Our Complaints Policy

1.1 Origin is committed to providing a good quality service to all customers. However, we recognise that sometimes people will have cause for dissatisfaction with our service and will wish to make a complaint.

1.2 We will investigate complaints in a confidential and respectful manner, keeping the customer fully informed throughout the process.

1.3 Wherever possible we will seek to resolve complaints informally to achieve a swift and satisfactory outcome for the customer without the need for a formal complaint.

1.4 We take learning from complaints seriously and will ensure that lessons learnt from the complaint process are used to inform service improvements.

1.5 In certain circumstances we may consider paying compensation as part of a complaint resolution, details of which are set out in our compensation procedure and through using the guidance set out by the Housing Ombudsman in their ‘remedies’ guidance.

1.6 Complaints from leaseholders regarding service charges should be referred to the First Tier Tribunal (Property Chamber).

2.1 All staff and managers are responsible for ensuring they work to the policy objectives.

2.2 By publishing this policy statement, we aim to ensure we deliver against the policy objectives.

Key objectives: 
• Deal with customer complaints swiftly and fairly
• Provide a resolution focused service
• Raise overall levels of customer satisfaction
• Ensure compliance with our statutory and regulatory obligations

3.1 A complaint is 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.

3.2 A service request is a request from a customer requiring action to be taken to put something right. Service requests are not complaints, but are recorded, monitored, and regularly reviewed.

3.3 We have a clear distinction between a request for a service (service request) and a complaint about a service. This policy relates to complaints about services. Service requests will be treated as a complaint if we fail to deal appropriately with the initial request.

3.4 Service requests will also be logged as a complaint if further enquiries are needed to resolve the matter, or if the customer requests it or if they express dissatisfaction with the response.

3.5 The customer does not have to use the word ‘complaint’ for it to be treated assuch.

3.6 A complaint that is submitted via a third party or representative will still be handled in line with our complaints policy
    

4.1 Who can complain?

The following people can log a complaint in accordance with this policy and
where appropriate escalate it through both stages of our complaints procedure:

Any Origin resident

• Anyone who is in receipt of a service or is affected by a service that is provided by Origin. 
• Anyone who may potentially receive a service from Origin, for example, someone who is applying for a service.
• Customers are welcome to make a complaint via an advocate. Where a complaint is made via an advocate, we will need the customer’s written consent.
• An advocate or representative, on behalf of the customer, can also deal with their complaint.
• They can also represent or be present or accompany the customer at any meeting with us, where this is reasonable.

4.2 We are not able to investigate complaints about services, organisations and individuals for which Origin is not responsible.

4.3 Exclusions

4.4 We will accept a complaint unless there is a valid reason not to do so. We adopt a fair and reasonable approach in these circumstances. Each complaint is considered on its own merits.

4.5 The responsibility for the final decision not to accept a complaint lies with the Head of Customer Services, or an Executive Director

4.6 Although a customer may use the term complaint, there are circumstances in which a matter will not be considered a complaint within this policy.

Examples include:

Requesting a service for the first time (service request) – e.g. reporting a repair or notifying us of an anti-social behaviour (ASB) incident.

Anti-Social Behaviour – reports of anti-social behaviour will not usually be managed through our complaints procedure and will instead be managed through our ASB procedure. We will only investigate a complaint about ASB if it’s in relation to the way it was handled by a member of staff.

Complaint relating to an issue that occurred more than 12 months ago
Discretion may be used if there is a valid reason for the delay or it relates to a safeguarding concern or health and safety issue. Where there is a long-standing issue, we will consider older reports as part of the background to the complaint if this helps to resolve the issue for the customer.

Legal proceedings have started
This is defined as details of the claim, such as the Claim Form and Particulars of Claim, having been filed at court. 

Matters that have previously been considered under the complaints policy.

A vexatious complainant as specified in our Unacceptable behaviour policy. See also Unacceptable Behaviour section below.

Complaints relating to Service Charges from Leaseholders
These are best managed through the First Tier Tribunal although we will always try to resolve these concerns informally, where we can. We will consider complaints about communication in respect of service charges, the level of service delivery or the process in respect of service charge setting. 

4.7 Where we do not accept a complaint, we will provide the customer with a detailed explanation setting out the reasons why the matter is not suitable for our complaints process.

4.8 Where we advise a customer that we are not accepting a complaint, the customer will have the right to challenge this decision and raise a complaint to the Housing Ombudsman Service. Details of how to contact the Housing Ombudsman can be found at section 5.0, below. Customers can also request contact details of the Housing Ombudsman from a staff member.

4.9 Making a complaint

We ensure customers can easily make a complaint without restriction. Customers can express their dissatisfaction in whichever way they choose. It is not necessary for a complaint to be made in writing. Complaints can be made to any member of staff or contractor, in the following ways:

• email
• visiting an office
• telephone
• completing a customer complaints form
• through a feedback survey
• face to face to any staff member or Origin representative
• through a third party e.g. an advocate, staff member or
  support worker, MP Councillor
• social media including Twitter, Facebook, Live Chat &
  WhatsApp

4.10 Complaints received via social media

Where a complaint is received via social media, whilst it will be acknowledged using that same channel, we will contact the customer requesting to explore if they wish to provide contact details to further investigate the complaint.
At all times we will respect the confidentiality and privacy concerns for all customers.

A decision will be made at the time of receiving the complaint if we have sufficient details to record a formal complaint and we will always explore if the customer wishes to receive a formal complaint investigation and response. If so, this will be logged and acknowledged, investigated, and responded to in line with this policy.

If a customer wishes to remain anonymous, or raises issues of confidentiality and privacy, we may be able to continue to investigate the details of the issue, where the evidence provided permits this, but would not necessarily log this through our formal complaints process.

Any decision in respect of this, will always be a decision by the Head of Customer Services or an Executive Director, and our actions and rationale recorded. Our aim is always to work to resolve customer’s issues, even if logging a formal complaint is not the process they wish to specifically follow.

For all other complaints, our method of communication will be in line with the customers preferred method of communication.

In addition to the above, there is also a dedicated complaints email account 
(complaints@originhousing.org.uk) which customers can use. They can also use an online form available via the Origin website.

4.11 Complaint stages

We will always try to resolve a dispute as quickly as possible with our customers and recognise that not all customers will wish to follow a formal process and may simply want an issue resolved. We will look to early and local resolution of issues.

We also encourage any customer using the complaints process to make us aware of any reasonable adjustments that they may require, in order to make the complaints process more accessible to them. The officer investigating the complaint will be able to discuss this on a case-by-case basis.

Our aim, and in line with this policy, is to it acknowledge and log a formal complaint at stage one of our complaints procedure, and within five working days of receipt.

We have a two stage formal complaints procedure coordinated by our Customer Relations Team:

Stage 1
At the start of a stage 1 complaint investigation, we will contact the customer via their channel of choice, to gain an understanding of the issues and the outcome the customer is seeking. We call this the “complaint definition”.

If any aspect of the complaint is unclear, the customer is asked for clarification and the full definition agreed between both us and the customer.

A full written response to the complaint will then be sent out as soon as possible and in any event within 10 working days. Where it is not possible to provide a full response within 10 working days, we will contact the customer to explain this, setting out the reasons why and when they can expect to receive the response.

On occasions, it may be necessary to extend the date for a full response by up to a further 10 working days to enable us to respond fully. We will not exceed this additional time estimate without good reason. Our approach is to explain this to the customer.

When we inform a customer about any extensions to timescales, we will provide them with the contact details of the Housing Ombudsman.

A complaint response will be provided to the customer when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. We will track outstanding actions and ensure these are actioned promptly with appropriate updates provided to the customer. This applies to both stage 1 and stage 2 complaints.

There are times where we may provide our formal stage 1 (or stage 2) response but there are still practical matters, such as a repair that is awaiting a part, that are still outstanding. In this instance, we may send the formal stage 1 response, including an offer of compensation if appropriate, but we are committed to working with the customer until all of their concerns 
are resolved.

The quality and standard of stage 1 responses will be overseen by the Customer Relations and Quality Assurance Manager who will regularly carry out quality control and assurance on complaints.

Where customers raise additional complaints during the investigation, this will 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

Stage 2
If all or part of the complaint is not resolved to the customer’s satisfaction at stage 1, it will be progressed to stage 2 of our complaints process. A Stage 2 complaint response is our final complaint response.

This request should be made within 10 working days of the stage 1 response. Requests made outside of this time will be considered by the Head of Customer Services and/or Director of Resident Services.

We will not unreasonably refuse to escalate a complaint to stage 2.

A customer does have to explain their reasons for requesting a stage 2. We will make reasonable efforts to understand why a customer remains unhappy as part of our stage 2 investigation and response.

Where a request for escalation to stage 2 is made, careful consideration will be given to determine if it warrants a review at stage 2 of our process. If the only element that the customer remains dissatisfied with is compensation, we will carry out a review of the compensation amount offered rather than a full stage 2 investigation. A compensation review will be undertaken by a senior manager, such as a Head of Service, who would otherwise be involved in reviewing the complaint at stage 2.

A stage 2 complaint investigation will usually focus on:

• Whether all elements of the stage 1 complaint were investigated and considered appropriately.
• Whether relevant policies or procedures relating to the service area were followed
• Whether the way in which the complaint was handled was fair and appropriate.
• Whether there is any further information or evidence that is now available, that was not supplied or available at the time of the initial investigation.
• Whether appropriate redress and apology was given if required.

At the start of a stage 2 complaint investigation, we will contact the customer via their channel of choice, to gain an understanding of the issues and the outcomes the customer is seeking. We call this the “complaint definition”.

If any aspect of the complaint is unclear, the customer is asked for clarification and the full definition agreed upon by the customer.

There may be some instances where we deny a request to escalate the complaint to stage 2 and the reasons for this are set out in section 8.0 of this policy. We will not usually escalate a complaint to stage 2 if the original complaint was fully investigated, where we followed our own policies and procedures correctly and all of the points of the complaint were addressed, 
even if the customer remains dissatisfied with the overall outcome. We cannot consider a complaint being escalated to stage 2 without the complainant providing clear reasons as to why this is being requested and what outcomes are being sought. A complaint must have gone through stage 1 of our complaints procedure and cannot enter the complaints process at stage 2.

Where escalation to stage 2 is denied, we will make clear that the previous response was a final response to the complaint and will provide information on the Housing Ombudsman Service. We will also provide full reasons for our decision.

At stage 2, the review will be carried out by the appropriate next level manager who has not previously been involved in the complaint, usually a Head of Service or Assistant Director. This manager will not have previously been directly involved in the complaint investigation.

All stage 2 complaint responses are quality checked and reviewed by an Executive Director before they are issued to customers.

We will ensure that the customer is given a fair opportunity to set out their position and comment on any adverse findings before a final decision is made.

The allocated staff member will aim to respond to the stage 2 response as soon as possible. 

We will decide whether we can accept a stage 2 within 5 working days of the escalation being received, and will carry out our investigation, and provide the customer with a response within 20 working days.

In very limited circumstances where it is not possible to provide a full response within 20 working days, we will contact the customer to explain this, setting out the reasons why and when they can expect to receive the response. In this circumstance, we may extend the time we have to investigate and respond to the complaint by a further 20 working days, but not without good reason, and we will clearly explain the reasons to the customer.

We will deal with all points raised in the complaint and provide clear reasons for any decisions.

Where we inform a customer about an extension or where agreement over an extension period cannot be reached, we will provide customers with the Housing Ombudsman’s contact details so the customer can challenge our decision.

4.12 Complaint outcomes

Complaints can be resolved in several ways. The outcome of a formal complaint will be:

• Upheld – this means that the customer’s reasons for dissatisfaction with Origin are justified
• Partially upheld – this means that some of the customer’s reasons for dissatisfaction are justified but that some of the issues or claims raised by the
• customer are unfounded, unreasonable or not the fault of Origin
  Not upheld – this means that none of the customer’s reasons for dissatisfaction with Origin are justified.

4.13 Complaint remedies

Any remedy offered will reflect the impact on the customer because of any fault or service failing identified.

Where something has gone wrong, we will acknowledge this and set out the actions we have already taken, or intend to take, to put things right. These can include:

• Apologising
• Acknowledging where things have gone wrong
• Providing an explanation, assistance, or reasons
• Taking action if there has been delay
• Reconsidering or changing a decision
• Amending a record or adding a correction or addendum
• Providing a financial remedy
• Changing policies, procedures, or practices

Whilst we are committed to working in partnership with our customers, we recognise that there may be instances where customers feel the need to seek external support or advice in getting their complaints resolved. The Housing Ombudsman service can provide support if we have refused to investigate a complaint, have refused to escalate a complaint from stage 1 to stage 2 or if a customer remains dissatisfied after we have concluded our stage 2 
investigation.

Contact details for the Housing Ombudsman can be found on our website, and also on our formal complaint responses at stages 1 and 2, and are also set out below:

E-mail: info@housing-ombudsman@org.uk
Website: Contact us - Housing Ombudsman (housing-ombudsman.org.uk)

The Ombudsman do not look at the original problem, for example, they do not determine whether there was anti-social behaviour or if a home has mould. Rather, they look at whether a landlord has dealt with the reported problem in line with the tenancy agreement, lease, or its own policies. The Housing Ombudsman Service will usually only investigate complaints whereby there is a landlord and tenant relationship.

A customer can contact the Housing Ombudsman at any point during our complaints process.

Sensitive complaints, such as those relating to staff members, or to people who have disclosed sensitive personal information as part of their complaint will be flagged as ‘sensitive’ when the complaint is logged, to ensure additional confidentiality. See Data 

Protection and Equality & Diversity policies

Where a complaint is made about the conduct of a staff member, the complaint will usually be investigated by their manager as opposed to the Customer Relations Team. Support will be given to the investigating manager, if required, by the Head of Customer Experience to ensure that the complaints policy and procedure is applied consistently.

All complaints will be handled in accordance with the principles of the Data Protection Act 1998 and with our policy.

We reserve the right to use discretion when applying this policy and procedure. We may deal with a complaint differently where individual circumstances merit it. A Head of Service and any Executive Director have the authority to exercise this discretion. Actions taken may include (this list is not exhaustive):

• Not investigating a complaint as for example, it has been investigated before or not escalating a complaint through all 2 stages as detailed below
• Forwarding the complaint through our procedure more quickly than usual
• Referring the complainant to contact an alternative organisation such as the Housing Ombudsman Service, Supporting People Team or the Care Quality Commission at any point in the process
• Complaints where we are refusing the right to escalate (see section below)
• Action regarding a petition where a number of complainants are involved (the complaint would however be registered in the usual way with the lead customer’s name used to log the complaint)
• Dealing with anonymous complaints. Complaints can be made anonymously and recorded and investigated as appropriate so that issues can be remedied and learning opportunities identified

We will always provide explanations to customers where we have exercised our discretion.

There may be times when it would not be appropriate to escalate a complaint to stage 2 if the customer is still dissatisfied after the stage 1 response. An example of this could include where the outcome that is being sought is not within our power or ability to deliver it. The reasons why we may not escalate a complaint are the same reasons why we would not accept a complaint and are outlined in section 4.2 of this policy.

We will not unreasonably refuse to escalate a complaint and if there is evidence that our complaints policy has not been correctly applied, we will investigate the complaint at stage 2.

The decision to refuse escalation can only be decided by the Head of Customer Service or by a Director. The Head of Customer Service or Director will use the criteria set out in this policy to satisfy themselves that the complaint has been appropriately investigated before deciding whether to refuse the escalation.

When contacting the complainant with a decision not to escalate, they will be
provided with information about how we reached that conclusion, in writing, as well as being supplied with information on how to contact the Housing Ombudsman Service.

We recognise that people who are unhappy about an issue may show signs of stress or frustration when reporting a complaint and that such behaviour may be out of character; however, some complainants are so angry and/or persistent that their behaviour results in unreasonable demands on, or behaviour towards our staff. 

Where a customer has become unreasonably persistent, abusive or vexatious we reserve the right to take appropriate action for that particular situation which may include limiting who the customer can contact within Origin or stopping the investigation into the complaint where the circumstances merit this approach. 

Further details are set out in our Unacceptable Behaviour policy. Examples of unacceptable behaviour include:

• Treating staff in an abusive or threatening manner
• Refusing to respond to contact from staff, which makes it difficult to investigate and resolve a complaint
• Repeatedly contacting several members of staff about the same complaint to deliberately cause confusion in the complaints process.

9.1 Where a decision is made to limit customer contact, the decision will be made and communicated by the Head of Customer Service in conjunction with an Executive Director.

In line with the Equality Act 2010, we recognise we may need to adapt normal policies, procedures, or processes to accommodate a customer’s individual needs.

We will assist all customers who require help when making a complaint, including using our interpreting service. If a customer is unable to make a complaint themselves or would like the support of others, we are happy to receive complaints from a third party on their behalf. Examples include a friend or family member, a carer or support worker, an advocate, an MP 
or Councillor, a representative from the Citizens’ Advice Bureau or other organisation e.g. a residents’ association or community group.

Our customer complaints leaflet, which outlines the key aspects of this policy and procedure, can be translated or provided in alternative formats such as Braille, pictorial, large print, audio, Easy Read upon request. Guidance on how quickly the alternative format will be provided will be given at the time of request. Origin’s Communications Policy must be adhered to.

To further support customers, we have in place a ‘Reasonable Adjustment Policy’ to support the Complaints Policy. 

Details of this policy are available below:

Reasonable Adjustments Policy

Complaints performance will be reviewed on a regular basis by the Senior Management Group, Executive, Customer Services Committee and Board. Emphasis will be placed on:

• The nature of the complaints received
• Customer feedback
• Response performance
• Quality of complaint handling
• How complaints have been used to improve services

Senior Managers regularly meet to discuss, review, and implement lessons learnt from complaints so that we’re proactively reducing the need to complain and improving customer satisfaction with the services we provide.

Monitoring & Evaluation

Origin welcomes all customer feedback, good or bad, recognising its value in helping to make things fairer for customers and highlighting the aspects of our services that need to be improved.

We will make it easy for customers to complain by promoting the service, including the difference that complaint feedback has made, and by offering customers a range of way to express their dissatisfaction.

Our staff will encourage customers to provide feedback about our services, including complaints. Customer complaints will be dealt with confidentially and they will not affect the way that customers are treated by Origin in the future. Staff will reassure customers of this when receiving a complaint.

We monitor the number of complaints and the service areas to which they relate. We also monitor customer satisfaction with the complaints handling process through surveys.

All complaints and expressions of dissatisfaction are recorded and used as a means of improving the way we deliver services. We will seek to identify learning opportunities, both by reviewing complaints individually and by regularly reviewing the bigger picture to see what aspects of our services are complained about the most.

We will report back on wider learning and improvements from complaints to our customers, managers and staff.

This policy will be promoted to customers through:

• Customer leaflets and posters in office and scheme receptions and on the Origin website. (Alternative formats will be available upon request)
• Information on the Origin website

The policy will be communicated to staff through:

• Articles and guidance on the intranet
• Regular training
• Discussion at team meetings

The policy is designed to be applied to the management of live complaints. Customer feedback on the quality of service received monthly will be used to review the policy.

The Customer Relations and Quality Assurance Manager undertakes monthly quality assurance on complaint handling to ensure that we are investigating complaints in the most thorough, robust, and effective way possible