RSL Complaint Procedures Access Study

ACCESS TO COMPLAINTS PROCEDURES
BY TENANTS OF RSLs

REPORT OF A STUDY FOR

THE INDEPENDENT HOUSING OMBUDSMAN LTD
AND
THE HOUSING CORPORATION

Caroline Pickering Associates
March 2002

Access to Complaints Procedures for RSL residents Caroline Pickering Associates

CONTENTS

1 INTRODUCTION ............................................................................................................................ 4
COMMISSIONING AND BRIEF ..................................................................................................................... 4
METHODS................................................................................................................................................. 4
COPYRIGHT ............................................................................................................................................ 4

2 EXECUTIVE SUMMARY AND RECOMMENDATIONS – ...................................................... 5
HEADLINES .............................................................................................................................................. 5
OVERALL RECOMMENDATIONS ................................................................................................................. 5
SPECIFIC RECOMMENDATIONS ................................................................................................................. 6
SUMMARY OF FINDINGS ........................................................................................................................... 6
Complaints are good for residents and RSLs - the review of literature and research. ..................................... 6
Tenants’ and RSLs’ experience - the first survey of residents and RSLs. ....................................................... 7
How to achieve the change - the Best Practice Guidance................................................................................ 8
Eight ‘golden rules’ for RSLs’ complaints management..................................................................... 8
3 OUR FINDINGS IN DETAIL ....................................................................................................... 10
THE WIDER CONTEXT ............................................................................................................................ 10
What is good practice in complaint management? – The Literature Review.................................... 10
Overview....................................................................................................................................................... 10
Introduction................................................................................................................................................... 10
The benefits of effective complaint management.......................................................................................... 11
Common Features ......................................................................................................................................... 11
Quality Assurance ......................................................................................................................................... 12
Definition of a complaint .............................................................................................................................. 12
Access ........................................................................................................................................................... 14
Simplicity...................................................................................................................................................... 15
Speed............................................................................................................................................................. 16
Fairness ......................................................................................................................................................... 16
Confidentiality............................................................................................................................................... 18
An effective response .................................................................................................................................... 19
Management Information .............................................................................................................................. 19
Training......................................................................................................................................................... 20
CURRENT EXPERIENCE........................................................................................................................... 22
The first questionnaires to residents and RSLs. ................................................................................ 22
Our key findings:........................................................................................................................................... 22
How satisfied are residents with complaint handling? What processes do RSLs use to deal with
resident dissatisfaction?.................................................................................................................... 23
Complaint procedures.................................................................................................................................... 23
Training and guidance ................................................................................................................................... 26
Time limits for responding and acknowledging complaints.......................................................................... 27
Complaint outcomes...................................................................................................................................... 27
Customer satisfaction with complaint handling............................................................................................. 28
Action taken to resolve a complaint .............................................................................................................. 30
Access and publicity...................................................................................................................................... 32
Reporting....................................................................................................................................................... 34
What do residents want?................................................................................................................................ 35
What are RSLs doing to improve complaint handling?................................................................................. 37
SETTING THE STANDARD – THE DISCUSSION GROUPS........................................................................... 39
Our key findings................................................................................................................................ 39
What are the existing requirements for landlord complaint procedures?....................................................... 40
The Discussion Groups ..................................................................................................................... 40
1 What do residents want from a complaints procedure? ....................................................................... 40
Why do people complain? …and why don’t they complain? ........................................................................ 40
Accessing a complaint procedure .................................................................................................................. 40
Customer care................................................................................................................................................ 41
Housing co-operatives................................................................................................................................... 42
Customer expectations and responses to complaints ..................................................................................... 42
Publicising a complaint procedure ................................................................................................................ 43
Complaint leaflets ......................................................................................................................................... 44

Copyright © CPA 2002 page 2

Access to Complaints Procedures for RSL residents Caroline Pickering Associates

What makes a successful complaint procedure?............................................................................................ 44
Stages of complaint ....................................................................................................................................... 45
Panel hearings ............................................................................................................................................... 45
A model complaint procedure ....................................................................................................................... 46
Some other comments ................................................................................................................................... 47
Conclusion – Residents groups ..................................................................................................................... 47
2 What do RSLs want from a complaint procedure? .............................................................................. 48
Organisational culture ................................................................................................................................... 48
Who can complain?....................................................................................................................................... 49
What is a complaint? ..................................................................................................................................... 49
Recording all complaints............................................................................................................................... 49
On-the-spot resolutions – informal vs. formal complaints ............................................................................ 50
Management Information .............................................................................................................................. 50
Recognising employees ................................................................................................................................. 50
Audit ............................................................................................................................................................. 51
Responding to complaints ............................................................................................................................. 51
Compensation................................................................................................................................................ 51
Customer satisfaction .................................................................................................................................... 52
Publishing information about changes made following investigation of complaints..................................... 52
Central contact point for complaints ............................................................................................................. 52
Helping customers to complain ..................................................................................................................... 52
Publicising the procedure .............................................................................................................................. 53
Training......................................................................................................................................................... 53
A model complaint procedure ....................................................................................................................... 53
Panel or committee stage............................................................................................................................... 54
Conclusion – RSLs groups ............................................................................................................................ 54
THE DRAFT BEST PRACTICE GUIDELINES ............................................................................................... 56
Residents’ assessments of the draft Guidelines................................................................................. 63
Overall perceptions ....................................................................................................................................... 63
Positive comments included:......................................................................................................................... 63
3-stage procedure .......................................................................................................................................... 64
8-week time limit .......................................................................................................................................... 64
Investigation of complaints at the final stage ................................................................................................ 64
Choice of complaining in person to a panel .................................................................................................. 64
Suggestions for improving the management and handling of complaints ..................................................... 65
RSLs’ assessments of the draft Guidelines........................................................................................ 66
Overall perceptions ....................................................................................................................................... 66
Criticisms of the guidelines........................................................................................................................... 66
3-stage procedure .......................................................................................................................................... 67
8-week time limit .......................................................................................................................................... 68
Investigation of complaints at the final stage ................................................................................................ 68
Choice of complaining in person to a panel .................................................................................................. 68
Suggestions for improving the management and handling of complaints ..................................................... 69
Representative bodies’ views ........................................................................................................................ 69
4 APPENDICES ................................................................................................................................ 70
APPENDIX A: REFERENCES ................................................................................................................... 70
Local Authority complaint procedures and policies ......................................................................... 71
RSL complaint procedures and policies............................................................................................ 71
Private Sector Complaint procedures and policies........................................................................... 72
APPENDIX B: PROFILE OF RESPONDENTS ............................................................................................... 73
RSLs:................................................................................................................................................. 73
Residents:.......................................................................................................................................... 73
Gender .............................................................................................................................................. 74
Disability........................................................................................................................................... 74
Age .................................................................................................................................................... 74
APPENDIX C: RESIDENTS’ REASONS FOR DISSATISFACTION WITH COMPLAINTS HANDLING ................... 75
APPENDIX D: RESIDENTS’ EXPECTATIONS WHEN MAKING A COMPLAINT .............................................. 76
APPENDIX E: RESIDENTS’ DISLIKES AND LIKES OF COMPLAINTS HANDLING .......................................... 77
APPENDIX F: RSLS INVOLVED IN THE PROJECT...................................................................................... 78
APPENDIX G: CONSULTATION QUESTIONNAIRES ................................................................................... 86
GLOSSARY OF TERMS...................................................................................................................... 101


Access to Complaints Procedures for RSL residents Introduction

1 INTRODUCTION

COMMISSIONING AND BRIEF

Caroline Pickering Associates were commissioned in 2001 by the Independent
Housing Ombudsman Ltd and the Housing Corporation to undertake a study (as the
first part of a two-part project) with the aim of :

Ø establishing what is current good practice in complaints management in the
public and private sectors
Ø assessing the extent to which current practice in RSL complaints management
– as reported by tenants who have complained and by RSLs themselves –
demonstrates best practice
Ø creating a set of criteria for best practice
Ø recommending how any gap between current practice in the RSL sector and
best practice can be addressed

METHODS

To answer the questions posed by the brief we carried out the following (reported in full
under “Findings in Detail”):

Ø A review of current literature and research about complaints management in the
public and private sectors, especially amongst Registered Social Landlords
(RSLs) and their residents.

Ø A questionnaire survey of RSL Chief Executives (or their nominated
representative) and complainants. More than 200 questionnaires were
distributed to RSLs, who distributed more than 600 questionnaires to their
resident complainants.

Ø Discussion groups involving more than 30 participants including both resident
complainants and employees with responsibility for complaint procedures.

Ø A survey of resident complainants, RSL employees and representative groups
on our “Best Practice Guidance for Complaint Procedures”.

Copyright

This report is copyright to Caroline Pickering Associates. Extracts may be used without specific
permission so long as they give a true account of the Report’s findings, are verbatim, and
acknowledge their source

.


Access to Complaints Procedures for RSL tenants Executive Summary and
Recommendations – A Mandate for Change

2 EXECUTIVE SUMMARY AND RECOMMENDATIONS –
A MANDATE FOR CHANGE

“It is expected that the improvements in their handling of complaints will lead to
a growing number of complaints being satisfactorily resolved by housing
associations.” (Housing Corporation, 1993)

HEADLINES

1 RSLs’ complaints procedures – with a few honourable exceptions – fall well
below the standard of other sectors in the public and private sectors, and
consistently fail to meet good practice

2 Residents and RSLs recognise the value of excellence in complaints
management, and have overwhelmingly welcomed the draft ‘Best Practice
Guidelines’

2 Residents – and to a lesser extent RSLs – wish the ‘Best Practice Guidelines’ to be
mandatory.

3 The manifest need for improvement in the way the RSL sector manages complaints
and treats complainants, the call from residents for this improvement, and RSLs’
readiness to change, are why we have called this report “A Mandate For Change”.

4 A Mandate for Change is what we believe the Ombudsman and the Corporation
have been given. The rest of this report documents:

Ø why the changes are needed,
Ø what the changes should achieve, and
Ø how they might be brought about.

OVERALL RECOMMENDATIONS

5 Our overall recommendation is that the Best Practice Guidelines – slightly modified
to take account of the helpful suggestions that came from residents and RSLs –
should be made a requirement: the Corporation and the Ombudsman should
require RSLs to implement and operate the Guidelines as quickly as can be
achieved. The key features of best practice in complaints management for RSLs
are set out in the “eight Golden Rules” below.

6 Other sectors now see complaint handling as a key regulatory area. The Financial
Services Authority (FSA) has both requirements and guidance for banks and has
recently issued requirements and guidance for credit unions. Other regulatory
bodies are moving in the same direction in recognition that protection of the
consumer’s right to complain can be one of the most effective ways of protecting
the consumer’s interests and bringing improvements to services.



SPECIFIC RECOMMENDATIONS

7 Justice delayed is justice denied. Residents and RSLs want speedier processes
and the guidance must be clear on the number of stages and should also suggest
appropriate time limits for different stages.

8 At the final stage, complainants should be offered the alternatives of

Ø an impartial and representative panel hearing (giving regard to the possible
implications of Beeson vs Dorset County Council) with no restrictions for the
complainant (such as time limit on presentation), or
Ø an investigation by an impartial and professional investigator.

9 Small community-based RSLs and housing co-operatives will need to consider
whether a third stage is appropriate when housing stock is managed by residents
and confidentiality of complainants cannot be guaranteed:
§ Option 1: Umbrella groups (or partnerships of local RSLs) organise and
recruit independent panel hearings at third stage
§ Option 2: No third stage – complainant goes direct to IHOS.

10 Finally, the features of best practice in complaints management for the RSL sector
are set out in the Best Practice Guidelines and the “eight golden rules” below.

SUMMARY OF FINDINGS

Complaints are good for residents and RSLs - the review of literature and
research.

11 “Handling complaints properly shows how important customer care is to your
organisation. It shows that you:
Ø Listen to your users;
Ø Learn from your mistakes; and
Ø Are continually trying to improve your service.”
(Service First Unit, 1999)

12 Complaints are a positive source of feedback and learning opportunities.

13 A healthy level of complaints can be an indicator of an effective service provider –
we found that those RSLs who record a high level of complaints tend to have
the highest customer satisfaction.

The 30 RSLs who recorded the highest number of complaints:
§ Recorded 57% of all complaints registered by the 152 RSLs who
completed our questionnaire
§ Manage 17.5% of all properties managed by RSLs who completed our
questionnaire.
§ 51% of their residents were satisfied with complaint handling
§ Only 4% of these satisfied residents said that they needed to complain
to a senior manager, a councillor or MP before getting satisfaction.
§ 43% of their residents were satisfied with the outcome of their
complaint



The other 122 RSLs:
§ Recorded 43% of all complaints registered by the 152 participating
RSLs
§ Manage 82.5% of all properties managed by RSLs who completed our
questionnaire.
§ 17% of their residents were satisfied with complaint handling
§ 24% of these satisfied residents said that they needed to complain to a
senior manager, councillor or MP before getting satisfaction.
§ 21% of their residents were satisfied with the outcome of their
complaint

Modern complaints management shows a number of other common features:

§ It has left behind the idea of formal and informal complaint processes and,
instead, utilises simple, streamlined feedback processes that deal with any
dissatisfaction.
§ Speed is of the essence in complaints handling - the longer a complaint
runs on, the more dissatisfied customers get: best practice organisations
aim to complete all internal stages within eight weeks.
§ Best practice organisations are dedicated to integrating complaint data in to
regular management processes to initiate improvements and use complaint
data in almost every area of the organisation.
§ The level of effective complaint handling training contributes significantly to
employees’ overall level of satisfaction with a complaints process. Only a
quarter of the sample RSLs who replied to the first survey said they had
provided any complaint-handling or customer care training to employees
during the last year.
§ Employees should have clear guidance on what they should do to put things
right when mistakes are made.

Tenants’ and RSLs’ experience - the first survey of residents and RSLs.

14 Few residents are said to complain and those who have aren’t impressed by the
RSL’s attempts to resolve any concerns;

15 With notable exceptions, RSLs’ complaints procedures don’t measure up to good
practice.
§ Only 1.6% of residents are recognised by our sample RSLs as having
complained in the last year- yet during 1995, according to the MORI survey,
15% of RSL residents said they had made a formal complaint. A significant
number of RSLs said that they receive no complaints (!).
§ The number of procedures with four or more stages has fallen greatly since
1995 but this reduction has not kept pace with the equivalent reduction in the
number of local authorities procedures with four or five stages.
§ Many RSLs require final stage complainants to present – often with a 10 or
20 minute time limit - to the board or committee and a few will arrange a
complaints panel (with clear guidelines on composition and role). Some
residents and RSLs were concerned that these hearings can be intimidating
for some people.
§ 57.4% of residents are dissatisfied with the outcome of making a complaint
to their landlord (Table 10a – 10c). Only 26.3% are satisfied (this is very



similar to National Health Service (NHS) complainants where 26% are
satisfied with the outcome).
§ Only 23% of residents stated that they were satisfied with the way their
complaint was handled and 61% were dissatisfied (Table 11a – 11e). Local
authority surveys show that 36% of respondents are satisfied and 55% are
dissatisfied and the recent NHS review of satisfaction with complaint
handling found 30.3% satisfied and 49.4% dissatisfied with complaint
handling.
§ Satisfaction among black and minority ethnic residents has marginally
improved but dissatisfaction has increased from 43% to 64%.
§ Only 14.5% of respondents aged 45 or under are satisfied with complaint
handling compared to 37% of respondents aged over 60.
§ Only 35% of RSLs will accept non-written complaints at all stages of the
complaint procedure.
§ Most RSLs publicise their complaint procedure through a statement in their
Residents Handbook. Only 2.5% of residents said they knew how to
complain by reading the handbook.
§ When residents complain, financial compensation is low on the list of
outcomes they want: putting something right and an apology is at the top.
§ Most RSLs were unable to say what compensation they had paid to
complainants or what other practical actions they had taken in
response to complaints.

How to achieve the change - the Best Practice Guidance

16 Only 3% of tenants and 6% of RSLs said any of our suggestions was a “bad idea”.
• The Guidelines met with much positive comment, and little negative
comment, from residents and RSLs.
• Several RSLs have said that complaints can be unjustified – an attitude that
fails to realise that customers tend not to complain and the importance of
discovering the cause of dissatisfaction.
• Some smaller RSLs are concerned about how applicable the guidance is to
them.

Eight ‘golden rules’ for RSLs’ complaints management

I Value complaints as an opportunity to learn and improve - use
complaints data at all levels of the organisation

II Have no more than three stages to your complaints procedure, and
make no distinction between ‘informal’ and ‘formal’ complaints

III Make sure your complaints procedure is widely publicised in appropriate
languages, formats and media

IV Try to resolve complaints on the spot – and offer to meet in person all
complainants where this hasn’t been achieved

V Apologise, provide a clear explanation of your response, and give full
compensation where it is deserved



VI Aim to take no more than eight weeks for complaints to complete all
internal stages

VII Train employees to be positive about complaints and manage them
skilfully

VIII Give complainants an opportunity to complain in person to a panel of
three impartial people at the final stage of the complaint procedure.


Access to Complaints Procedures for RSL residents Findings in detail

3 OUR FINDINGS IN DETAIL

THE WIDER CONTEXT
Why Complaints are Good for Residents and RSLs

What is good practice in complaint management? – The Literature Review

Overview

17 This review reports on 37 documents we have looked at (listed in the
bibliography). The salient findings are here presented under the headings of the
Cabinet Office’s essential points for complaint procedures.

Introduction
“Next time I will contact my councillor and ring the local newspaper.”

18 The National Complaints Culture Survey 20011 found that 50% of customers
complain all or most of the time when they are unhappy with the way they have
been treated by an organisation. The private sector recognises that dissatisfied
customers tell 10-25 others about a poor service experience and go elsewhere
for the service in future. Also, a customer who has a complaint satisfactorily
resolved will be more likely to purchase products or services in future than a
satisfied customer who never complains. Customers accept that things go wrong
but expect that something will be done to put things right and prevent the same
problem happening again.

19 Customers of public services, generally, have limited choice but customers may
lose confidence in services and go elsewhere – Ombudsman, councillors,
Members of Parliament – or may “shop the system” contacting several services
and agencies for the right answer. During 1999, the Local Government
Ombudsman’ carried out a study of complaint handling that found only 13%
satisfaction with complaint handling where a customer had been referred back to
a local authority’s complaint procedure after making a complaint to the
Ombudsman’s offices – compared to a national average of 36% satisfaction with
local authority complaint handling. ORC International’s research (ORC, 2000) into
complaints made following contact with the Independent Housing Ombudsman
Service found that 60% of RSL Residents considered that the relationship with
their landlord worsened after making a complaint.

20 Dissatisfied customers of social housing providers may delay or withhold
payment of rent or service charges imposing extra collection expense on their
landlord. A study in the private sector showed that satisfied customers pay on
average 14 days earlier than dissatisfied customers.

21 Poor complaint handling can cause the organisation to develop a poor image –
dissatisfied customers spread bad news by ‘word of mouth’ or contact the local
press. Registered Social RSLs participating in stock transfer programmes may
well find prospective Residents giving some thought to their landlord’s “image”
before voting for or against the transfer.

1 References are listed in the Bibliography



22 Public services also need to be aware that unresponsive, difficult-to-access
processes create “difficult” customers who become costly, time-consuming
customers with low expectations and a lack of understanding of the processes
they are required to follow. But these “difficult” customers can be turned into very
effective exposers of flaws in the organisations services and policies.
The benefits of effective complaint management

23 An effective complaint scheme will develop a culture of continuous improvement
across services. The best organisations, in the public and private sectors, are
recognising that improving systems for capturing complaints data provides
information about every part of the organisation. Ben Page (Director of
Government Research, MORI) has commented that an effective complaint
scheme can be more effective than a Best Value regime because of this (MORI,
2000).

24 An effective scheme also:
q Improves both customer confidence and satisfaction
q Improves credibility and image
q Improves employee morale through empowerment and recognition

25 Customers can be better educated about an organisation’s processes – a
complaint may be an opportunity for a customer to learn about how an application
form should be completed (reducing the costs of processing incomplete forms in
future).

26 Some other benefits of effective complaint management are:
q Early warning of service breakdown
q Prevention of repeat problems
q Free consultation
q Reduced costs of litigation
q Improved targeting of resources and lower costs of service delivery
q Increased customer loyalty
o Customers loyal to the company and spreading “good news
stories”
o Helping to attract investment
o Helping to attract Government funding for ‘top performers’ in social
housing

Common Features

27 All effective complaints systems have some essential points in common. The
Citizens Charter Complaints Task Force summarised these as follows:

“Complaints systems should:
§ be easily accessible and well publicised;
§ be simple to understand and use;
§ allow speedy handling, with established time limits for action, and keep
people informed of progress;
§ ensure a full and fair investigation;
§ respect people’s desire for confidentiality;
§ address all the points at issue, and provide an effective response and
appropriate redress;
§ provide information to management so that services can be improved.”
(CITIZENS CHARTER COMPLAINTS TASK FORCE, 1995)



28 Other elements such as independence, accountability, training and review might
also be considered as essential to an effective social housing complaint handling
system.

Quality Assurance

29 The Financial Services Authority (FSA) has been encouraging regulated
companies under its control to use the British Standard for complaint
management (BS8600) as a guide for developing effective complaint handling
processes (FSA, 2000).

30 The British Standard (BSI, 1999) suggests that complaint procedures should
provide:
§ Adequate resources to deal with the complaints received.
§ Employee training to make sure those who deal with customers
understand the procedures and operate them properly.
§ Delegation and responsibility to enable employees to deal quickly and
efficiently with routine complaints.
§ Escalation procedures to ensure that in the event of a serious complaint,
key employees are alerted and the problem is dealt with by whoever has
the appropriate expertise.
§ External review mechanism to be available where internal procedures
are deadlocked.
§ Follow-up action to ensure that the company learns from any mistakes,
and improves products and services and the complaints system where
necessary.
(These features are consistent with the Citizens Charter Task Force’s ‘essential
points’.)

31 The accredited version of the British Standards Institute’s complaint management
standard (CMSAS 86:2000) ensures that an organisation’s complaints
management achieves an acceptable minimum standard, and the requirement for
annual checks ensures that this standard is continuously maintained (BSI, 2000).
In Australia, AS 4269 – the Australian equivalent to the British complaint
management standard – is a required standard for many monopoly service
providers (such as utilities and government departments and agencies).
Government Ombudsmen are promoting the adoption of the Standard as a
means of promoting a customer-friendly culture and to have a responsive
complaints handling procedure at the source. Australian Financial Service
providers are required by law and regulations to have an AS 4269 system in
place. Australia has a number of industry based dispute resolution schemes, for
example, in banking, insurance and telecommunications and participants are
required to have complaints systems meeting the standard (Australian Standards,
2001).

Definition of a complaint

The public sector has long debated the definition of a complaint. This is in stark
contrast to most of the private sector where customers simply “complain”. The
British Standard requires that all complaints should be logged – however made
(BSI, 1999). Guidance for Charter Mark applications states that organisations
should “keep records of the number and types of complaints you have received,



including informal complaints, and how quickly you have dealt with them”
(Citizens Charter Complaints Taskforce, 1995). The reality has been that in the
public sector often only formal complaints are logged – unlike the private sector
where all complaints can be opportunities to increase customer loyalty and
ensure repeat business. Avis, the car hire company, advises employees to log all
contact whether written or on the telephone. The company’s complaint codes
include personal service delivery issues such as telephone problems (engaged,
no answer or too may transfers) and process issues such as reservations, check
in and check out and insurance. The collected data is used to monitor trends and
identify root causes.

32 The Department of Health’s current review of Social Services complaint
procedures recognises that informal suggests a lack of seriousness about the
complaints and proposes that the word “informal” is not used in the new
procedures (DoH, 2001)

33 Discussions about “formal” and “informal” complaints are rarely found outside the
public sector – customers complain and the best companies want to know about that
feedback and feed it into the quality assurance process - and a web search on
“informal complaints” will generate a list of public service complaint procedures. The
analysis of RSL complaint systems has shown that most follow the traditional public
sector method of distinguishing between “informal“ complaints – that are not recorded
- and “formal” complaints. Some RSL complaint procedures encourage customers to
complain informally before making a formal complaint but other RSLs have stage 1 as
an “informal” stage.

34 Most complaint systems that recognise “informal” complaints define an “informal”
complaint as a complaint that is immediately resolved. However, several RSLs’
complaint procedures gave a timescale for handling an “informal” complaint that
can range from 7 to 14 days. One complaint leaflet reviewed also stated that “you
do not need to use the complaint procedure if you have only a small criticism” of
the RSL.

35 Some RSLs have a “grievance procedure” instead of a complaint procedure. The
word grievance suggests – unhelpfully - that complaints should be directed at
personnel.

36 The National Consumer Council’s 1991 report on social housing complaint
procedures found that 90% of housing complaints are made informally to front-line
employees (NCC, 1991). The National Consumer Council commented “unfortunately,
many public services seem to regard the role of front-line staff in this informal
procedure as not part of their complaints procedure… it does nothing for the large
bulk of complaints ‘business’ which is carried out by front-line staff.”

37 If a customer is dissatisfied and their dissatisfaction is not responded to, it will
turn into a complaint. If they didn’t think they had a serious complaint but their
comment was responded to positively with a consequent service improvement,
they will be delighted. More and more organisations are now taking a positive
approach by telling employees: "If you have to ask, treat it as a complaint”.
Northamptonshire County Council has recently introduced a new complaint policy
that gives customers the right to decide whether the matter is a complaint.

38 The London Borough of Wandsworth also follows this principle and has
been recording 25,000 complaints each year. This is the highest number of



complaints recorded by a local authority, yet Wandsworth also have more
Charter Mark awards than any other public service.

39 The British Standard for complaint management embraces this approach by
defining a complaint as “any dissatisfaction (with an organisation) whether
justified or not” (BSI, 1999).

Access

40 Organisations that are committed to customer service encourage customers to
use their complaints system. A report commissioned by the Association of British
Insurers found that customers generally shy away when faced by a formal
complaint procedure. They may grumble but they don’t like making too much of a
fuss (ABI, 1998).

41 A complaint system can only be effective it is used. If the system is to be used,
customers need to know about it and find it easy to get their complaint started
and progress it through the process. Any complaint procedure should be well
publicised. Customers prefer to have a choice of complaint method. Some
customers prefer to complain in writing but others may prefer to complain by
phone or in person. More customers are using the accessibility of the Internet to
make a complaint. The London Borough of Camden has a guide to complaining
on their web site that gives local residents advice on how to complain about a
RSL and allows them to complain online about several local RSLs.

42 Many RSLs require formal complaints to be put in writing. Most RSLs will respond
to an “informal” complaint however made. A few RSLs have produced publicity
that positively encourages feedback from customers.

43 Barber and Møller say that a written complaint is a “red flag” and provide the
following list of reasons why people will put a complaint in writing:

§ The customer is upset (it takes effort to write a letter although many who
say they will write a letter of complaint do not follow through).
§ The customer is dissatisfied with the outcome of a verbal complaint (many
people only complain in writing after trying some other method to resolve
the problem).
§ The customer is building a paper trail in preparation for legal action
(needing to create evidence that they gave the company a chance to fix
their complaint).
§ The customer was not able to find someone to complain to in person
§ The customer feels uncomfortable with face-to-face complaining
§ The customer has a personal reason why they could not or did not want to
complain at the time
§ The customer has been told to complain in writing
(Barber and Møller, 1996)

44 One RSL allows complaints to be made using a form (with Crystal Mark
recognition of the plain language used), in writing to a Freepost address, by
phone, by Minicom, by fax, by email or in person. A telephone number is also
advertised (in partnership with a local authority) for getting information in large
print or Braille or accessing a translation service.



45 OFGEM, the regulatory body for the gas and electricity markets, requires all
companies to submit their complaint handling code for approval (following
consultation with the consumer body, energywatch) before giving them a licence.

46 The code has a number of requirements for companies including:
§ Provision of details of how a customer can contact the company to make
a complaint, including any special arrangements for customers who are of
pensionable age, disabled or chronically sick, and those whose first
language is not English
§ Provision of details of advice agencies and other organisations able to
help the customer pursue his or her complaint

47 Some RSLs restrict access to a complaints system. Some only allow direct
customers, such as tenants or leaseholders, to complain whereas others allow
tenants, leaseholders, housing applicants, members of the public, contractors,
suppliers and other organisations to complain.

48 Other RSLs have restricted access by excluding certain types of complaints. One
RSL reviewed does not allow customers to complain about policies because
“policies have been carefully considered and help the organisation to achieve
objectives”.

49 Many RSLs do not allow anonymous complaints and state in their publicity that
they will not be considered. However, a pattern of anonymous complaints may
highlight a problem with customer perceptions of a service or raise a “whistle
blowing” issue that needs to be followed up. An organisation that disregards
anonymous complaints will miss out on these opportunities. Northamptonshire
Social Care and Health Services advise their employees to investigate an
anonymous complaint in a similar way to any other complaint.

50 The Office of Fair Trading advises that a company should do its best to pursue
even anonymous complaints but recognises that there may be practical
difficulties in doing so where full information is not available and clarification
cannot be sought from the complainant.

51 Research (TARP, 1997) has shown that a freepost or freephone facility for
complainants installs greater confidence in customers who consequently
recognise the willingness of the organisation to put things right when they go
wrong. A report commissioned by the British Association of Insurers in 1998
stated that companies with a freephone or freepost facility for services, but not
complaints, could not claim to take complaints seriously (AIB, 1998).

52 Just like any service or product, a complaints system needs to be accompanied
by regular, good-quality publicity. Some organisations will do this by putting
details on invoices or with mailshots, articles in newsletters or magazines
describing positive complaint outcomes and attractive leaflets and posters in
highly visible areas of customer access areas. The National Housing Federation’s
guide to dealing with complaints and compensation mentioned that maintenance
orders give a good opportunity to get tenant feedback (NHF, 1994).

Simplicity

53 Some organisations have got rather carried away in designing complaints
systems – and for the best possible motives. They have allowed their systems to



become more and more complex, rules introduced to deal with abuse,
procedures changed to accommodate special cases, additional routes of appeal
provided to prevent injustice, and so on. To those used to the mechanics of
procedures and paperwork, it may seem that complainants are being provided
with the best possible service but to complainants themselves the whole business
can be alienating. Surveys show that complainants are less happy with multi-
stage procedures with many stages of appeal than they are with simpler set-ups.

Speed

54 The Office of Fair Trading (OFT) conducted a survey that found that complaints
resolved in less than three weeks have a net balance of satisfied customers but
dissatisfaction grows steadily when more than three weeks pass by before
resolution. Speed is of the essence in complaints handling. The longer a
complaint runs on, the more dissatisfied customers get – and with good reason
(OFT, 1999).

55 The National Complaints Culture Survey found that customers expect an
acknowledgement by return of post. Customers want an acknowledgement of
their complaint as soon as possible – unless the complaint can be resolved
immediately (TMI/Institute of Customer Service, 2001).

56 Customers want to be kept informed about the progress of a complaint.
Sometimes an interim response can reassure a customer that their problem is
being dealt with even if a full response will take some time. Response times
should be clearly set out in leaflets outlining the complaints procedure and
resources should be made available to ensure that the targets are met.

57 The Financial Services Ombudsman Service introduced a maximum time limit of
eight weeks for a company or credit union to resolve a complaint (FSA, 2000).
The Local Government Ombudsman has introduced an initial twelve-week time
limit for local authorities to handle a complaint but will be reducing this to eight
weeks from 1 April 2002. Both schemes allow a customer to complain to the
Ombudsman if the complaint is not handled within the time limit2.

Fairness

58 The National Consumer Council’s report (NCC, 1991) on housing complaint
procedures stated that: “those who operate the system must be seen to be as
impartial and objective as possible. The complaints system is likely to fail unless this
can be achieved.”

59 RSLs follow a wide range of approaches to achieving fairness. The Housing
Corporation’s Performance Standard G6 requires that a complaint procedure
“should include a personal appeal to the governing body, which would involve
one or more of its members”. Most RSLs do this by requiring complainants to
present a complaint to board or committee members and some to a complaints

2
This power, and the Ombudsmens’ ability to choose to accept and investigate complaints
before they have been through the entirety of a company’s or Council’s complaints
procedures, have proved to be powerful levers of change and improvement.



panel that may include someone independent of the organisation (such as a
tenant from another RSL).

60 In fact, however, research has shown that what complainants have been shown
to want is the opportunity to discuss their complaint in person at the beginning of
the process, not at the end.

61 The Local Government Ombudsman’s “Devising a complaints system” booklet
states that someone investigating a complaint should contact the customer to:
• Clarify the complaint;
• Clarify the outcome sought;
• Check whether he or she needs support of any kind, whether he or she
has poor sight or hearing, or a language need;
• Check what he or she needs to understand the discussion properly; and
• Explain the investigation procedure.
(CLA, 1993)

62 A complaint procedure should put the complaint handler in a position where they
can judge fairly from all the information whether or not a complaint is valid (they
will also require the appropriate skills to ensure that they implement the system
properly – see Training below). Complaint handlers should be looking to engage
with a customer at the earliest possible opportunity.

63 Our study of complaint procedures has shown that many RSL procedures have
the focus on direct contact with a customer at the end of the process. RSL’s do
have a variety of approaches to giving a customer an opportunity to discuss their
complaint. One of the RSL complaint procedures described a complaints panel of
board members that is convened at the end of the complaint procedure. The
panel can be convened within six weeks and will communicate a decision within
two weeks of the hearing – a total of eight weeks before a response is given to
the customer. Another RSL’s complaint procedure reduces the possibility of delay
at the panel stage by immediately referring a complaint to the Complaints Panel if
not upheld by the Director at stage two.

64 The London Borough of Camden’s Housing department has guidelines that
require an employee to visit any customer who complains about delay or quality
of repairs.

65 Many complaint systems try to make sure that the people who make the decision
can realistically be seen as fair and impartial – for example by ensuring that
complaints are never investigated by the individual or group against whom the
complaint is made. It is harder to establish the independence of internal
arbitrators. The best that can be done is to explain to complainants that someone
independent of the original decision on their complaint can carry out a review. If
an appeal is made, the results of the appeal should be set out with detailed
reasons for them in a clear letter that explains the result as impartially as
possible.

66 The FSA’s complaint handling requirements state that a letter giving a final
response on a complaint must inform the complainant of a right to go to an
ombudsman and include a copy of the Financial Services Ombudsman’s leaflet.
This helps to reassure complainants that the organisation is trying to be fair (FSA,
2000).



67 Most RSL complaint procedures give the contact details of the Independent
Housing Ombudsman Service but some refer to the Housing Corporation as the
“final stage” or as another option for the complainant. One RSL’s complaint
procedure states “if tenants are unhappy with the RSL after exhausting the
appeals and complaints procedure, they can ask the Housing Corporation, the
Government body which monitors us, to investigate the complaint.”

68 The Independent Housing Ombudsman Service encourages RSLs to use
alternative dispute resolution methods. One RSL’s complaint procedure has a
mediation service built into their complaint procedure.

69 The Walsall Mediation Service wrote:
“A complaint is a situation that involves a person who believes that they have
been aggrieved and it requires a response which will provide some kind of
redress. This type of situation normally lends itself to successful resolution
following a traditional complaint procedure.

A dispute has no clear definition. Allegations are often met by counter
allegations. Facts are often subjective, proof difficult to substantiate and there is
no conclusive evidence about who is right or wrong. Following a traditional
complaint procedure is not appropriate for disputes.”

70 The British Standard’s guidance is that mediation or arbitration is available as an
independent service where the internal complaint procedure has been exhausted.
The standard also suggests that an Ombudsman scheme should try and mediate
a resolution before carrying out an independent review of a complaint (BSI,
1999).

71 The FSA’s guidelines advise companies to consider alternative dispute resolution
schemes, such as mediation or arbitration, where the complaints are outside of
the Ombudsman Service’s jurisdiction (FSA, 2000).

Confidentiality

72 Social Services departments are required to employ a designated complaints
officer to provide such a role - and manage the operation of the procedure. One
of the RSLs reviewed did advise customers to contact a Customer Relations
Team if they are concerned about making a complaint direct to the service
provider.

73 The FSA requires all authorised companies to have a single contact point for
customers to contact and get advice. The NFH guide to complaint handling
suggested that RSLs could follow the designated complaints officer model (NFH,
1994). One RSL’s complaint procedure mentions a complaints officer but gives
no means of phoning this officer.

74 Customers want to be reassured that there will be no adverse consequences
because of a complaint - such as taking a service away from them. These
assurances can be included in literature produced about the complaints scheme.
Customers should be given an opportunity to complain in confidence.



An effective response

75 Research carried out for the Cabinet Office, by MORI, into public sector complaint
handling has shown that a rapid response is more likely to lead to a satisfactory
resolution than the same response made later (MORI, 2000). The research also
highlighted that the importance of a proper apology should not be forgotten even
where the complaint may be due to a misunderstanding rather than a mistake.

76 The British Standard stresses that, if procedures are changed because of the
complaint, the complainant should be told about what has been done - and
thanked for helping the organisation to improve (BSI, 1999).

77 Empowering junior employees to make immediate ex gratia payouts is not only
effective but saves on administrative costs. The National Consumer Council’s 1996
report (NCC, 1996) on public service complaint procedures commented “front-line
staff should be delegated as much discretion as is appropriate to help them resolve
complaints… this may include a power to provide ‘ex gratia’ payments.”

78 The Association of British Insurers’ report on complaint handling procedures
comments: “if a mistake that has had an adverse affect on the customer then
compensation or some other benefit should be considered in order to put them
into the position they would have been in had the mistake not occurred” (AIB,
1998). The assessment should include an element for the inconvenience of
having to make a complaint. The Local Government Ombudsman has produced a
good practice guide on remedies that includes advice on assessing a payment for
inconvenience and time and trouble.

79 The Housing Corporation requires RSLs to have procedures for dealing with:
80 complaints about services including an appeal to the governing body; and claims
for compensation for service failures.

81 Some RSLs have taken this literally and set up separate procedures for dealing with
complaints and requests for compensation. Therefore, a customer can receive a
response to a complaint accepting that a mistake has been made and then have to go
through another procedure to get compensation.

82 One RSL reviewed requires complainants to make a claim for compensation in
writing to the Housing Manager who will consider the claim in consultation with
the Director. Another landlord had a separate policy for dealing with claims for
compensation but a customer can use the complaints procedure if they are
unhappy with a decision made on a claim for compensation!

83 We also found a RSL that stated that compensation could only be claimed if no
legal remedy is available to the customer – preventing themselves from benefiting
by resolving a case before legal proceedings are instigated by the customer.

84 We did find a landlord that took a more positive approach by publishing a
statement that advises customers that compensation will be considered when
appropriate even where the customer has not specifically requested this.

Management Information

85 The American Productivity and Quality Centre carried out a benchmarking
exercise to assess the complaint handling processes of best-practice



organisations in the United States. They found that these organisations were
dedicated to integrating complaint data in to regular management processes to
initiate improvements and that complaint data was used in almost every area of
the organisation (APQC, 2000).

86 The best organisations also monitor customer satisfaction with the complaint
handling process. The Audit Commission has introduced a performance indicator
for customer satisfaction with local authority complaint handling. The results have
shown that 66% of customers dissatisfied with complaint handling were
dissatisfied with the overall level of service (MORI, 2001).

87 Management information can also be used to discover patterns and trends of
groups of customers who access a complaint scheme – or don’t. A complaint
procedure integrated into the overall business so that all information from
dissatisfied customers can be routinely used to guide future decision-making and
can be especially important in a regulated industry like social housing.

88 Two RSLs do monitor complainants by gender, age, ethnicity and disability to
establish whether all sections of their customers have equally easy access to the
complaints procedure. However, these were the only RSLs that appeared to be
doing this valuable analysis. This ‘profiling’ of customers can be used effectively
to make sure that the scheme is widely accessible and identify whether any
further development or community outreach work is required to make sure all
customers understand that complaining is important to the organisation.

89 The Financial Services Authority requires financial services providers to provide a
bi-annual report to the Financial Services Ombudsman. Companies are required
to provide a detailed breakdown of complaint data to allow the industry’s
regulators to be well informed of consumer concerns (FSA, 2000).

90 The recent review of the National Health Service complaint procedures has
recommended that NHS organisations are required to provide a quarterly report
analysing complaint trends, causes and action taken to prevent recurrence to
both the board of management and copied to the local health council and the
proposed Patients’ Forum (DoH, 2001).

91 The Office of the Rail Regulator is currently planning to pursue improvements to
the quality of complaint data provided by train operators that is already published
in an annual report, and to require annual audits of the data provided (ORR,
2001).

Training

92 The British Standard lists training as a primary requirement of any complaint
scheme and requires that training requirements have been set and achieved
(BSI, 1999). However excellent an organisation’s complaints procedure, the
quality of the complaints management will also depend crucially upon the skills of
the employees who implement it. These skills can be to a certain extent imparted
via regular and general customer care training, but there is also a need for
specialist training in, for example, investigation skills.

93 TXU Energi are implementing a “Living the Service Excellence Culture”
programme. The programme, for all employees, includes a Service Excellence
Complaints Workshop that includes the following sessions:



• Dealing with the industry’s escalated complaints handler (energywatch)

• “Prevention (escalated complaints procedure)”

• “Complaints (timescales and costs)”

• “Complaints procedure – Service Excellence”

• “No quibble” – session focusing on style of response letters.

• Questions and Answers session

94 This programme is in addition to Complaint Handling training and a monthly clinic
session where employees can get advice on resolving complaints made to the
industry’s consumer watchdog, energywatch.

95 The provision of complaint handling training for RSLs appears to be confined to a
session within a general customer care package although the Chartered Institute
of Housing does provide an annual Complaints Policy and Strategy training event
that focuses on:

• Why people complain and how to obtain constructive feedback

• Anticipating how employees may react to complaints and identifying ways to
change this

• Examining barriers to developing and implementing effective complaints
procedures

• Involving employees, residents and members in the development of a policy

• Dealing with complaints within the context of Best Value

96 The National Complaints Culture Survey 2000 found that the level of effective
complaint handling training contributes significantly to employees’ overall level of
satisfaction with a complaints process. Public services topped the league of
employee dissatisfaction with the level of training provided to complaint handlers
(TMI/Institute of Customer Service, 2000).



CURRENT EXPERIENCE

The first questionnaires to residents and RSLs.

97 152 of the 200 questionnaires (65%) sent out to RSLs were returned. 69 (45%) of
these questionnaires arrived after the closing date of 14th September 2000.

98 These RSLs posted out 541 resident questionnaires (out of a possible 650).
Some RSLs sent out fewer than the required 5 questionnaires because they had
received fewer than 5 (in some cases zero) complaints in the last few years.

99 338 residents (55.2%) completed and returned a resident questionnaire. This was
a very good response to the questionnaire (the recent NHS review achieved a
complainant response rate of 31%) and shows the high level of interest in this
project.

Our key findings:

§ 57.4% of residents are dissatisfied with the outcome of making a
complaint to their landlord. Only 26.3% are satisfied (this is very similar to
NHS complainants where 26% are satisfied with the outcome). A
comparison with the 1995 MORI RSL study shows that satisfaction
has reduced and dissatisfaction has increased.
§ Only 1.6% of residents are reported by RSLs to have complained in the
last year. During 1995, MORI found that 15% of RSL residents said they
had made a formal complaint.
§ The number of procedures with four or more stages has fallen greatly
since Lickiss and Karn’s study in 1995 but this reduction has not kept
pace with the equivalent reduction in the number of local authorities
procedures with four or five stages.
• There is little consistency in RSLs’ approaches to giving residents an
opportunity to present their complaint in person at the final stage.
• 40 RSLs (26%) said they had provided complaint-handling or customer
care training to a total of 853 employees during the last year.
• Only 3% of RSLs did not have a documented complaint procedure.
• Only 23% of residents stated that they were satisfied with the way their
complaint was handled. Recent local authority surveys showed that 36%
of respondents were satisfied and 55% were dissatisfied. The recent
National Health Service review of satisfaction with complaint handling
found 30.3% satisfied and 49.4% dissatisfied with complaint handling.
• Resident complainants are most likely to want something put right, or an
apology, than to want compensation.
§ Black and black British residents are more likely to be dissatisfied with the
handling of a complaint than other ethnic groups. Asian and Asian British
residents are more likely to be satisfied with complaint handling.
§ Satisfaction among black and minority ethnic residents has marginally
improved but dissatisfaction has increased from 43% to 64%.
§ Only 19% of male respondents are satisfied with the handling of their
complaint compared to 25% of female respondents.
handling compared to 37% of respondents aged over 60.



§ There is little difference between the satisfaction of respondents who have
long-term illness, health problem or disability that limits their daily
activities or the work they do and respondents who do not.
§ Only 40% of residents found the process of making a complaint to a
landlord to be easy.
§ Analysis of compensation payments shows that the average
compensation award rises from £140.55 under an internal complaint
procedure to £2,507.39 where payment is agreed following legal
proceedings.
§ Only 35% of RSLs will accept non-written complaints at all stages of the
complaint procedure. Several RSLs had stated on the questionnaire that
non-written complaints are accepted whereas a check of their complaint
literature showed that residents are still told to put a complaint in writing.
§ Most RSLs publicise their complaint procedure through a statement in
their Residents Handbook. Only 2.5% of residents said they knew how to
complain by reading the handbook.
§ 83% of RSLs say that board (or management committee) members are
provided with reports of complaints but over half of service managers do
not get information about complaints. 67% of service managers working
for RSLs managing more than 10,000 properties receive no information
about complaints.
§ 66% of RSLs record and analyse complaints by using manual, paper-
based processes.

How satisfied are residents with complaint handling? What processes do RSLs
use to deal with resident dissatisfaction?

Complaint procedures

100 5 (3%) of RSLs did not have a documented complaint procedure (3 large, 1
small and 1 specialist landlord).

101Table 1 shows the number of properties managed by the sample group of RSLs and
the number of complaints registered at each stage of the complaint procedure
(including Ombudsman).

Table 1: Number of properties managed and numbers of complainants at each
stage

Number of properties managed by sample RSL group:
Number of rented properties 378,418
Number of leasehold properties 40,494
Property total 418,912
Stage Number of complainants % of property total
One 5,983 1.428%
Two 1,342 0.32%
Three 346 0.082%
Four 47 0.011%
Five 13 0.003%
Ombudsman 64 0.015%
MPs and Councillors 94 0.022%



102According to RSLs, 5,983 residents (1.4% of residents) had accessed a
complaint procedure in the last year (64 complaints to the IHOS were recorded)
whereas MORI found that in 1995. 15% of RSL Residents said they had made a
formal complaint. Some of the RSLs involved in the survey do not have a distinction
between “informal” and “formal” complaints and log all complaints received. Other
RSLs will only record those complaints that are formal complaints made in writing.

103 Four RSLs, who were rated highly on complaint handling – 82% of
complainants satisfied opposed to only 6% dissatisfied - accounted for 36%
of the total number of complaints recorded but manage only 7% of the
properties represented in this survey.

104 Table 2 shows that most landlord complaint procedures allow any individual
or group of persons affected by a service or a policy to make a complaint.

Table 2: Eligible complainants

No of procedures % of procedures
Resident 150 99%
Applicant for housing 143 94%
Resident’s group 125 82%
Affected member of 134 88%
the public
Affected organisation 119 78%
No reply 2 1%

105 All landlord complaint procedures included in the sample study had a number
of escalation stages. The number of procedures with four or more stages has
fallen greatly since Lickiss and Karn’s study (Lickiss and Karn, 1995).

Table 3: Number of stages in complaint procedures
No of 1995 2001
stages No of % of procedures No of % of procedures
procedures procedures
One 2 1 0 0
Two 10 6 8 5
Three 41 25 82 54
Four 76 47 49 32
Five 30 18 13 9
Six or 5 3 0 0
more
Total 164 100 152 100

106The number of procedures with four or five stages is still higher than local authority
equivalents. Before the Local Government Ombudsman recently introduced an eight-
week time limit for completing all stages of a complaint procedure, only 10% of local
authorities had four or five stages and 26% had only two stages.

107 Some final stages of landlord complaint procedures could have been
considered as two stages. Complaint literature reviews showed that some of the
sampled procedures allowed a director to review the complaint at the final stage
and then progress the complaint to a panel if not upheld (still at the same stage).

108 Although the number of procedures with four or five stages has fallen, the
time taken to complete all stages appears to have increased since 1995.



Table 4: Time taken to complete all stages of procedure
Number of 1995 2001
working days: No of % of No of % of
procedures procedures procedures procedures
Less than two 0 0 8 6
weeks
Two to three 17 18 20 14
weeks
Four to five weeks 35 38 27 19
Six to seven 20 22 32 23
weeks
Eight to twenty- 20 22 53 38
two weeks
Total 92 100 141 100

109Table 4 shows that 38% of landlord complaint procedures have timescales that
total between eight and twenty-two weeks compared to only 22% in 1995.

110The survey also showed that 84% of the complaints made to the IHOS were by
residents who had used a complaint procedure with three or less stages
111Table 5 shows the responsibility for resolving and responding to complaints at each
stage of a landlord’s complaint procedure. The table highlights the procedures where
an on-the-spot or informal resolution is included in the process (i.e. any employee can
handle the complaint) and those procedures that do not include this type of resolution
(i.e. management responsibility at the outset).

Table 5: Responsibility for resolving complaints
Person(s) responsible:
Stage 1 Stage 2 Stage 3 Stage 4 Stage 5
Any employee 28 1
Officer 39
Matron or warden 6
Customer service 2
adviser
Manager 59 33
Senior Manager 19 4 1
Management Team 2
Customer Relations or 3 1
Complaints Manager
Investigating Officer 1
Director 9 46 18 4
Chief Executive 1 22 29 4
Chair 3 8 19 5
Sub-Committee or Panel 2 10 43 20 4
Clerk or Nominated 3
Trustee
General Meeting 1 1
Management Committee 1 23 24 7
or Board
National or Regional 3
Office
Secretary 2
Managing Agent 1



Independent Arbitor 1
No reply 2 2
Total 152 152 141 60 12

11223% of RSLs who responded said that they have not reviewed their complaint
procedure for more than two years. 31% have not reviewed the operation of the
procedure and policies.

11352% of RSLs did not publish information about the operation of their scheme.
Most of the RSLs that publish information use their annual report to notify residents of
the results. Many RSLs mentioned that they did not publish any information because
they received no or too few complaints.

Table 6a: Review of complaint policy and procedures
Last review of policy and
procedures: No of % of
Less than 6 months ago 37 24%
6 to 12 months ago 38 25%
1 to 2 years ago 42 28%
More than 2 years ago 29 19%
Never 6 4%
Total 152 100%

Table 6b: Review of the operation of the complaint policy and procedures
Last review of operation:
No of % of
Less than 1 year ago 67 44%
Never 27 18%
No reply 2 1%
Total 152 100%

114 Tables 6a and 6b show that while just under half of RSLs reviewed their
complaints policy or procedures in the last year, one third hadnot reviewed its
operation within the last two years.

Training and guidance

115Only 40 RSLs (26%) said they had provided complaint-handling or customer
care training during the last year (to 853 employees).

116Table 7 shows that 54% of RSLs have produced guidance for employees on the
handling of complaints within the last two years.

Table 7: Employee guidance on complaint handling
Last guidance
produced: No of % of
Less than 6 months ago 22 14%



6 to 12 months ago 25 16%
No guidance 30 20%
Total 152 100%

Time limits for responding and acknowledging complaints

117 Many RSLs do not monitor their performance in acknowledging or responding
to complaints. Time limits for acknowledging receipt of a complaint vary from 3
hours to 15 working days. Time limits for responding to a stage 1 complaint vary
from 12 hours to 30 working days. Panel hearings can be arranged in 3 to 40
working days.

Table 8: Response performance
Stage: Procedures Average time Procedures Performance
with time limits monitoring
limits performance
Acknowledging 138 4 working days 99 93.2%
Stage 1 134 9 working days 93 88.1%
Panel hearings 41 20 working days 22 86.8%

Complaint outcomes

118 72% of RSLs were able to provide information about the outcome of
complaints received during the last year.

Table 9: Complaints upheld or justified
Stage: Percentage
upheld
Stage 1 45.4%
Stage 2 47.9%
Stage 3 44.6%
Stage 4 31.1%
Ombudsman 22.3%
All stages 46.5%

118.1 Appendix D shows resident expectations when making a complaint to their
landlord. Many residents simply wanted the landlord to provide a service such as
carrying out a repair or dealing with neighbour nuisance. The chart shows that
younger residents are more likely to want to see the landlord improve procedures and
customer care, apologise and, where necessary, pay compensation.

Table 10a: Resident satisfaction with outcome of complaint
Satisfied Dissatisfied
RSL type No of % of No of % of
respondents respondents respondents respondents
Small 16 48.5% 12 36.4%
Large 37 19.8% 121 64.7%
LSVT 11 29.7% 21 56.7%
BME 1 6.7% 14 93.4%
Specialist 8 36.3% 10 45.5%
Rural 2 40% 1 20%



Community 6 19.4% 20 64.5%
Almshouse 4 80% 0 0%
Not known 0 0% 0 0%
ALL 78 26.3% 210 57.4%

118.2 Resident satisfaction with the outcome of a complaint is low but marginally higher
than satisfaction with complaint handling.

119 57.4% of residents are dissatisfied with the outcome of making a complaint to
their landlord. Only 26.3% are satisfied. This is very similar to NHS complainants
where 26% are satisfied with the outcome (DoH, 2001). Table 10b compares
satisfaction with complaint outcome to data collected by MORI (MORI, 1995).
The comparison shows that satisfaction with complaint outcome has fallen
and dissatisfaction has increased since that survey was carried out.

Table 10b: Resident satisfaction with outcome of complaint
1995 2001
No of % of No of % of
Satisfied 48 32% 78 26%
Dissatisfied 67 45% 210 57%
Total 149 338

120 During 1995, black and minority ethnic resident satisfaction with complaint
outcomes was lower than the overall rating3. The satisfaction rating has now
marginally improved but dissatisfaction has increased from 43% to 64%.

Table 10c: Black and minority ethnic resident satisfaction with outcome of
complaint
1995 2001
No of % of No of % of
Satisfied 27 20% 8 22%
Dissatisfied 58 43% 23 64%
Total 134 36

Customer satisfaction with complaint handling

121 Only 9% of RSLs were able to provide information about the level of customer
satisfaction with complaint handling during the last year; these RSLs had higher
than average levels of complainant satisfaction.
§ An average of 65% of complainants they surveyed were satisfied with
complaint handling.
§ An average of 19.5% were dissatisfied.
RSLs who monitored customer satisfaction had upheld 51% of the complaints
they received.

122 Table 11a shows how greatly this differs from overall resident satisfaction with
complaint handling. Only 23% of residents stated that they were satisfied
with the way their complaint was handled. During 2000, all local authorities
carried out surveys of satisfaction with complaint handling. The surveys showed



that 36% of respondents were satisfied and 55% were dissatisfied. The new
unitary authorities rated 43% satisfaction and inner London boroughs rated only
25% satisfaction (ALG, 2001). The recent National Health Service review of
satisfaction with complaint handling found 30.3% satisfied and 49.4% dissatisfied
with complaint handling (DoH, 2001).

Table 11a: Resident satisfaction with handling of complaint
RSL type No of % of No of % of
Small 16 48.5% 12 36.4%
Large 34 18.2% 124 66.4%
LSVT 7 18.9% 27 72.9%
BME 1 6.7% 13 86.7%
Specialist 8 36.3% 10 45.5%
Rural 2 40% 2 40%
Community 5 16.2% 22 70.9%
Almshouse 4 80% 0 0%
Not known 1 0% 0 0%
ALL 78 23% 210 62.1%

123 28% of complainants who contact the IHO when making a complaint are
satisfied and 62% are dissatisfied (ORC International, 2000).

124 Our comparative analysis of resident satisfaction by ethnicity, gender,
disability and age shows:
§ Black and black British are more likely to be dissatisfied with the handling
of a complaint than other ethnic groups (table 11b).
§ Asian and Asian British are more likely to be satisfied with complaint
handling than other ethnic groups (table 11b).
§ Only 19% of male respondents are satisfied compared to 25% of female
respondents (table 11d).
handling compared to 37% of respondents aged over 60 (table 11c).
§ Little difference between respondents who have long-term illness, health
problem or disability that limits their daily activities or the work they do and
respondents who do not (table 11d).

Table 11b: Resident satisfaction with handling of complaint and ethnicity of
respondents
Ethnicity of No of % of No of % of
respondents respondents respondents respondents respondents
White British 66 24.2% 164 60.1%
Black or Black 1 7.1% 12 85.7%
British
Asian or Asian 4 33.3% 8 66.6%
British
Mixed parentage 0 0% 5 71.4%
Other 1 33.3% 2 66.3%
Not known 6 22.2% 19 70.4%
ALL 78 23% 210 62.1%

Table 11c: Resident satisfaction with handling of complaint and gender of
respondents


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