(UNCONTROLLED WHEN PRINTED) SHEPHERDS BUSH HOUSING GROUP 1. INTRODUCTION Shepherds Bush Housing Group (SBHG) includes Shepherds Bush Housing Association (SBHA) and Staying First. Shepherds Bush Housing Group, like all organisations, make mistakes from time to time, and value the opportunity to investigate, apologise and put them right. We aim to be the best in London, and recognise the valuable role which learning from customer complaints can play in helping to deliver the highest levels of customer service and satisfaction. 2. AIMS This policy aims to: Effectively and efficiently manage customer complaints Establish a fast and fair complaint escalation and review process 3. COMPLAINTS Customers often have cause to complain where they feel that: we missed an agreed appointment we failed our service standards we failed to respond to enquiries we gave poor or unsuitable advice our actions are inappropriate our staff were rude or unhelpful Complaints may be made by the following customers : a current resident or customer; a former resident or customer; a prospective resident or customer; a third party affected by our actions; or an MP, Councillor or third party acting on their behalf with their permission. We will ensure opportunities to complain are promoted and encouraged, and will accept complaints through our website, by e-mail, by post or freepost, by phone, and in person. We will usually treat any complaint addressed to the Chief Executive or Board to have been addressed to the organisation at large. We will encourage customers to complain to us directly in the first instance, and not via an MP or Councillor, for a speedy resolution. 1
3.1. PROCESS SBHG will give customers the choice to allow us to immediately address clear failings or issues, or to raise an official complaint where we will additionally investigate and respond. We will operate a two stage complaints process: official complaint, followed by internal review if requested, after which the customer may seek external adjudication. We will consider compensation requests in accordance with our Compensation Policy, and will require an official complaint to be made should the issue concern service failure. 3.2. EXCLUSIONS Customers are unable to use our complaints process in the following circumstances: The issue has already been raised through our complaints process The issue is, has or may be handled under an appeals process The issue is, has or should be handled through legal action The issue is an initial notification or request for service We may accept an anonymous complaint but won t usually issue an official response. Where a complaint relates to an agent or contractor acting on our behalf, and the issue is of an operational nature, then we may direct customers to complain directly to that organisation in the first instance before our complaints process can be used. 4. OFFICIAL COMPLAINTS Official complaints will not fast-track or change our processes, but will provide an opportunity for us to investigate the issue, explore how and why it happened, find an appropriate resolution, and learn any lessons to avoid such issues in future. We consider an official complaint to be: Any dissatisfaction a customer expresses about an aspect of our service, policies, actions or decisions which the customer wishes us to formally investigate, consider, address and respond. Customers must make official complaints within two months of the issue coming to light. 4.1. ACKNOWLEDGEMENT SBHG will issue an acknowledgement of an official complaint within two working days of receipt; acknowledgement may be written or verbal. We will advise of the timescale for response, and will provide a unique case reference. 2
4.2. RESPONSE SBHG will respond to all official complaints in writing, whether as our sole response or following a telephone call or meeting. We aim to respond in full within 10 working days of receipt, but may agree an alternative timescale with customers on a case-by-case basis where appropriate. 5. INTERNAL REVIEW Customers have a right to an internal review of their official complaint if they are not satisfied with our response. We will clearly explain the right to an internal review in our official complaint response. An internal review represents the formal completion of our official complaints process. Customers must request an internal review within 14 working days of our official complaint response, explaining how and why they are dissatisfied. An internal review will be conducted by the director responsible for the service. An internal review will check that we have followed our official complaints process, and investigated and responded appropriately. We will consider the reasonableness of our official complaint response, but won t substitute judgement in decision making where the decision was reasonable. 6. EXTERNAL ADJUDICATION Customers may have a right to independent and impartial consideration of their complaint following the completion of our official complaints process. We will clearly explain any relevant right to external adjudication in our internal review response. 6.1. DESIGNATED PERSONS Customers can ask a designated person, either a local MP or Councillor, to consider their complaint once our official complaints process has been exhausted. The use of a designated person is intended to resolve complaints early and locally through use of mediation or other intervention, but there are no special or legal powers other than the ability to immediately refer eligible complaints to the Housing Ombudsman. 6.2. HOUSING OMBUDSMAN SBHA have mandatory membership of the Housing Ombudsman Service, whose jurisdiction covers all landlord and resident housing activities across all tenures. There are various exceptions to their jurisdiction, such as rent and service charge matters. 3
The Housing Ombudsman will only accept referrals from customers between eight weeks and six months after our official complaints process has been exhausted, or immediately upon referral from a designated person. 6.3. FINANCIAL OMBUDSMAN Staying First have mandatory membership of the Financial Ombudsman Service, whose jurisdiction applies only to their debt and financial advice service. The Financial Ombudsman will only accept referrals from customers after our official complaints process has been exhausted, or eight weeks after they have made an official complaint. 6.4. STAYING FIRST COMMITTEE Staying First have no external adjudication schemes, other than the Financial Ombudsman in limited circumstances. We will provide a discretionary right of referral to the Staying First Board in lieu of external adjudication. The Staying First Board will only accept referrals from customers within one month of them having exhausted our official complaints process. The Staying First Board will convene a Complaints Committee to review, investigate and respond. 7. EXCEPTIONAL VARIATION A tiny minority of customers may account for a disproportionately high volume of complaints, diverting significant time and resource away from other customers. We may vary our complaints process for these customers in a manner specific and proportionate to the circumstances. We will ensure that exceptional variation is only made with the agreement of a relevant Director, is communicated to the customer clearly in writing, and is reviewed every two years to ensure it remains appropriate. 8. LESSONS LEARNT SBHG will use complaints as an opportunity to learn; we will identify and consider lessons learnt from official complaints, and will implement remedies to prevent future reoccurrences where appropriate. We will operate a Customer Complaints Improvement Panel to assess and scrutinise our handling of complaints and implementation of our official complaints process. The Panel will meet on a quarterly basis and will include delegates from the Resident Voice and lay customers. The Panel will review lessons learnt to ensure that we are learning from our mistakes and have considered appropriate changes to our operating practices. 4
9. EQUALITY AND DIVERSITY SBHG will ensure that this policy is applied fairly and consistently. We will not directly or indirectly discriminate against any person or group of people in line with our Equality and Diversity Policy. We will act sensitively towards the diverse needs of individuals and communities and will take positive action where appropriate. We will make appropriate arrangements where necessary to ensure that customers with distinct communication needs are not unreasonably and disproportionately affected. This could involve providing communications in alternative languages or formats, or providing interpretative or transcriptive assistance where appropriate. 10. TRAINING SBHG will provide all staff responsible for implementing this policy with comprehensive training as required. 11. MONITORING SBHG will monitor complaints received, business areas affected, time taken to respond, whether upheld, complaints escalated to internal and or external review, and any agreed exceptional variations. We will report on our performance to our Senior Management Team, Board and Resident Voice on a regular basis. 12. REVIEW SBHG will formally review this policy every three years, unless changes in legislation or regulation require an earlier review. 13. SCOPE This policy applies to employees with statements of terms and conditions from the following organisations: Shepherds Bush Housing Association Staying First 5
14. STATUTORY AND REGULATORY FRAMEWORK This policy is informed by the following legislation and regulation: Tenant Involvement and Empowerment Standard 2009 Financial Services and Markets Act 2000 Localism Act 2011 Housing Act 1996 15. ASSOCIATED DOCUMENTS This policy is implemented by the following procedures: Complaints Procedure This policy is supported by the following documents: Compensation Policy 6