Housing Ombudsman Complaint Handling Code: Self-assessment form

This self-assessment form should be completed by the complaints officer and it must be reviewed and approved by the landlord’s governing body at least annually.

Once approved, landlords must publish the self-assessment as part of the annual complaints performance and service improvement report on their website. The governing body’s response to the report must be published alongside this.

Landlords are required to complete the self-assessment in full and support all statements with evidence, with additional commentary as necessary.

We recognise that there may be a small number of circumstances where landlords are unable to meet the requirements, for example, if they do not have a website. In these circumstances, we expect landlords to deliver the intentions of the Code in an alternative way, for example by publishing information in a public area so that it is easily accessible.

Section 1 -Definition of a complaint

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
1.2	A complaint must be defined as: ‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the landlord, its own staff, or those acting on its behalf, affecting a resident or group of residents.’	Yes	In the policy on our website at 2.1.9 https://www.reading.gov.uk/contact-us/complaints/corporate-complaints-procedure/
1.3	A resident does not have to use the word ‘complaint’ for it to be treated as such. Whenever a resident expresses dissatisfaction landlords must give them the choice to make complaint. A complaint that is submitted via a third party or representative must be handled in line with the landlord’s complaints policy.	Yes	In the policy on our website at 2.1.9 https://www.reading.gov.uk/contact-us/complaints/corporate-complaints-procedure/	The word ‘complaint’ does not need to be used. We require consent to be given to accept a complaint from a third party.
1.4	Landlords must recognise the difference between a service request and a complaint. This must be set out in their complaints policy. A service request is a request from a resident to the landlord requiring action to be taken to put something right. Service requests are not complaints, but must be recorded, monitored and reviewed regularly.	Yes		Cases are triaged at first contact to distinguish between these
1.5	A complaint must be raised when the resident expresses dissatisfaction with the response to their service request, even if the handling of the service request remains ongoing. Landlords must not stop their efforts to address the service request if the resident complains.	Yes		Service Requests are handled separately and will not be impacted by the raising of a new complaint
1.6	An expression of dissatisfaction with services made through a survey is not defined as a complaint, though wherever possible, the person completing the survey should be made aware of how they can pursue a complaint if they wish to. Where landlords ask for wider feedback about their services, they also must provide details of how residents can complain.			Surveys for Tenants Satisfaction questionnaire are outsourced to NWA who complete these on our behalf, We don’t believe they inform respondents on every survey how to make a complaint, however we are confident if the were asked they would provide this information. We will ask them to inform all respondents now moving forward. Every communication to our residents has the info of how to complain and how to contact the ombudsmen.

Section 2 – Exclusions

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
2.1	Landlords must accept a complaint unless there is a valid reason not to do so. If landlords decide not to accept a complaint they must be able to evidence their reasoning. Each complaint must be considered on its own merits	Yes	In the policy on our website at 2.1.9 https://www.reading.gov.uk/contact-us/complaints/corporate-complaints-procedure/	This is accepted and is set out in the complaints process
2.2	A complaints policy must set out the circumstances in which a matter will not be considered as a complaint or escalated, and these circumstances must be fair and reasonable to residents. Acceptable exclusions include: The issue giving rise to the complaint occurred over twelve months ago. Legal proceedings have started. This is defined as details of the claim, such as the Claim Form and Particulars of Claim, having been filed at court. Matters that have previously been considered under the complaints policy.	Yes		Please see answer to 2.1
2.3	Landlords must accept complaints referred to them within 12 months of the issue occurring or the resident becoming aware of the issue, unless they are excluded on other grounds. Landlords must consider whether to apply discretion to accept complaints made outside this time limit where there are good reasons to do so.	Yes		Each case and circumstance is assessed on it’s on own merit following the policy
2.4	If a landlord decides not to accept a complaint, an explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman. If the Ombudsman does not agree that the exclusion has been fairly applied, the Ombudsman may tell the landlord to take on the complaint.	Yes		Please see answer to 2.1
2.5	Landlords must not take a blanket approach to excluding complaints; they must consider the individual circumstances of each complaint.	Yes		Each case and circumstance are assessed on it’s on own merit following the policy

Section 3 – Accessibility and awareness

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
3.1	Landlords must make it easy for residents to complain by providing different channels through which they can make a complaint. Landlords must consider their duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process.	Yes		We offer in person, telephone, in writing, by e-mail and digitally options to raise a complaint with us.  Equality and Diversity training is a mandatory training requirement for all staff which is monitored by senior managers.
3.2	Residents must be able to raise their complaints in any way and with any member of staff. All staff must be aware of the complaints process and be able to pass details of the complaint to the appropriate person within the landlord.	Yes		All staff are required to complete online complaint training. The complaints manager advises new starters at corporate induction events on the process that must be followed.
3.3	High volumes of complaints must not be seen as a negative, as they can be indicative of a well-publicised and accessible complaints process.  Low complaint volumes are potentially a sign that residents are unable to complain.	Yes		The council welcomes feedback through complaints. The complaints process is accessible to all our residents as per point 3.1.
3.4	Landlords must make their complaint policy available in a clear and accessible format for all residents. This will detail the two stage process, what will happen at each stage, and the timeframes for responding. The policy must also be published on the landlord’s website.	Yes		This is included in our policy which is on our website.
3.5	The policy must explain how the landlord will publicise details of the complaints policy, including information about the Ombudsman and this Code.	Yes		We are updating our policy for this to be included.
3.6	Landlords must give residents the opportunity to have a representative deal with their complaint on their behalf, and to be represented or accompanied at any meeting with the landlord.	Yes		We are in the process of updating our policy for this to be included, however if residents require an advocate we sign-post them to advocacy providers in the voluntary sector.
3.7	Landlords must provide residents with information on their right to access the Ombudsman service and how the individual can engage with the Ombudsman about their complaint.	Yes		We provide this information to the resident when acknowledging their complaint in writing

Section 4 – Complaint handling staff

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
4.1	Landlords must have a person or team assigned to take responsibility for complaint handling, including liaison with the Ombudsman and ensuring complaints are reported to the governing body (or equivalent). This Code will refer to that person or team as the ‘complaints officer’. This role may be in addition to other duties.	Yes		We have a dedicated team called the ‘Customer Relations Team (CRT)’ that also includes the link officer to the Ombudsman.
4.2	The complaints officer must have access to staff at all levels to facilitate the prompt resolution of complaints. They must also have the authority and autonomy to act to resolve disputes promptly and fairly.	Yes		The designated Complaints Manager reports to a member of the Corporate Management team. The Customer Relations Manager reports to the Complaints Manager, both attend directorate management meetings and lead member briefings.
4.3	Landlords are expected to prioritise complaint handling and a culture of learning from complaints. All relevant staff must be suitably trained in the importance of complaint handling. It is important that complaints are seen as a core service and must be resourced to handle complaints effectively	Yes		Please refer to point 4.1 and 3.2 as we have a dedicated team for managing complaints. Quarterly learning from complaints reports are shared with DMT and the lead councillor. Complaint handling training is undertaken by staff who manage and respond to complaints.

Section 5 – Complaint handling process

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
5.1	Landlords must have a single policy in place for dealing with complaints covered by this Code. Residents must not be treated differently if they complain.	Yes	In the policy on our website at 2.1.9 https://www.reading.gov.uk/contact-us/complaints/corporate-complaints-procedure/	A separate policy is on our website for complaint handling, all residents are treated equally, and complaints are welcomed and inform service improvements and training requirements
5.2	The early and local resolution of issues between landlords and residents is key to effective complaint handling. It is not appropriate to have extra named stages (such as ‘stage 0’ or ‘informal complaint’) as this causes unnecessary confusion.	Yes		The complaints process is two stages. Stage 1 and stage 2 is followed in accordance with the Code.
5.3	A process with more than two stages is not acceptable under any circumstances as this will make the complaint process unduly long and delay access to the Ombudsman.	Yes		Please see answer to 5.2.
5.4	Where a landlord’s complaint response is handled by a third party (e.g. a contractor or independent adjudicator) at any stage, it must form part of the two stage complaints process set out in this Code. Residents must not be expected to go through two complaints processes.	Yes		The Council takes responsibility for leading on the complaint investigation and as part of this contractors or 3rd parties are consulted.
5.5	Landlords are responsible for ensuring that any third parties handle complaints in line with the Code.	Yes		Please see response for 5.4.
5.6	When a complaint is logged at Stage 1 or escalated to Stage 2, landlords must set out their understanding of the complaint and the outcomes the resident is seeking. The Code will refer to this as “the complaint definition”. If any aspect of the complaint is unclear, the resident must be asked for clarification.	Yes		Investigators are required to speak to the resident to clarify their complaint as part of the stage 1 and stage 2 process.
5.7	When a complaint is acknowledged at either stage, landlords must be clear which aspects of the complaint they are, and are not, responsible for and clarify any areas where this is not clear.	Yes		Where this is required the Customer Relations Team ensures the acknowledgment is clear as to what is going to be investigated and what is not.
5.8	At each stage of the complaints process, complaint handlers must:   a. deal with complaints on their    merits, act independently, and     have an open mind;  b.  give the resident a fair chance to set out their position;   c. take measures to address any actual or perceived conflict of             interest; and   d. consider all relevant information and evidence carefully.	Yes		The Customer Relations Team is independent of the Housing Service. The investigating officer is required to speak to the resident as part of the investigation. The Customer Relations Team review each case prior to allocation for investigation to ensure any conflicts of interest are considered to ensure an impartial investigation. Same as point b.
5.9	Where a response to a complaint will fall outside the timescales set out in this Code, the landlord must agree with the resident suitable intervals for keeping them informed about their complaint.	Yes		This is included in our policy
5.10	Landlords must make reasonable adjustments for residents where appropriate under the Equality Act 2010. Landlords must keep a record of any reasonable adjustments agreed, as well as a record of any disabilities a resident has disclosed. Any agreed reasonable adjustments must be kept under active review.	Yes		All staff complete Diversity and Equality training. All reasonable adjustments requested are highlighted by CRT to the Investigating Officer and is noted to that resident’s complaint file.
5.11	Landlords must not refuse to escalate a complaint through all stages of the complaints procedure unless it has valid reasons to do so. Landlords must clearly set out these reasons, and they must comply with the provisions set out in section 2 of this Code.	Yes		When a complaint is not escalated, the reasons for this are communicated to the resident and Ombudsman details supplied.
5.12	A full record must be kept of the complaint, and the outcomes at each stage. This must include the original complaint and the date received, all correspondence with the resident, correspondence with other parties, and any relevant supporting documentation such as reports or surveys.	Yes		All correspondence at each stage is saved in the resident’s complaint case file/case management system.
5.13	Landlords must have processes in place to ensure a complaint can be remedied at any stage of its complaints process. Landlords must ensure appropriate remedies can be provided at any stage of the complaints process without the need for escalation.	Yes		All officers will meet or have a telephone conversation with the resident to discuss remedies as part of their investigation process.
5.14	Landlords must have policies and procedures in place for managing unacceptable behaviour from residents and/or their representatives. Landlords must be able to evidence reasons for putting any restrictions in place and must keep restrictions under regular review.	Yes	Add link	The Council has a policy in place and all evidence is kept in a separate file. 6 monthly reviews are undertaken as part of the policy.
5.15	Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010.	Yes		This is set out in the policy

Section 6 – Complaints stages

Stage 1

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
6.1	Landlords must have processes in place to consider which complaints can be responded to as early as possible, and which require further investigation. Landlords must consider factors such as the complexity of the complaint and whether the resident is vulnerable or at risk. Most stage 1 complaints can be resolved promptly, and an explanation, apology or resolution provided to the resident.	Yes		The Council has a process in place. Advice will be provided to the investigating officer by the CRT when the complaint is received and reviewed.
6.2	Complaints must be acknowledged, defined and logged at stage 1 of the complaints procedure within five working days of the complaint being received.	Yes		This is written into the policy
6.3	Landlords must issue a full response to stage 1 complaints within 10 working days of the complaint being acknowledged.	Yes		This is written into the policy
6.4	Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 10 working days without good reason, and the reason(s) must be clearly explained to the resident.	Yes		In this scenario, the resident is contacted, and an extension is agreed with the resident, this is then noted on the complaint file/case management system
6.5	When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.	Yes		Details of the Ombudsman are provided when acknowledging, when extending a response due date and at all stages of the complaints process.
6.6	A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.	Yes		Complaint response is provided when the outcome has been investigated. Any actions outstanding are logged onto a tracker and followed to ensure they have taken place at the agreed date. The Housing service has staff dedicated to monitoring actions/learning from complaints who work closely with CRT and the Housing Management team
6.7	Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.	Yes	Templates are included	This is part of standard template that each officer must use when responding to a complaint. All responses are quality assured by the CRT prior to dispatch to the complainant.
6.8	Where residents raise additional complaints during the investigation, these must be incorporated into the stage 1 response if they are related and the stage 1 response has not been issued. Where the stage 1 response has been issued, the new issues are unrelated to the issues already being investigated or it would unreasonably delay the response, the new issues must be logged as a new complaint.	Yes		This is the process that we follow. CRT contact the investigating officer to advise of additional information/complaints by the resident.
6.9	Landlords must confirm the following in writing to the resident at the completion of stage 1 in clear, plain language:   a. the complaint stage;  b. the complaint definition; c. the decision on the complaint; d. the reasons for any decisions made;  e. the details of any remedy offered to put things right;  f. details of any outstanding actions; and  g. details of how to escalate the matter to stage 2 if the individual is not satisfied with the response.	Yes	As per the link at 6.7	Each of these points are in our standard templates that each officer uses when responding to a complaint.

Stage 2

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
6.10	If all or part of the complaint is not resolved to the resident’s satisfaction at stage 1, it must be progressed to stage 2 of the landlord’s procedure. Stage 2 is the landlord’s final response.	Yes		Stage 2 is part of our complaints policy
6.11	Requests for stage 2 must be acknowledged, defined and logged at stage 2 of the complaints procedure within five working days of the escalation request being received.	Yes		This is in our policy.
6.12	Residents must not be required to explain their reasons for requesting a stage 2 consideration. Landlords are expected to make reasonable efforts to understand why a resident remains unhappy as part of its stage 2 response.	Yes		All stage 2 requests are considered under the complaints process, we will contact the resident if it is unclear why a stage 2 has been requested and if possible, resolve without a stage 2 investigation.
6.13	The person considering the complaint at stage 2 must not be the same person that considered the complaint at stage 1.	Yes		A different/more senior officer is assigned for the stage 2 as per our policy.
6.14	Landlords must issue a final response to the stage 2 within 20 working days of the complaint being acknowledged.	Yes		This is the guidance in our policy
6.15	Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 20 working days without good reason, and the reason(s) must be clearly explained to the resident.			In this scenario the resident is contacted, and the extension is agreed with the resident
6.16	When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.			Details of the Ombudsman are provided when acknowledging, when extending a response due date and at all stages of the process.
6.17	A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.			See 6.6
6.18	Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.	Yes		This is included in our standard stage 2 response template used by officers.
6.19	Landlords must confirm the following in writing to the resident at the completion of stage 2 in clear, plain language: a. the complaint stage;   b. the complaint definition;  c. the decision on the complaint;  d. the reasons for any decisions made;  e. the details of any remedy offered to put things right;  f. details of any outstanding   actions; and  g. details of how to escalate the matter to the Ombudsman Service if the individual remains             dissatisfied.			This is included in our standard stage 2 response template used by officers.
6.20	Stage 2 is the landlord’s final response and must involve all suitable staff members needed to issue such a response.	Yes		Stage 2 investigators contact all parties that have been involved in the case.

Section 7 – Putting things right

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
7.1	Where something has gone wrong a landlord must acknowledge this and set out the actions it has already taken, or intends to take, to put things right. These can include:  Apologising;  Acknowledging where things have gone wrong;  Providing an explanation, assistance or reasons;  Taking action if there has been     delay;  Reconsidering or changing a    decision;  Amending a record or adding a correction or addendum;  Providing a financial remedy;  Changing policies, procedures or  practices.	Yes		This is done as part of the response and is quality checked by CRT for compliance
7.2	Any remedy offered must reflect the impact on the resident as a result of any fault identified.	Yes		We use the Ombudsman guidance when considering the impact on the resident.
7.3	The remedy offer must clearly set out what will happen and by when, in agreement with the resident where appropriate. Any remedy proposed must be followed through to completion.	Yes		This is part of our standard response when offering this to the resident
7.4	Landlords must take account of the guidance issued by the Ombudsman when deciding on appropriate remedies.	Yes		We use the Ombudsman guidance when considering remedies

Section 8 – Self-assessment, reporting and compliance

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
8.1	Landlords must produce an annual complaints performance and service improvement report for scrutiny and challenge, which must include:  a. the annual self-assessment against this Code to ensure their complaint handling policy remains in line with its requirements.  b. a qualitative and quantitative analysis of the landlord’s complaint handling performance. This must also include a summary of the types of complaints the landlord has refused to accept;  c. any findings of non-compliance with this Code by the Ombudsman;  d. the service improvements made as a result of the learning from complaints;  e. any annual report about the landlord’s performance from the Ombudsman; and  f. any other relevant reports or publications produced by the Ombudsman in relation to the work of the landlord.	Yes		Weekly/Quarterly and Annual reports are produced. These are taken to HCMT, DMT, CMT and LCB meetings. From April 2025 we will schedule the annual complaints report for scrutiny at a public meeting.
8.2	The annual complaints performance and service improvement report must be reported to the landlord’s governing body (or equivalent) and published on the on the section of its website relating to complaints. The governing body’s response to the report must be published alongside this.	Yes		Same as 8.1
8.3	Landlords must also carry out a self-assessment following a significant restructure, merger and/or change in procedures.	Yes		Recent self-assessment has been carried out as a result to a change of policy and timescales.
8.4	Landlords may be asked to review and update the self-assessment following an Ombudsman investigation.	Yes		This is something we are happy to do.
8.5	If a landlord is unable to comply with the Code due to exceptional circumstances, such as a cyber incident, they must inform the Ombudsman, provide information to residents who may be affected, and publish this on their website Landlords must provide a timescale for returning to compliance with the Code.			We can and will do this as and when required

Section 9: Scrutiny and oversight: continuous learning and improvement

Code provision	Code requirement	Comply: Yes / No	Evidence	Commentary / explanation
9.1	Landlords must look beyond the circumstances of the individual complaint and consider whether service improvements can be made as a result of any learning from the complaint.	Yes		This is carried out each quarter or when a theme has been identified by the Housing Service at HCMT Meetings along with the Customer Relations Team.
9.2	A positive complaint handling culture is integral to the effectiveness with which landlords resolve disputes. Landlords must use complaints as a source of intelligence to identify issues and introduce positive changes in service delivery.	Yes		This is discussed in previously mentioned meetings see point 9.1.
9.3	Accountability and transparency are also integral to a positive complaint handling culture. Landlords must report back on wider learning and improvements from complaints to stakeholders, such as residents’ panels, staff and relevant committees.			The Housing & Communities service has taken a strategic approach to learning from complaints. A full analysis is completed on an annual basis, review large scale themes and issues that form the basis of an improvement plan. However, information for each team is sent monthly to the relevant leads to complete any urgent actions or improvements, and this info will also be taken quarterly to HCMT for regular oversight. We’re working out how to include the learning in this years annual report, as it’s a new approach, we’re still developing it for this years publication.
9.4	Landlords must appoint a suitably senior lead person as accountable for their complaint handling. This person must assess any themes or trends to identify potential systemic issues, serious risks, or policies and procedures that require revision.	Yes		The council have a designated Complaints Manager and a Customer Relations Manager who has oversight and provides reports to the lead member.
9.5	In addition to this a member of the governing body (or equivalent) must be appointed to have lead responsibility for complaints to support a positive complaint handling culture. This person is referred to as the Member Responsible for Complaints (‘the MRC’).	Yes		This our Lead Member for Housing.
9.6	The MRC will be responsible for ensuring the governing body receives regular information on complaints that provides insight on the landlord’s complaint handling performance. This person must have access to suitable information and staff to perform this role and report on their findings.	Yes		All this information is provided during the regular Lead Member Briefings that are held.
9.7	As a minimum, the MRC and the governing body (or equivalent) must receive: a.  regular updates on the volume, categories and outcomes of complaints, alongside complaint handling performance;  b. regular reviews of issues and trends arising from complaint handling;    c. regular updates on the outcomes of the Ombudsman’s investigations and progress made in complying with orders related to severe maladministration findings; and   d. annual complaints performance and service improvement report.	Yes		This is included in meetings as part of the answer to 9.1.
9.8	Landlords must have a standard objective in relation to complaint handling for all relevant employees or third parties that reflects the need to: a.  have a collaborative and co-operative approach towards resolving complaints, working with colleagues across teams and departments;  b. take collective responsibility for any shortfalls identified through complaints, rather than blaming others; and  c. act within the professional standards for engaging with complaints as set by any relevant professional body.	Yes		We are committed to our Ethics, which are: Selflessness Integrity Objectivity Accountability Openness Honesty Leadership We also work to our ‘Team Reading’ approach.