Complaints policy
2024
Monitoring and review
Document owner |
Approved by |
Authorised by |
Effective date |
Review date |
Nicky Devey – Head of |
Julie Haydon – Director Corporate Services | Wolverhampton Homes Board |
June 2024 | June 2025 |
Andrew Finch – Customer Experience Manager |
Document history
Version |
Summary of changes |
Document status |
Date |
1 | Review against Complaints Handling Code |
Approved | June 2024 |
1.0 Purpose
1.1Wolverhampton Homes aims to provide great homes in clean, safe neighbourhoods to support helping people get on in life. We are also committed to providing a high-quality customer contact and access including dealing with complaints in a fair and impartial way
1.2 By proactively listening to our customers and dealing with complaints about our services, we are able to make improvements based on the feedback you give us. It also allows us to manage, respond to and learn from complaints. We will apply fairness and impartiality; and our customers will not be treated any differently if they complain.
1.3 This complaints policy aims to set out a clear and fair process for the handling of complaints from all our customers relating to the services we provide contributing to the overall aim of dealing with all complainants in a transparent, consistent, fair, and reasonable way.
1.4 This includes clear processes and timeframes to help customers understand how we will investigate their complaint and when we will respond. This has been developed in line with dispute resolution principles recommended by the Housing Ombudsman, which are to:
- Be fair – treat people fairly and follow fair process.
- Put things right.
- Learn from outcomes.
1.5 In a small number of cases where complainants, either individually or on behalf of someone they represent, pursue their complaint in an unreasonable and persistent way, where this is considered to be unacceptable or habitual, this is covered separately by the Persistent or Unreasonable Complainant Policy (detailed further in Section 10).
1.6 Our Customer Resolution team have access to staff at all levels to facilitate the prompt resolution of complaints and have authority and autonomy to act to resolve disputes promptly and fairly.
2.0 What is a complaint?
2.1 Under this policy, a complaint is defined as an expression of dissatisfaction, however made, the definition of a complaint is where an expression of dissatisfaction, however this is made about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, where this affects an individual resident or group of residents.
This differs from a service request which is where the customer is requesting a service, rather than making a complaint.
We will raise a complaint where dissatisfaction is raised with the response to a service request, even if the handling of the service request remains ongoing. We will not stop our efforts to address the service request if the customer complains.
3.0 Who can make a complaint?
3.1 A customer can make a complaint if they are the person who is affected by the action, or a customer can give consent for somebody else to act on their behalf.
3.2 Complaints can also be made by Designated Persons as defined by the Localism Act 2011. A Designated Person can be an MP, a local councillor, or a tenant panel member. They can intervene on a customers’ behalf to help to resolve a complaint.
4.0 Complaints that cannot be dealt with under this policy
4.1 We will accept a complaint unless there is a valid reason not to do so. There are certain types of complaints that are not covered by this policy and will not be considered or escalated as a complaint. They are:
- anonymous complaints.
- where the issue is a service request unless the complaint is relating to a response to a service request.
- a complaint that has already been fully investigated in line with this policy.
- a complaint made by an employee about any matter relating to their employment.
- when the issue took place more than twelve months ago.
- where we have specific arrangements in place in line with our Persistent or Unreasonable Complainants Policy.
- complaints that are being pursued in an unreasonable manner.
- the policy does not cover complaints which are subject to legal action, where action has commenced following the pre-action protocol.
- where there is an insurance claim, whether on-going or closed, this will not prevent related formal complaints being dealt with.
We will apply discretion as to whether to accept complaints outside of the 12-month time limit where there are good reasons to do so.
Where we decide not to accept a complaint, we will provide an explanation to the complainant 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 us to consider the complaint.
We will take an individual approach to all complaints and consider the individual circumstances of each.
5.0 How to make a complaint
5.1 Information about making a complaint or giving feedback can be found on our website: https://www.wolverhamptonhomes.org.uk/giving-feedback
5.2 Complaints can be made in any one of the following methods:
- Online at:
https://www.wolverhamptonhomes.org.uk/feedback-form
- Email at:
complimentsandcomplaints@wolverhamptonhomes.org.uk
- Through webchat:
https://www.wolverhamptonhomes.org.uk/
- Via telephone by calling Homes Direct on 01902 556789.
- In writing to:
Wolverhampton Homes
Wednesfield Housing Office
Alfred Squire Road
Wednesfield
Wolverhampton
WV11 1XU
- By asking a friend, relative, a trusted person or an advocate such as a Member of Parliament or Councillor to contact us on a customer’s behalf. In these cases, we will need customer consent to discuss any issues with them.
5.3 We ask customers to let us know if they need any help in making a complaint and our Customer Resolution team will be able to support them.
5.4 Where a complaint raises issues that fall within the responsibility of both the City of Wolverhampton Council and Wolverhampton Homes, we will agree with the council who will lead the investigation. We will let the customer know how their complaint will be handled and the reply will be approved by both organisations before it is sent.
5.5 An expression of dissatisfaction with services made through a survey is not defined as a complaint, though wherever possible, the person completing the survey will be made aware of how they can pursue a complaint if they wish to. Where we ask for wider feedback about our services, we will also provide details of how a complaint can be submitted.
6.0 Putting things right
6.1 We aim to resolve expressions of dissatisfaction quickly, wherever possible at first point of contact with a customer, either by our customer services team or by the relevant service area. If the matter cannot be resolved quickly, we follow a two-stage complaints process detailed as Stage 1 and Stage 2.
We will listen to a customer’s complaint and where we have made a mistake, there are several ways we can try to put it right. This includes:
- Speaking to the customer directly to ensure we are clear about the concerns and to provide opportunity for the customer to be clear about their concerns and the resolution sought.
- Addressing any actual or perceived conflicts of interest.
- Acknowledging when something has gone wrong and making an apology.
- Providing a full explanation and reasons where something has gone wrong and take action if there has been a delay.
- Amending or correcting a record.
- Reviewing a decision that has already been made.
- Reviewing our procedures to ensure we capture any learning and improvements.
- Consider financial compensation – this may include making a goodwill payment or providing advice on making an insurance claim.
- Any remedy will reflect the impact on the customer as a result of any fault identified. Remedies will clearly set out what will happen and by when, in agreement with the customer where appropriate. Any remedy proposed will be followed through to completion.
We will consider all information and evidence carefully, treat each complaint on its own merits and offer the most suitable remedy to resolve the issue, to take steps to put things right, and to learn and make service improvements.
6.2 Where our complaint response is handled by a third party (e.g. a contractor or independent adjudicator) at any stage, this will be part of our two stage complaints process. We will not expect customers to go through two complaints processes and will ensure any third party follows this process
7.0 Complaints process
7.1 Stage 1 - we will aim to resolve all complaints at this stage wherever possible.
Our Customer Resolution Team aim to acknowledge a Stage 1 complaint within five working days of receipt. We aim to respond fully in writing within 10 working days of the complaint being acknowledged.
We will also attempt to contact the customer directly to discuss the complaint and to explore how we can work to resolve it. We will also confirm any customer support needs to help identify any reasonable adjustments that may be required in the handling of the complaint.
Each complaint will be investigated with the relevant service lead with the aim of resolving the matter as quickly as possible and our response will include whether each element of the complaint is upheld or not.
The Customer Resolution Team will keep in contact with the customer to talk through the outcome of the investigation and to check on satisfaction and to provide an opportunity to review our reply at Stage 1 if needed, before it is issued.
An update on the complaint will be provided to the customer at the point the answer to each concern is known, and not left until all outstanding actions required to address the complaint are completed. Outstanding actions will be monitored, and an action plan issued to the service area, to ensure these are resolve promptly with appropriate updates provided to the customer.
Where a customer raises additional complaints during the investigation, these will be incorporated into the Stage 1 response if they are related, and this response has not been issued. Where the Stage 1 response has been issued, and the new issues are unrelated to the issues already being investigated or it would unreasonably delay the response, the new issues will be logged as a new complaint.
If the investigation is going to take longer than 10 days, we will contact the customer to provide the reasons for the delay and confirm the extension of the investigation with the customer, to agree a new response date. Any extension will not be longer than 10 working days. The customer will be provided with details of the Housing Ombudsman at this stage.
7.2 Stage 2 - If a customer is not satisfied with the response given at Stage 1, they can ask us to review our original investigation. The customer will need to explain how the complaint meets one of the following criteria:
- The issue was not properly addressed at Stage 1 of the process.
- There was something inaccurate in the response given.
- The customer has new information or evidence to give to us, that was not available originally.
If the above criteria are not met, we may decide not to escalate a complaint to Stage 2 of our complaints process, however we will clearly explain the reason for this decision in writing to the customer. We will make all reasonable efforts to communicate with the customer and to understand why they remain dissatisfied.
Where a customer wishes to progress to Stage 2 of the complaint process, we request this is requested as soon as possible, preferably within 20 working days of our response to the Stage 1 complaint.
We aim to acknowledge the Stage 2 complaint within 5 working days of receipt. We will attempt to contact the customer by telephone to discuss the complaint and how we can work to resolve it. Once the complaint is received,
we will work with the relevant Head of Service to investigate, and we will also try to resolve any outstanding matters straight away.
Where the original complaint has followed policy and procedure and where
there is no change to the original outcome, the original decision will be upheld.
An update on the complaint will be provided to the customer when the answer to each concern is known, not left until all outstanding actions required to address the complaint are completed. Outstanding actions will be monitored, and an action plan issued to the service area, to ensure these are resolved promptly with appropriate updates provided to the customer.
We will aim to respond fully within 20 working days from the day the Stage 2 complaint was acknowledged to confirm our decision.
If the investigation is going to take longer, the Customer Resolution Team will contact the customer within 20 days of the complaint being received. They will provide the reasons for the delay and agree an extension of the investigation with the customer, providing a new response date. Any extension will not be longer than 10 working days. The customer will be provided with details of the Housing Ombudsman at this stage.
This is the end of our internal complaints process.
8.0 What if I am still not happy with the outcome to my complaint?
8.1 We will maintain contact with the customer to ensure where possible they are satisfied with our response at Stage 2; however, this may not always be achievable.
8.2 If a customer is still not happy with the response they have received, they can choose to refer your complaint to a designated person, such as a Member of Parliament or Councillor.
8.3 In some cases the customer will be able to refer the case to the Local Government and Social Care Ombudsman. If this is the appropriate body for the complaint, details of how to contact them will be provided in our Stage 2 response letter.
8.4 The Housing Ombudsman is responsible for complaints about council or housing association landlords. They can look at how a landlord dealt with a request for a service. The Ombudsman decides if a landlord acted properly and followed the correct procedures.
8.5 The Housing Ombudsman can be contact by telephone on 0300 111 3000 or email at: https://www.housing-ombudsman.org.uk/contact-us/
9.0 Learning from complaints
9.1 Customer satisfaction is very important to us, and we use your feedback, including learning from complaints to shape improvements to our services and processes. We will 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.
9.2 We will include our complaints performance and how we have improved services in line with customer feedback into our annual report.
9.3 We will also publish on our website our performance of the handling of
complaints in line with this policy, together with details on learnings from complaints.
10.0 Persistent or unreasonable complaints
10.1 As detailed above, we are committed to providing a high-quality customer service and will deal with complaints in a fair and impartial way. However, in a small number of cases customers pursue their complaints in an unreasonable and persistent way that can negatively impact the investigation of their complaint and the ability of staff to provide a quality service to other customers.
10.2 This may involve making persistent complaints about different matters, or repeated complaints about the same issue. These actions can occur either while their complaint is being investigated, or once the investigation has been completed.
10.3 We consider these types of unreasonable complaints to be unacceptable, and they will be handled in line with our Persistent or Unreasonable Complainants Policy. Where a complaint is considered unreasonable, it is still important to ensure that the customer can access our services, including the complaints service. There are options available to staff to enable them to manage unreasonable complaints effectively and fairly, with minimal disruption to other customers. Full details can be found in our Persistent or Unreasonable Complainants Policy.
10.4 We will take a proportionate approach to all customers and have regard to the provisions of the Equality Act 2010.
11.0 Policy review
11.1 This policy will be reviewed on an annual basis or in line with changes in law, or business requirements, or at the request of the Housing Ombudsman following an investigation where this requires to be reflected in the policy
11.2 The Housing Ombudsman requires landlords to self-assess against the Complaint Handling Code on an annual basis and publish this on their website.
11.3 In the event we are unable to comply with this Policy and the Housing Ombudsman Complaint Handling Code due to exceptional circumstances, such as a cyber incident, we will inform the Ombudsman, provide information to customers who may be affected, and publish on our website, advising of the timescale for returning to compliance with the Code.
12.0 Privacy and personal data
12.1 Customer privacy is important to us, and we are committed to handling personal data in accordance with the provisions of the Data Protection Act 2018, General Data Protection Regulation 2016 / 679, and any subsequent changes to data protection legislation.
12.2 Our privacy policy can be found on our website: Wolverhampton Homes | Privacy policy
13.0 Discretionary goodwill payments
13.1 Wolverhampton Homes aims to be fair and proportionate in its response to resolving issues arising from complaints and in doing so may consider a gesture of a good will without prejudice to be considered by way of a compensation payment.
13.2 The factors taken into account when deciding the overall amount include:
- The duration of any avoidable distress or inconvenience
- The seriousness of any other unfair impact
13.3 If a discretionary compensation payment is awarded, the value will be offset against any outstanding balances owed in the first instance, including but not exclusive to rent arrears or repair recharges.
13.4 We will follow the guidance issued by the Housing Ombudsman when considering remedies.
14.0 Equality, Diversity and Inclusion
14.1 This policy clearly details the multiple ways that a complaint can be made, including via an advocate. This will help to remove barriers and ensure fair and equal access to the process for all customers.
14.2 All reasonable adjustments will be made if disability is considered a factor in the ability of our customer to make a complaint. We will take reasonable steps to accommodate any reasonable adjustments you may have to enable you to access this policy or receive responses to complaints in other formats and provide such assistance as you may reasonably require.
14.3 Wolverhampton Homes is committed to making sure our policies and services reflect the community we serve and to meet equal opportunities. Our aim is to make the Complaints policy easy to use and accessible to all of our customers in line with the Equality Act 2010.
14.4 Wolverhampton Homes works with a number of community groups to develop services that are both accessible and responsive to individual needs.
14.5 We will ensure that our complaint responses take into account customer support needs from a service delivery point of view, we will detail offers of support and a tailored service where required.