Housing Ombudsman Complaint Handling Code:

In July 2020, the Housing Ombudsman Service (HOS) published a new Complaints Handling Code which requires all landlords to self-assess against the Code and publish the results of this self-assessment on their own website by 31 December 2020. Any areas where current policy and procedure do not comply with the Code must be addressed by the Code implementation date of 31 March 2021.


The Code is being introduced to standardise complaint handling across the sector, as response times and the number of stages a complaint can go through vary widely across landlords. 


Below is the York Housing Association’s self-assessment against the new Code.

Compliance with the Complaint Handling Code

1. Definition of a complaint
Does the complaints process use the following definition of a complaint? No

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

Comment / Further Action

Although we do not use this specific wording, this has been covered in our explanation of what constitutes a complaint.  YHA will be adopting the new  Karbon Complaint Handling Policy and this wording will be incorporated.

Does the policy have exclusions where a complaint will not be considered? Yes

Are these exclusions reasonable and fair to residents? Yes

Evidence relied upon :

Current York Housing Association Complaints Handling Procedure :

When it is not appropriate to deal with a complaint?

Generally, we will not progress complaints if :

  • They are unreasonable

  • Where unreasonable demands about the outcome are being made

  • They are anonymous

  • They are an issue that has already been looked at through our complaints procedure

  • They are made more than three months after the customer became aware of the problem, whereas a complaint should be made as soon as possible.

  • They are straightforward issues that should be easily dealt with through our normal policies and procedures rather than following the complaints procedure.  For instance :

  • A contractor turning up late to carry out a repair would be followed up as a breach of our customer service standards

  • A concern about a neighbour’s behaviour would be dealt with in line with our anti-social behaviour policy.

Examples of Unreasonable Complaints or Unreasonable Demands:

The list below provides some examples of unreasonable complaints or unreasonable demands :

  • Lodging numerous complaints about the same issue over a period of time

  • Using valid new enquiries or complaints to raise issues that have previously been responded to.

  • Attempting to submit a new complaint when the matter is clearly about an issue that has already been through our complaints process.

  • Refusing to accept the stance of YHA in terms of service delivery once the complaints process has been exhausted.

  • Refusal to accept that an issue is not within the remit of our complaints process.

  • Demanding outcomes that are unreasonable (e.g. dismissal of staff members, overturning court decisions, criminal prosecution of staff or tenants).

  • Making unnecessarily excessive demands on the time and resources of staff.

  • Unreasonably refusing to deal with members of staff who ordinarily would deal with the issue.

  • Canvassing for complaints from other customers

  • Refusal to co-operate with the complaints process (e.g. failing to provide information to help progress the complaint or failing to advise YHA of the customers preferred outcome from the complaint)

  • Electronically recording meetings, telephone calls and conversations without the prior knowledge, and/or consent of the other persons involved.

Comment / Further Action

We added these examples into our policy following advice from the Ombudsman service when we previously asked them to look over our complaint policy following some training. The Ombudsman service put us in touch with an organisation who they considered to have a model policy and we have used similar wording.

2. Accessibility

Are multiple accessibility routes available for residents to make a complaint? Yes

Is the complaints policy and procedure available online? Yes

Do we have a reasonable adjustments policy? Yes

Do we regularly advise residents about our complaints process? No

Comment / Further Action

Although we provide a leaflet on sign up and there is information on the website, going forward we intend to advise residents about our complaints process regularly via other media.

3. Complaints team and process

Is there a complaint officer or equivalent in post? Yes

Comment / Further Action

The Customer Insight and Involvement Manager is responsible for co-ordinating our response to complaints.

Does the complaint officer have autonomy to resolve complaints? No

Comment / Further Action

Complaints are allocated to an individual staff member who has the autonomy to resolve (where compensation is to be paid it may be necessary to escalate for approval as per authorisation levels in the delegatory framework)

Does the complaint officer have authority to compel engagement from other departments to resolve disputes? Yes

If there is a third stage to the complaints procedure are residents involved in the decision making? N/A

Is any third stage optional for residents?  No

Does the final stage response set out residents’ right to refer the matter to the Housing Ombudsman Service?  Yes

Do we keep a record of complaint correspondence including correspondence from the resident?  Yes

At what stage are most complaints resolved?

Stage 1; only one complaint has been escalated to Stage 2 in over three years.

4. Communication

Are residents kept informed and updated during the complaints process? Yes

Are residents informed of the landlord’s position and given a chance to respond and

challenge any area of dispute before the final decision? Yes

Are all complaints acknowledged and logged within five days? Yes

Are residents advised of how to escalate at the end of each stage? Yes

What proportion of complaints are resolved at stage one?  95.4%

What proportion of complaints are resolved at stage two? 4.6%

What proportion of complaint responses are sent within Code timescales?
  • Stage one - Stage one (with extension)
  • Stage two - Stage two (with extension)
Stage 1 – Code 10 days, YHA 15 days.
Stage 2 – Code 20 days, YHA 25 days.
Our timescales are not currently compliant with the Code.  This will be addressed in the new policy.

Where timescales have been extended did we have good reason?  Yes

Where timescales have been extended did we keep the resident informed?  Yes

What proportion of complaints do we resolve to residents’ satisfaction?  95.4%

5. Cooperation with Housing Ombudsman Service

Were all requests for evidence responded to within 15 days? N/A

Where the timescale was extended did we keep the Ombudsman informed? N/A

6. Fairness in complaint handling

Are residents able to complain via a representative throughout? Yes

If advice was given, was this accurate and easy to understand?  N/A

How many cases did we refuse to escalate?  None

What was the reason for the refusal?  N/A

Did we explain our decision to the resident?  N/A

7. Outcomes and remedies

Where something has gone wrong are we taking appropriate steps to put things right?  Yes

8. Continuous learning and improvement

What improvements have we made as a result of learning from complaints?

Staff and customer service – strengthening 1-1 and appraisal process, customer service training, workshop on behaviours.

ASB – Change to processes and staff refresher training

Planned maintenance – More rigorous contract monitoring, Improved customer communications

Responsive repairs – More rigorous contract monitoring and workshop with contractor’s operatives

How do we share these lessons with:

  1. residents?

  1. the board/governing body?

  1. In the Annual Report?

Residents’ Newsletter

A paper is submitted to Board on an annual basis covering the number of complaints received, the nature of the complaints, the outcomes, and learnings.

There is a section in the Annual Report on the number of complaints received, the nature of the complaints and the outcomes and learnings.

Has the Code made a difference to how we respond to complaints? Yes

What changes have we made?

Going forward :

  • Updated Policy and Procedure in line with the Code

  • Improved complaint handling timescales.

  • More regular publishing on complaints handling process.

More detailed information for residents on lessons learned.

If you need help or advice, talk to your housing officer

Call 01904 636061