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Complaint Handling Code 2023
We want to respond to your complaints fairly and effectively. This code helps us do just that.
The next self-assessment will be live on our website from July 2024 in line with the new Housing Ombudsman code.
We look at the way we handle complaints every year. This is our 2023 self-assessment, showing how we comply with the Housing Ombudsman's Complaints Handling Code. You can download a PDF or read the table below.
Live in one of our homes?
The Code is a guide for you - our customers - and shows what you can expect when you raise a complaint from us.
Peaks & Plains Complaints Self-Assessment
| Code section |
Code requirement |
Comply: Yes | Comply: No | Evidence, commentary and any explanations |
| 1.2 | A complaint must be defined as: ‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents. |
X | The Ombudsman's definition of a complaint is included in the Peaks & Plains policy and procedure.
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| 1.3 |
The resident does not have to use the word ‘complaint’ for it to be treated as such. A complaint that is submitted via a third party or representative must still be handled in line with the landlord’s complaints policy. |
X |
All expressions of dissatisfaction are logged, including when the word ‘complaint’ is not used by the customer. Service requests are logged and given to the relevant team to action. Contacts are triaged by Customer Experience team to ensure the issue is logged accordingly. The Trust accept complaints from advocates acting on behalf of customers.
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| 1.4 |
('Should' requirement) Landlords should recognise the difference between a service request, where a resident may be unhappy with a situation that they wish to have rectified, and a complaint about the service they have/have not received. |
X |
All customer contacts are triaged at the first point of contact to clarify if they are a service request, or a complaint. Our Customer Experience team are trained to distinguish the difference.
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| 1.5 |
('Should' requirement) Survey feedback may not necessarily need to be treated as a complaint, though, where possible, the person completing the survey should be made aware of how they can pursue their dissatisfaction as a complaint if they wish to. |
X |
If a customer reports dissatisfaction on a transactional survey this is logged and our Complaints Coordinator will follow up with the customer to resolve. |
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| 1.6 |
… if further enquiries are needed to resolve the matter, or if the resident requests it, the issue must be logged as a complaint. |
X |
This is assessed at the triage stage and then recorded as a complaint. Read the Complaints Policy |
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| 1.7 |
A landlord must accept a complaint unless there is a valid reason not to do so. |
X |
All matters are assessed at triage stage and recorded appropriately. If there is a valid reason for the issue not to be logged as a complaint, for example if it is a first request.
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| 1.8 |
A complaints policy must clearly set out the circumstances in which a matter will not be considered, and these circumstances should be fair and reasonable to residents. |
X |
The Trust's complaints policy clearly outlines exclusions.
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| 1.9 |
If a landlord decides not to accept a complaint, a detailed explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman. |
X |
If a decision is made not to accept a complaint, a full response is provided to the customer setting out the reason(s) the complaint has not been accepted. All complaints letters sent to customers include their right to take the decision to the Housing Ombudsman. A copy of the complaints process infographic is also sent to the customer to advise of the process.
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| 2 | Accessibility and awareness | |||
| 2.1 | Landlords must make it easy for residents to complain by providing different channels through which residents can make a complaint such as in person, over the telephone, in writing, by email and digitally. While the Ombudsman recognises that it may not be feasible for a landlord to use all of the potential channels, there must be more than one route of access into the complaints system. |
X |
Customers can make a complaint via their preferred channel; face to face, over the telephone, by email, letter, via their online account, our website, or a social media channel. This is explained in the customer complaints section of our website, on the Complaints process infographic and detailed in the policy.
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| 2.2 |
('Should' requirement) Where a landlord has set up channels to communicate with its residents via social media, then it should expect to receive complaints via those channels. Policies should contain details of the steps that will be taken when a complaint is received via social media and how confidentiality and privacy will be maintained. |
X |
Guidance on the handling of social media complaints is included in our complaints policy. |
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| 2.3 | Landlords must make their complaint policy available in a clear and accessible format for all residents. This will detail the number of stages involved, what will happen at each stage and the timeframes for responding. | X |
The complaints policy and procedure is available on our website. Customers may request a hard copy, CD, Braille, large print or translation of the policy which the Complaints Team will send via post. There is also a ‘Sight Accessibility’ feature on the website. |
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| 2.4 | Landlord websites, if they exist, must include information on how to raise a complaint. The complaints policy and process must be easy to find on the website. | X |
The information is available on the Trust's complaints page on our website. |
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| 2.5 | Landlords must comply with the Equality Act 2010 and may need to adapt normal policies, procedures, or processes to accommodate an individual’s needs. Landlords must satisfy themselves that their policy sets out how they will respond to reasonable adjustments requests in line with the Equality Act and that complaints handlers have had appropriate training to deal with such requests. | X |
The Trust has an EDI Policy. All staff undergo regular EDI training. An EDI Committee operate within the Trust where complaints relating to EDI are discussed. |
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| 2.6 | Landlords must publicise the complaints policy and process, the Complaint Handling Code and the Housing Ombudsman Scheme in leaflets, posters, newsletters, online and as part of regular correspondence with residents. |
X |
The Trust publish the policy and code on our website. Information about the Complaints process is published online and in newsletters. The Trust issue a complaints process leaflet with every Investigation and Review stage complaint acknowledgement. |
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| 2.7 | Landlords must provide residents with contact information for the Ombudsman as part of its regular correspondence with residents. | X |
The Ombudsman’s contact details are |
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| 2.8 | Landlords must provide early advice to residents regarding their right to access the Housing Ombudsman Service throughout their complaint, not only when the landlord’s complaints process is exhausted. | X |
The Ombudsman’s contact details are
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| 3 | Complaint handling personnel | |||
| 3.1 | Landlords must have a person or team assigned to take responsibility for complaint handling to ensure complaints receive the necessary attention, and that these are reported to the governing body. This Code will refer to that person or team as the “complaints officer". | X |
The Customer Experience Manager and Complaints Coordinator are responsible for overseeing all complaints. Managers are responsible for stage 1 investigations and Senior Managers for stage 2 reviews.
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| 3.2 | …the complaint handler appointed must have appropriate complaint handling skills and no conflicts of interest. | X | Staff and Managers receive complaints training, the training is supported by the guidance provided in the complaints policy, procedure, compensation policy. Mandatory training will be undertaken by all new staff responsible for complaint investigations from November 2023. All staff Trust undertake annual ‘declaration of interest’ questionnaires. | |
| 3.3 |
('Should' requirement) Complaint handlers should:
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X | All points are covered in our complaints training and regular complaints meetings held with staff. Training videos will be accessed via the Trusts e-learning system and will be a mandatory requirement for staff to complete by the end of 2023. | |
| 4 | Complaint Handling Principles | |||
| 4.1 | Any decision to try and resolve a concern must be taken in agreement with the resident and a landlord’s audit trail/records should be able to demonstrate this. Landlords must ensure that efforts to resolve a resident’s concerns do not obstruct access to the complaints procedure or result in any unreasonable delay. It is not appropriate to have extra named stages (such as ‘stage 0’ or ‘pre-complaint stage’) as this causes unnecessary confusion for residents. When a complaint is made, it must be acknowledged and logged at stage one of the complaints procedure within five days of receipt. |
X |
Complaints are logged on our CRM. All correspondence both externally and internally are saved to a case file unique to that complaint. Stage 1 and Stage 2 complaints are acknowledged within 5 working days of receipt of the complaint being received.
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| 4.2 | Within the complaint acknowledgement, landlords must set out their understanding of the complaint and the outcomes the resident is seeking. If any aspect of the complaint is unclear, the resident must be asked for clarification and the full definition agreed between both parties. |
X |
Our Complaints Coordinator is trained to write acknowledgement letters and to break down the reasons for the complaint – demonstrating understanding of the complaint and desired outcomes in writing. If the issues are not clear, the Coordinator will contact the customer to discuss in more detail.
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| 4.3 | ('should requirement') Landlords should manage residents’ expectations from the outset, being clear where a desired outcome is unreasonable or unrealistic. | X | This is built into our internal procedure as part of the assessment stage of a complaint. Staff are trained to manage expectations at first point of contact. | |
| 4.4 | ('should' requirement) A complaint should be resolved at the earliest possible opportunity, having assessed what evidence is needed to fully consider the issues, what outcome would resolve the matter for the resident and whether there are any urgent actions required. |
X | The complaint is triaged at first contact and action is taken from that stage. Customer Services are trained to ask what the customers desired resolution would be and manage expectations at the start. Any urgent matters are dealt with at that stage. | |
| 4.5 | ('Should' requirement) Landlords should give residents the opportunity to have a representative deal with their complaint on their behalf, and to be represented or accompanied at any meeting with the landlord where this is reasonable. |
X |
This is detailed in our complaints policy.
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| 4.6 | A complaint investigation must be conducted in an impartial manner. | X | All persons responsible for conducting investigations have been trained to take an impartial approach when responding to complaints. Additionally, our Complaints Coordinator quality checks all responses to ensure impartiality. | |
| 4.7 |
The complaint handler must:
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X | Full training has been provided to staff to ensure that this is adhered to. Additionally, a complaint investigation checklist has been provided to staff responsible for answering complaints which is also checked by the Complaints Coordinator before the written response is provided to the customer. | |
| 4.8 | ('Should' requirement) Where a key issue of a complaint related to the parties' legal obligations landlords should clearly set out their understanding of the obligations of both parties. | X |
Any legal obligations are explained as part of the Stage 1 or Stage 2 response.
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| 4.9 | ('Should' requirement) Communication with the resident should not generally identify individual members of staff or contractors. | X | Staff have received training to deal with this sensitively. | |
| 4.10 |
('Should' requirement) Landlords should keep residents regularly updated about the progress of the investigation. |
X |
Stage 1 process requires the investigator to contact the customer within 3 working days of receiving the acknowledgement letter.
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| 4.11 |
Landlords must adhere to any reasonable arrangements agreed with residents in terms of frequency and method of communication |
X |
Complaint handlers contact customers to discuss the complaint in more detail. This includes referring to the customers preferred method of contact, details which are stored on our system. Updates will be provided to the customer via their preferred contact method.
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| 4.12 |
The resident, and if applicable any staff member who is the subject of the complaint, must also be given a fair chance to:
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X |
If a complaint is made about a staff members behaviour, the complaint handler will discuss this with the colleague and ask them to set out their position. They will also have a chance to review the findings before a final decision is issued. |
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| 4.13 |
A landlord must include in its complaints policy its timescales for a resident to request escalation of a complaint. |
X |
The escalation process and timescales are included in the Stage 1 and Stage 2 letters and also our policy. It is also on the complaints process infographic available on the Trust’s website.
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| 4.14 |
A landlord must not unreasonably refuse to escalate a complaint through all stages of the complaints procedure and must have clear and valid reasons for taking that course of action. Reasons for declining to escalate a complaint must be clearly set out in a |
X |
This is covered in the complaints policy. We will advise customers in writing of the reasons why we have refused to escalate a complaint. Customers can refer to our exclusions list within our policy.
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| 4.15 |
A full record must be kept of the complaint, any review |
X | All case records are held on our CRM and all relevant documentation regarding the case will be stored in online files. | |
| 4.16 |
('Should' requirement) Landlords should seek feedback from its residents in relation to the landlord’s complaint handling as part of |
X | When the complaint case has been closed customers are invited to complete a satisfaction survey. The Trust also invites customers that have expressed a desire to be involved to attend feedback sessions. The Complaints Manager regularly attends the Customer Challenge Group meeting for feedback on the service. |
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| 4.17 |
('Should' requirement) Landlords should recognise the implact that being complained about can have on future service delivery. |
X |
Learning actions are summarised in the response letters and these are tracked by Service Managers on a quarterly basis and will be publicised to customers regularly. |
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| 4.18 |
Landlords must have policies and procedures in place for managing unacceptable behaviour from residents and/or their representatives when pursuing a complaint. |
X |
The Trust has an Unacceptable Behaviour policy.
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| 4.19 |
('Should' requirement') Any restrictions placed on a residents contact due to unacceptable behaviour should be appropriate to their needs and should demonstrate regard for the provisions of the Equality Act 2010. |
X |
Each case is assessed individually and dealt with sensitively to the customer’s needs.
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| 5 | Complaint stages | |||
| 5.1 | Landlords must respond to the complaint within 10 working days of the complaint being logged. Exceptionally, landlords may provide an explanation to the resident containing a clear timeframe for when the response will be received. This should not exceed a further 10 days without good reason. | X | Our Stage 1 response timescale is 10 working days which is measured and reported on the Monthly KPI report, quarterly to Board and Exec team and the Customer Challenge Group. | |
| 5.2 | ('Should' requirement - Stage 1) If an extension beyond 20 working days is required for the landlord to respond to the complaint fully, this should be agreed by both parties. | X |
The Complaints Coordinator will contact the customer to advise them of the delay, reasons why and will provide a new date.
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5.3 |
('Should' requirement - Stage 1) Where aregeement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details so the resident can challenge the landlord’s plan for responding and/or the proposed timeliness of a landlord’s response. | X |
The Housing Ombudsman contact details are provided to customers in all complaint correspondence and on our website. The details are also available on the Complaints process infographic.
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| 5.4 | ('Should' requirement - Stage 1) Where the problem is a recurring issue, the landlord should consider any older reports as part of the background to the complaint if this will help to resolve the issue for the resident. | X | The complaints handlers, along with the complaints coordinator when required will carry out a full investigation including reviewing historic data and/or documentation. | |
| 5.5 | A complaint response must be sent to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue, are completed. Outstanding actions must still be tracked and actioned expeditiously with regular updates provided to the resident. |
X | This forms part of our internal procedure. Outstanding actions are recorded and monitored by the relevant managers and complaints team. | |
| 5.6 | Landlords must address all points raised in the complaint and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate. |
X |
This is required as part of our Stage 1 and Stage 2 outcome letter templates. Staff have received training to ensure this is adhered to and this will be a mandatory requirement of all new staff.
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| 5.7 | ('Should' requirement - stage 1) Where residents raise additional complaints during the investigation, these should be incorporated into the stage one response if they are relevant and the stage one response has not been issued. Where the stage one response has been issued, or it would unreasonably delay the response, the complaint should be logged as a new complaint. | X |
For instances where a customer raises additional complaints during the investigation, the Investigating Manager will include these within the stage 1 response. Where customers raise additional issues following the Stage 1 response being completed a new complaint case will be logged.
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| 5.8 | Landlords must confirm the following in writing to the resident at the completion of stage one in clear, plain language: • the complaint stage • the decision on the complaint • the reasons for any decisions made • the details of any remedy offered to put things right • details of any outstanding actions • details of how to escalate the matter to stage two if the resident is not satisfied with the answer |
X |
This is required as part of our Stage 1 and Stage 2 outcome letter templates. Staff have received training to ensure this is adhered to.
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| 5.9 | If all or part of the resident's complaint is not resolved to their satisfaction at stage one, it must be progressed to stage two of the landlord’s procedure, unless an exclusion ground now applies. In instances where a landlord declines to escalate a complaint it must clearly communicate in writing its reasons for not escalating as well as the resident’s right to approach the Ombudsman about its decision. |
X |
This forms part of our internal procedure and is included in the Complaints policy.
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| 5.10 | On receipt of the escalation request, landlords must set out their understanding of issues outstanding and the outcomes the resident is seeking. If any aspect of the complaint is unclear, the resident must be asked for clarification and the full definition agreed between both parties. |
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This forms part of our internal procedure.
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| 5.11 | Landlords must only escalate a complaint to stage two once it has completed stage one and at the request of the resident | X |
Complaints are initially investigated at quick fix or stage 1 depending on the complexity of the case. If we are unable to resolve a complaint to the customer’s satisfaction at the stage 1, a customer can ask to escalate their complaint to the next stage, stage 2 of our policy.
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| 5.12 | The person considering the complaint at stage two, must not be the same person that considered the complaint at stage one. | X |
Complaints are investigated by Complaints Handlers. Stage 2 complaints are assigned to a Senior Manager or Head of Service who has not been involved in the original investigation.
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| 5.13 | Landlords must respond to the stage two complaint within 20 working days of the complaint being escalated. Exceptionally, landlords may provide an explanation to the resident containing a clear timeframe for when the response will be received. This should not exceed a further 10 days without good reason. |
X |
To ensure complaints do not exceed the timescales we send diary invites to the investigating officer. Performance is monitored daily by the complaints team. We will respond to a stage 2 complaints within 20 working days of the complaint being received. In instances where we are unable to provide a response within 20 working days, we will contact the customer and inform them that an extension is required and advise of a new date when the response will be provided which would not exceed 10 days.
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| 5.14 | ('Should' requirement - stage 2) If an extension beyond 10 working days is required to enable the landlord to respond to the complaint fully, this should be agreed by both parties. | X |
The complaints coordinator contacts the customer and informs them of any delay in providing a full response and also informs them of the new date the complaint response will be issued.
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| 5.15 | ('Should' requirement - stage 2) Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details so the resident can challenge the landlord’s plan for responding and/or the proposed timeliness of a landlord’s response | X |
The Housing Ombudsman contact details are provided to customers in all complaint correspondence and on the complaints process infographic.
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| 5.16 | Landlords must confirm the following in writing to the resident at the completion of stage two in clear, plain language:
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X |
The details are provided for all stage 2 complaints correspondence. Letters are structured using the Ombudsman template which covers all of the requirements.
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| 5.17 | Two stage landlord complaint procedures are ideal. This ensures that the complaint process is not unduly long. If landlords strongly believe a third stage is necessary, they must set out their reasons for this as part of their self-assessment. A process with more than three stages is not acceptable under any circumstances. |
X |
The Trust operates a two stage process with option to escalate to the Housing Ombudsman.
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| 5.18 | Complaints should only go to a third stage if the resident has actively requested a third stage review of their complaint. Where a third stage is in place and has been requested, landlords must respond to the stage three complaint within 20 working days of the complaint being escalated. Additional time will only be justified if related to convening a panel. An explanation and a date for when the stage three response will be received should be provided to the resident. |
X | The Trust does not operate a stage 3 process. | |
| 5.19 | Where agreement over an extension period cannot be reached, landlords should provide the Housing Ombudsman’s contact details so the resident can challenge the landlord’s plan for responding and/or the proposed timeliness of a landlord’s response. | X | The Trust does not operate a stage 3 process. | |
| 5.20 | Landlords must confirm the following in writing to the resident at the completion of stage three in clear, plain language:
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X |
The Trust operates a 2 stage process with an option of a quick fix resolution for less complex cases.
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| 6 | Putting things right | |||
| 6.1 |
Effective dispute resolution requires a process designed to resolve complaints. Where something has gone wrong a landlord must acknowledge this and set out the actions it has already taken, or intends to take, to put things right. |
X |
This is covered in our complaints
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| 6.2 |
Any remedy offered must reflect the extent of any service failures and the level of detriment caused to the resident as a result. A landlord must carefully manage the expectations of residents and not promise anything that cannot be delivered or would cause unfairness to other residents. |
X |
This is included in our Compensation
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| 6.3 |
('Should' requirement) Landlord should look beyond the circumstances of the individual complaint and consider whether anything needs to be ‘put right’ in terms of process or systems to the benefit of all residents. |
X | The Complaints team records all learning outcomes and discuss these at quarterly complaints meetings. System failures or process reviews are considered and actions take place as a result. All actions will be logged on our risk and action system by the end of 2023 | |
| 6.5 |
The remedy offer must clearly set out what will happen and by |
X |
This is covered in our complaints
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| 6.6 |
In awarding compensation, a landlord must consider whether |
X |
This is included in our Compensation
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| 6.7 |
('Should' requirement) In some cases, a resident may have a legal requirement to redress. The landlord should still offer a resolution where possible, obtaining legal advice as to how any offer of resolution should be worded. |
X | The Trust will provide the customer with a resolution to their complaint and when required consult for legal advice. | |
| 7 |
Section 7 - Continuous learning and improvement |
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| 7.2 |
Accountability and transparency are integral to a positive |
X |
The Complaints team will report on wider learning and improvements from complaints regularly on our website, within the annual report and to Customer groups. |
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| 7.3 |
('Should' requirement) A member of the governing body should be appointed to have lead responsibility for complaints to support a positive complaint handling culture. This role will be responsible for ensuring the governing body receives regular information on complaints that provides insight to the governing body on the landlord’s complaint handling performance. |
X | Complaints handling performance will be reported on a monthly and quarterly basis to our Board member 'Complaint Champion'. | |
| 7.4 |
('Should' requirement) As a minimum, governing bodies should receive: • Regular updates on the volume, categories and outcome of |
X | Complaints handling performance is reported to the Board at each meeting with a more detailed report being presented annually. The Board also receives information about cases which result in findings of maladministration. | |
| 7.5 |
('Should' requirement) Any themes or trends should be assessed by senior management to identify potential systemic issues, serious risks or policies and procedures that require revision. They should also be used to inform staff and contractor training. |
X | Themes are reviewed on a quarterly basis by SLT. | |
| 7.6 |
('Should' requirement) Landlords should have a standard objective in relation to complaint handling for all employees that reflects the need to: |
X | The Complaints Manager meet with all Mangers responsible for complaint handling every quarter. Senior Management Team meet monthly to review insight and act upon. Complaints Handlers will complete the online training by the Housing Ombudsman on Dispute Resolution. The Trust are part of the Northwest complaints forum to share knowledge/best practice within the sector. | |
| 8 | Self-assessment and compliance | |||
| 8.1 | Landlords must carry out an annual self-assessment against the Code to ensure their complaint handling remains in line with its requirements. |
X | The Trust's Complaints Team carries out an annual self-assessment each year as recommended by the Housing Ombudsman. | |
| 8.2 |
Landlords must also carry out a self-assessment following a |
X | In cases of a significant restructure and/or changes to a procedure occur, the Complaint Team will carry out a fresh self-assessment. | |
| 8.3 |
Following each self-assessment, a landlord must: |
X |
Self-assessment will be shared with Board and Customer Groups as well as our website and annual report. |