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Date approved: April 2022
Review date: April 2024

See below for the full policy, but please be aware this may include acronyms or technical jargon used internally within Raven. If you have any questions, please contact us.

1. Purpose of the policy

1.1. The purpose of this policy is to provide information on how we resolve customer complaints in an honest, transparent, and visible way to build trust with our customers.

1.2. Raven is committed to providing a high-quality service for its customers and treating all customers fairly. We recognise that on occasions things go wrong and customers may wish to complain. This Policy sets out how Raven will respond where customers make a complaint.

1.3. Supporting our Customer Experience Strategy and Customer Engagement Framework, complaints are way to demonstrate that we listen and act on concerns. We are committed to viewing complaints positively, learning from mistakes and implementing service improvements. We aim to resolve matters locally and as quickly as possible by being open and accountable.

Scope of the policy

1.4. This policy covers customer complaints. Ravens defines a customer as a tenant, leaseholder, anyone applying for a Raven home, and any person, agency, partner, or organisation seeking information from us or affected by our services. For our internal complaints process, this includes services delivered by a subsidiary of Raven Housing Trust.

1.5. Raven defines a complaint as “an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents.”

1.6. The word complaint does not need to be used for it to be treated as such. We will recognise the difference between a service request (pre-complaint), survey feedback and a formal
complaint and take appropriate steps to resolve the issue for customers as early as possible.

Operating framework

1.7. The Housing Ombudsman Service is set up by law to look at complaints about the housing organisations registered with them. Raven Housing Trust is a member of the Housing Ombudsman Scheme.

1.8. It is mandatory for all local authorities and registered social housing providers to be members of the Ombudsman Scheme. The Housing Ombudsman Scheme has specific authority which sets out the matters they can consider. Their service is free, independent, and impartial.

1.9. The Housing Ombudsman Service does not have jurisdiction where the complainant does not have a landlord/tenant relationship with a member landlord or managing agent. Jurisdiction includes leaseholders and other residents with agreements to live in premises.

1.10. This policy is based on the Housing Ombudsman Complaint Handling Code and Dispute Resolution principles – be fair, put things right and learning from outcomes. It also includes our approach to compensation using the Housing Ombudsman Remedy Guidance.

1.11. This policy is in line with relevant legislation including the Housing Act 1996 (schedule 2), General Data Protection Act 2018, Localism Act 2011, Equality Act 2010, Housing Ombudsman Scheme and Tenant Involvement Empowerment Standards and Government White Paper.

1.12. Where complainants without a landlord/tenant relationship with Raven Housing Trust or its subsidiaries exhaust Raven’s internal complaints process, they will be advised of other relevant resolution schemes depending on the relationship and availability of alternatives.

2. Detailed policy content

2.1. We will make it easy for residents to complain, by providing different channels through which customers can make a complaint. This can include email, telephone, letter, online or through social media.

2.2. We will make the complaint policy available in a clear and accessible format for customers including publicising the policy on our website and through regular correspondence with customers.

2.3. We will ensure customers are provided with contact information for the Housing Ombudsman Service and notified that they can refer their complaint to the service at any point in the process.

2.4. We will handle the complaint through the following 3 stages:

  • 1. GET ON TRACK – In order to try and resolve complaints as quickly as possible we may initially deal with the problem or service failure under our ‘get on track ‘process.
  • We aim to resolve the failure in service and get it back on track within five working days. A get on track complaint is dealt with much quicker than a formal complaint as we will not normally carry out an investigation or send formal letters.
  • The complainant will receive an agreed plan of actions and timescales to deal with their complaint.
  • Get on track can be by-passed if a customer wishes to raise a formal complaint immediately. However, we will expect residents to explain why if they do not wish to use the get on track option first.
  • Get on track complaints can be raised and dealt with by all front-line staff. As part of this process front line staff are empowered to offer financial redress.
  • 2. FORMAL COMPLAINT – If a customer is unhappy with a service we have provided or we have been unable to resolve an issue to their satisfaction under our get on track process they can raise a formal complaint.
  • A manager will investigate the complaint and offer a face-to-face meeting with the complainant to discuss the complaint. If a face-to-face meeting is not required or not possible, the complainant will receive a phone call from the investigating manager.
  • The manager will provide a written response within 10 working days of receiving the complaint and will keep the complainant informed of the progress until resolution.
  • The formal response will include: the complaint stage, the outcome of the complaint, the reasons for any decisions made, details of any remedy offered to put things right and any outstanding actions.
  • We aim to fully resolve the complaint and carry out agreed actions within 30 calendar days where it is the responsibility of Raven or one of our contractors. If longer is required, we will contact the complainant to agree a new timescale.
  • We will send a closure letter if we have not heard from the complainant within 14 working days to request an appeal.
  • When a complaint is closed, customers will be advised how to contact the Housing Ombudsman Service if they wish to pursue their complaint further.
  • 3. APPEAL – If the complainant is dissatisfied with the outcome of their formal complaint, they may be able to appeal under specific grounds set out in the formal response letter. We will advise customers that this request must be made within 14 working days of Raven’s final response letter at formal complaint stage.
  • Our Complaints Policy differentiates between those who have or have had a contractual relationship with Raven and those who do not / have not – e.g., those with a tenancy or a customer of a Raven subsidiary; and those who may have an interest but do not pay a contribution towards any form of management or service.

No Right of Appeal

  • Complainants without a contractual relationship with Raven Housing Trust can raise a formal complaint but they do not have option to take their complaint to appeal.
  • Where they exist, complainants will be advised of other appropriate resolution schemes

Right of Appeal

  • A tenant, leaseholder, or party with a contractual relationship with Raven Housing Trust can raise a formal complaint and then has the right to an appeal stage although the complaint should be in relation to the service defined in their contract. Relatives of a deceased tenant or leaseholder complaining on their behalf have the right to access both stages.
  • The appeal will only consider any issues that were included in the original formal complaint.
  • Where this is offered, we expect a complainant to participate in mediation as part of the formal complaint process before allowing an appeal to discuss how a resolution may to be reached.
  • We will write to the complainant within 20 working days from the date of request for escalation setting out whether the appeal has been accepted or declined and the reasons for this decision.
  • If we do not hear from the complainant within 14 days of Raven’s response to the formal complaint, we will write to the complainant to confirm the complaint is closed as they have not appealed.
  • The grounds on which an appeal will be considered are:
    a) There was a material administrative error in the information received and considered; or
    b) There is evidence to suggest that a policy or procedure is incorrect in terms of government legislation, or
    c) There is evidence key information presented as part of the original complaint has not been considered, or
    d) That the complaint has not been conducted in accordance with Ravens complaint policy, or
    e) The complainant had been prevented from attending or submitting evidence by illness or other compelling cause that related to personal circumstances, or
    f) The complainant feels they have been treated unfairly or disadvantaged accessing the complaint process because of a protected characteristic identified in the Equality Act, or
    g) The value of financial compensation is incorrect. This will only be considered where Raven has not followed the Housing Ombudsman remedy guidance or has not taken directly relevant evidence of monetary loss into account in making an award. Evidence of monetary loss must have been submitted as part of the original complaint. We may offer to review the offer of compensation outside a formal appeal to support a swift resolution where this is the only issue.
  • Where an appeal is accepted, it will be heard by a panel which will normally include a Board Member (chair), a Raven resident (usually a member of Customer Voice Panel), and a Raven Director who has not been significantly involved in the complaint. The Raven manager who investigated the complaint and the customer will also attend.
  • The decision at appeal stage will signify the end of Raven’s internal complaint process. If the complainant wishes to pursue their complaint after completing Raven’s internal complaint process, they can contact the following:
    • Designated Person – A designated person can be a local councillor (not County or Parish), or the local MP were identified as the designated person. The designated person can try to resolve the complaint locally or refer the case to the Housing Ombudsman if the complainant requests. The designated person will not decide upon the case – they will try to find a resolution
    • Housing Ombudsman Service – the complainant will be informed about how to contact the Housing Ombudsman service in all correspondence and will be advised they can contact the Housing Ombudsman Service at any point during the complaint process. When the internal complaints process has concluded, the complainant will be advised how to contact the Housing Ombudsman Service if they remain dissatisfied. Raven will cooperate by providing evidence supporting the complaint to be investigated by the service. Referral to the Housing Ombudsman Service should be undertaken within 8 weeks of the final decision letter
    • We support and will signpost the use of organisations such as Shelter and Citizens Advice to aid local resolution where appropriate.

2.5. We retain discretion to close complaints early where the following applies:

  • Our investigation is complete, and a response sent
  • There is no further contact after the timescales sent out in the closure letter of 7 days
  • When resolution is agreed, and we have committed to deliver the action.

3. Approach to remedies and resolution

3.1. Or approach when considering remedies to a complaint follows the Housing Ombudsman Service remedy guidance and includes:

  • Be Fair – we will seek fair outcomes ensuring we treat each case individually and taking into account the behaviour of complainant as well as our actions
  • Put Things Right – we will consider a range of measures to put things right for a complainant including financial compensation where appropriate
  • Learn from Outcomes – We will ensure that changes are made to policies, procedures, systems, staff training or all of these to reduce future complaints.

3.2. Where a complaint is upheld, we will consider a variety of remedies, which could include:

  • An apology – acknowledging an error and taking responsibility
  • Specific action – such as completing repairs or changing a decision
  • Amending policies or procedures
  • Financial compensation – for quantifiable financial loss or other financial redress.

3.3. We will normally offer financial remedy based on the Housing Ombudsman Remedy Guidance, where applicable. It will take into consideration evidence of financial loss, the duration of avoidable distress or inconvenience, seriousness of impact, potential mitigating actions by the complainant, level of rent or service changes, and looking at similar cases.

3.4. The Housing Ombudsman Service is an alternative resolution process and remedies are not intended to be punitive. The Service does not make orders of compensation in the way that a court may order payments of damages.

4. Applicability and exclusion

4.1. We will not normally consider a complaint if the issue giving rise the complaint occurred more than 6 months ago. Where the problem is re-occurring, we will consider older reports if this helps resolve the issue. We will consider this where health and safety or illness has prevented a complaint being raised in the 6 months period.

4.2. We do not accept complaints from groups of customers; however, we may accept an individual complaint as a lead complaint and any decisions made, may apply to other named individuals in the same circumstances. We would apply the same decisions without the need for multiple investigations.

4.3. This policy excludes complaints from contractors and organisations Raven holds a contract or service level agreement with. These will be dealt with through the dispute resolution mechanism in the relevant contract or agreement.

4.4. If legal proceedings have started, we will continue our complaints process only where no court proceedings or settlement agreement has been reached.

4.5. In circumstances where complainants are thought to be unreasonable, unreasonably persistent, or even vexatious, and this behaviour is having a significant or detrimental impact on staff this may affect the way a complaint is dealt with. In these cases, we will decide on the most appropriate way to manage and conclude the complaint. Full details of our response to unreasonable behaviour can be found in Challenging Behaviour Procedure.

5. Responsibilities

5.1 Raven Housing Trust Board is responsible for approving this policy.

5.2 Leadership team is responsible for overseeing compliance with this policy.

5.3 All senior and team managers are responsible for implementing this policy.

6. Confidentiality

6.1. Raven will comply with collection, storage, access to, provision and disclosure of complaint data in accordance with our privacy policy and with the Data Protection Act 2018.

7. Implementation procedures

7.1. This policy will be implemented through staff training and the Complaints Procedure.

8. Equality, diversity and inclusion

8.1. Raven will comply with the Equality Act 2010 and were deemed necessary will make reasonable adjustments to how we except or handle a complaint based on individual needs.

8.2. An Equality Assessment has been carried out for this policy and ongoing monitoring of complainant characteristics will continue to identify any future actions required.

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