procedure? ________________ 8. Please identify the position of the person who is responsible for responding to a complaint at each stage of your complaint procedure: Stage 1 ________________________________________ Stage 2 ________________________________________ Stage 3 ________________________________________ Stage 4 ________________________________________ Further (please tell us) ________________________________________ Copyright © CPA 2002 page 93
  • 94. Appendix G (b): Landlord Questionnaire 9. When did you last review your complaints or customer feedback policy? Less than 6 months ago ? Between 6 and 12 months ago ? Between one and two years ago ? More than two years ago ? Never ? 10. When did you last produce written complaint handling guidance for your employees? Less than 6 months ago ? Between 6 to 12 months ago ? Between one and two years ago ? More than two years ago ? No written guidance ? 12. How many staff received complaint handling training in the last year? ________________ 13. Of these staff, how many handle complaints? ________________ 14. How many complaints did you receive between 1 April 2000 and 31 March 2001? ________________ 15. How many of these reached each stage of your complaint procedure? Stage 1 __________ Stage 2 __________ Stage 3 __________ Stage 4 __________ Other __________ Ombudsman __________ How are you doing in meeting your standards? 16. What is your time limit for acknowledging receipt of a complaint? ______________ 17. What are your time limits for: Responding to a complaint at stage 1 _________ Responding to a complaint at stage 2 _________ Responding to a complaint at stage 3 _________ Holding a complaints panel hearing _________ Other _______________________________________________ 18. What was your performance in meeting those time limits? (Please tell us as a percentage of total number of complaints received. For example, Acknowledging receipt... 85%) Acknowledging receipt of complaints _________ Responding to complaints at stage 1 _________ Responding to complaints at stage 2 _________ Responding to complaints at stage 3 _________ Holding complaints panel hearings _________ Copyright © CPA 2002 page 94
  • 95. Appendix G (b): Landlord Questionnaire Outcomes 19. What percentage of complaints were upheld or justified during 2000/2001? ______________ 20. What percentage of these complaints were upheld or justified at each stage of your complaint procedure? Stage 1 __________ Stage 2 __________ Stage 3 __________ Stage 4 __________ Ombudsman __________ 21. How many complainants received redress during 2000/2001? A service provided (for example, rehousing or a repair carried out) ___________ Information provided (for example, a rent statement) ___________ Procedures reviewed ___________ Policy reviewed ___________ Training for staff ___________ Other (please tell us) _______________________________________________ 22. How many complainants received compensation during 2000/2001? ______________ 23. What was the average amount of compensation paid per complaint during 2000/2001? Complaint procedure __________ Compensation policy (if separate from your complaint procedure) __________ Ombudsman __________ Legal proceedings (for example, disrepair cases) __________ 24. Did you survey the views of customers who complained during 2000/2001? Yes ? No ? 25. If yes, what percentage were satisfied with your complaints handling? ________________ 26. What percentage were dissatisfied with your complaints handling? ________________ 27. What action, if any, was taken as a result of this dissatisfaction? _______________________________________________________ _______________________________________________________ Access and publicity 28. How can customers complain to you at stage 1, stage 2 and so on? (tick all that apply) Stage 1 Stage 2 Stage 3 Stage 4 In person ? ? ? ? Copyright © CPA 2002 page 95
  • 96. Appendix G (b): Landlord Questionnaire Telephone ? ? ? ? In writing ? ? ? ? Complaint form ? ? ? ? Email ? ? ? ? Web form ? ? ? ? Minicom ? ? ? ? Braille ? ? ? ? Fax ? ? ? ? Any language ? ? ? ? Other (please tell us) ____________________________________________ 29. How do you publicise your complaints policy? (tick all that apply) Leaflets ? Posters ? Tenants Handbook ? Information on rent statements ? Information in newsletter/magazine ? Web site ? Other (please tell us) ________________________________ 30. How do you inform complainants of their right to have a decision reviewed? (tick all that apply) Complaints booklet ? If the complainant contacts a member of staff ? Telling them at end of response ? Telling them when acknowledging receipt of the complaint ? Other (please tell us) ________________________________ 31. How do you inform complainants of their right to complain to the Independent Housing Ombudsman? Complaints booklet ? If the complainant contacts a member of staff ? Telling them at the end of your final response to a complaint ? Telling them when acknowledging receipt of a request for a panel ? hearing Other (please tell us) ________________________________ Review and Learning 32. What complaint information do you report to your board and management teams? (tick all that apply) Service Managers Senior Board Management Type of complaint ? ? ? Service ? ? ? Medium of complaint ? ? ? Outcome ? ? ? Remedy ? ? ? Escalation ? ? ? Response performance ? ? ? Compensation ? ? ? 33. How regularly do you report complaint information to your board and management teams? Service Managers Senior Board Management Weekly ? ? ? Monthly ? ? ? Quarterly ? ? ? Annually ? ? ? Copyright © CPA 2002 page 96
  • 97. Appendix G (b): Landlord Questionnaire 34. Does the information you report include all complaints? All complaints including those resolved immediately ? All complaints except those resolved immediately ? Complaints at stage 2 or higher ? Complaints at stage 3 or higher ? Other (please tell us) ________________________________ 35. How do you record information about complaints? Paper-based system ? In-house database ? Complaint management software ? Other (please tell us) ________________________________ 36. Do you publish information on the operation of your complaints policy? Yes (separate report for customers) ? Yes (part of your annual report) ? No ? Other (please tell us) ________________________________ 37. Is there a reason why information is not published? __________________________________________________________________ __________________________________________________________________ 38. When did you last carry out a review of the performance of your complaint management processes? Less than 1 year ago ? Between 1 and 2 years ago ? More than 2 years ago ? Never ? 39. What did the review show? __________________________________________________________________ __________________________________________________________________ 40. What action did you take? __________________________________________________________________ __________________________________________________________________ Copyright © CPA 2002 page 97
  • 98. Appendix G (b): Landlord Questionnaire Your name ____________________________________________________________________________ Your job title ____________________________________________________________________________ Your organisation ____________________________________________________________________________ Your telephone number ________________________________________ Your email address ____________________________________________________________________________ Please can you tell us how many of your recent complainants were forwarded our "tenant complainant" questionnaire? __________ If you experience any problems completing this questionnaire or have any comments, please phone our helpline on 01953 717 978. Please return your completed questionnaire in the reply paid envelope by 14 September 2001 to: Michael Hill 35 Lincoln Court London Road Enfield EN2 6EW or fax to: 0870 1343251 Thank you for your co-operation with this important project. Copyright © CPA 2002 page 98
  • 99. APPENDIX G: CONSULTATION QUESTIONNAIRES Opinion Survey We would like you to give us your own views on the Best Practice Guidelines to help us assist landlords to provide a high-quality complaints service to all of their customers. Please answer each question by ticking the appropriate box. Good Okay Bad idea idea Not Sure idea Landlords should not have more than 3 stages of complaint. Landlords should usually issue a final response to a complaint within 8 weeks of the resident’s first complaint. Landlords should make sure that whoever investigates complaints at the final stage is trained in putting things right for the customer. As an alternative to investigation at the final stage, landlords should give customers an opportunity to present their complaint in person to a panel of board or committee members. If you have said that any of these statements were good or bad ideas, can you tell us why? Please let us know about anything you think we should change in our best practice guidance… Please let us know about anything you think we should add to our best practice guidance… Copyright © CPA 2002 page 99
  • 100. APPENDIX G: CONSULTATION QUESTIONNAIRES Is anything else you would like to tell us about our best practice guidance? Please send this form (you should use the enclosed envelope) to: Michael Hill 35 Lincoln Court London Road Enfield EN2 6EW Please make sure that you return your completed survey form to us by 25 February 2002 Copyright © CPA 2002 page 100
  • 101. GLOSSARY OF TERMS GLOSSARY OF TERMS Complaint: “Any expression of dissatisfaction (with the organisation) whether justified or not” Complaints officer: An employee who has overall responsibility and authority for the day-to-day management of the procedure. This person may also be called the Complaints Manager, Customer Relations Manager or Customer Feedback Manager. The role may be full-time in a large organisation or one role of several for someone in a small organisation. Complaints Panel: A panel of three persons who are independent of the service provider. Panel members should be representative of the landlord’s residents and may include a residents’ representative and board or management committee members. CMSAS 86:2000: The Complaint Management Scheme Assessment Standard is the accredited version of the complaint management standard (BS8600). The standard can be linked to schemes such as ISO9002, EFQM, Charter Mark and others. Escalation process: An escalation process is a clear process for progressing a complaint where a customer is dissatisfied with a response to their complaint. The process should be clearly set out and understandable by customers and employees. A typical escalation process would be: Step 1: Complaint handled by any employee. Step 2: The customer or organisation escalates the complaint to a manager who arranges an investigation. Step 3: The customer or organisation escalates the complaint for review by a complaints panel. Step 4: The customer escalates the complaint for independent assessment by an Ombudsman. An escalation process should also set out criteria for ”fast tracking” a complaint. For example, where the organisation fails to respond to a complaint within a reasonable time limit. Remedies menu: A remedies menu sets out practical action that can be taken to put things right for a customer. A typical remedies menu would include: § Say sorry to the customer § Provide a service to the customer § Provide information to the customer § Review customer information (leaflets, poster and so on) § Review your working procedures § Request members to review a policy Copyright © CPA 2002 page 101
  • 102. GLOSSARY OF TERMS § Arrange employee training or guidance § Employee action § Pay compensation or give a refund Copyright © CPA 2002 page 102

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