Complaint Handling Code

We want to respond to your complaints fairly and effectively. This code helps us do just that.

We look at the way we handle complaints every year. This is our 2022 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. You can find more about our complaints process here.

Peaks & Plains Complaints Self-Assessment

1

Definition of a complaint

Yes No Commentary
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 and Plains policy and procedure.
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. We accept complaints
from advocates acting on behalf of
customers.
1.4 

('Should' requirement) Landlords should recognise the difference between a sevice 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.
1.5

('Should' requirement) Survey feedback may not necessarily need to be treated as a complaint, though, where possible, the person completeing the survey should be made aware of how they can pursure their dissatisfaction as a complaint.

X   If a customer reports dissatisfaction on a transactional survey these are logged and our Complaints Coordinator will follow up with the customer to resolve.
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.
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, this will be explained to the customer in line with our policy.
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 Trusts complaints policy clearly outlines exclusions.
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 letters to customers include their right to take the decision to the Housing Ombudsman.
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.
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.
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. The website translates web content into all languages. Customers may request a hard copy of the policy which we will send to them via post.
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 Trusts complaints page on our website.
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   We have an EDI Policy.
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   We will publish on our website, newsletters and social media.
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
included in Stage 1 and Stage 2 letter templates.
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
included in Stage 1 and Stage 2 letter
templates. We also advise customers of this when responding to a ‘quick fix’ issue.
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 and responsible for overseeing all complaints. Managers are responsible for stage 1 investigations and Senior Managers for stage 2 reviews.
 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. All staff
Trust undertake annual ‘declaration of interest’ questionnaires.
3.3

('Should' requirement) Complaint handlers should:

• be able to act sensitively and fairly
• be trained to handle complaints and deal with distressed and upset residents
• have access to staff at all levels to facilitate quick resolution of complaints
• have the authority and autonomy to act to resolve disputes quickly and fairly.

X   All points are covered in our complaints training and regular complaints meetings held with staff. 
 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. We also offer a ‘quick fix’ resolution which is triaged and agreed with customer when the
complaint is first reported.
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.
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. 
 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:

• deal with complaints on their merits

• act independently and have an open mind

• take measures to address any actual or perceived conflict of interest

• consider all information and evidence carefully 

• keep the complaint confidential as far as possible, with information only disclosed if necessary to properly investigate the matter.

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.
 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.
 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. 
4.11

 Landlords must adhere to any reasonable arrangements agreed with residents in terms of frequency and method of communication

X   Complaint handlers will 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.
 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:

• set out their position

• comment on any adverse findings before a final decision is made. 

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.
 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.
 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
landlord’s complaints policy and must be the same as the reasons for not accepting a complaint.

X   This 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. 
 4.15

 A full record must be kept of the complaint, any review
and the outcomes at each stage. This must include the
original complaint and the date received, all correspondence with the resident, correspondence with other parties and any reports or surveys prepared

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
the drive to encourage a positive complaint and learning culture. 

X   When the complaint case has been closed. Customers are invited to complete a satisfaction survey.
4.17

('Should' requirement) Landlords should recognise the implact that being complained about can have on future service delivery.
Landlords should ensure that staff are supported and engaged in the complaints process, including the learning that can be gained. 

X   Learning actions are summarised in the Stage 1 response letter and these are tracked by Service Managers on a quarterly basis and will be publicised to customers regularly.
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 have an Unacceptable Behaviour policy.
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 customers needs.
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. 
 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.
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.
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.
X   This forms part of our internal procedure. Outstanding actions are recorded on the Action Plan 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. 
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, we 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.
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.
All letters are quality checked before they are sent by the Complaints Coordinator.
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.
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.
X   This forms part of our internal procedure.
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 stage 1. 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.
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.
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. 
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 inform them of the new date the complaint response will be issued. 
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. 
5.16 Landlords must confirm the following in writing to the resident at the completion of stage two in clear, plain language:
• the complaint stage
• the complaint definition
• 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
and
• if the landlord has a third stage, details of how to escalate the matter to stage three
• if this was the final stage, details of how to escalate the matter to the Housing Ombudsman Service if the resident remains dissatisfied. 
X   The details are provided for all stage 2 complaints correspondence. Letters are structured using the Ombudsman template which covers all of the requirements. 
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 operate a two stage process with option to escalate to the Housing Ombudsman.
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   We do not have 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   We do not have 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:
• the complaint stage
• the complaint definition
• 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 the Housing
Ombudsman Service if the resident remains dissatisfied
X   The Trust operates a 2 stage process only.
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
procedure and in the Stage 1 and Stage 2 outcome letters. 
 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
Procedure and guidance. 
 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   We record all learning outcomes and
discuss these at a monthly and quarterly complaint’s meetings. System failures or process reviews are considered and actions take place as a result.
 6.5

The remedy offer must clearly set out what will happen and by
when, in agreement with the resident where appropriate. Any
remedy proposed must be followed through to completion.

X   his is covered in our complaints
procedure and in the Stage 1 and Stage 2 outcome letters
6.6

In awarding compensation, a landlord must consider whether
any statutory payments are due, if any quantifiable losses have
been incurred, the time and trouble a resident has been put to
as well as any distress and inconvenience caused. 

X   This is included in our Compensation
Procedure and guidance.
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   We provide the customer with a resolution to their complaint and when required consult for legal advice.
7

Section 7 - Continuous learning and improvement

     
7.2

Accountability and transparency are integral to a positive
complaint handling culture. Landlords must report back on wider
learning and improvements from complaints in their annual
report and more frequently to their residents, staff and scrutiny
panels. 

X   We will report on wider learning and
improvements from complaints regularly on our website, within the annual report and to Customer groups.
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
complaints, alongside complaint handling performance including compliance with the Ombudsman’s orders
• Regular reviews of issues and trends arising from complaint
handling
• The annual performance report produced by the
Ombudsman, where applicable
• Individual complaint outcomes where necessary, including
where the Ombudsman made findings of severe maladministration or referrals to regulatory bodies. The implementation of management responses should be tracked to ensure they are delivered to agreed timescales. The annual self-assessment against the Complaint Handling Code for scrutiny and challenge.

X   Complaints handling performance is
reported on a monthly, quarterly and
annual basis. 
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:
• have a collaborative and co-operative approach towards
resolving complaints, working with colleagues across teams
and departments
• take collective responsibility for any shortfalls identified
through complaints rather than blaming others
• act within the Professional Standards for engaging with
complaints as set by the Chartered Institute of Housing.

X   We hold working groups each quarterly with SMT to review insight and act upon.
Complaints Handlers are encouraged to 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   We will carry 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
significant restructure and/or change in procedures.

X   In cases of a significant restructure and/or changes to a procedure occur, we will carry out a fresh self- assessment. 
 8.3

Following each self-assessment, a landlord must:
• report the outcome of their self-assessment to their governing body. In the case of local authorities, self-assessment outcomes should be reported to elected members
• publish the outcome of their assessment on their website if
they have one, or otherwise make accessible to residents
• include the self-assessment in their annual report section on
complaints handling performance

X   Self-assessment will be shared with Board and Customer Groups as well as our website and annual report.

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