The Housing Ombudsman Service (HOS) resolves disputes involving our residents in England when our internal complaints process has been exhausted. It produced a 'Spotlight report (662KB PDF)' on damp and mould with 26 recommendations on how landlords should address issues.
We have assessed ourselves against those recommendations, with the support of our National Resident Scrutiny Panel.
We’ve summarised our response to the report into five commitments to our customers:
- We have a zero-tolerance approach on damp and mould, with a four-step process to; identify, remedy, resolve and prevent damp and mould.
- Whenever we are contacted by customers about damp and mould, we will work with you to make sure we diagnose the problem at an early stage.
- We will tailor our approach based upon understanding your needs.
- We will make sure our teams have the skills and knowledge to tackle the issue effectively.
- We might not always get things right first time. Where we don’t, we’ll work with you to make sure we remedy the situation quickly.
You’ll find more detail in our full assessment below.
|1||Landlords should adopt a zero-tolerance approach to damp and mould interventions. Landlords should review their current strategy and consider whether their approach will achieve this.||
We have a zero-tolerance approach. Reflecting our Corporate Strategy, our teams are committed to putting our customers first. We have reviewed the scripts at our contact centres, where customers first get in touch with us to make a report, to make sure we continue to be thorough in our initial diagnosis of damp and mould, and don't apportion blame. Through this we ensure we take the right action, starting with appropriate cleaning and treatment if mould is diagnosed, through to more intensive resolution when more severe damp is identified. This includes moving a resident to alternative accommodation, should that be necessary. This is considered on a case-by-case basis taking account of the individual circumstances.
We have devoted more resources, including our Housing 360 team, to triage reports of damp and mould through a new referral process. This will ensure, where needed, initial property visits happen faster, and issues are followed through to resolution even more effectively. We are improving our systems to ensure the data we hold supports this by having 360-degree view of our residents and homes. We will use this so we can track specific damp and mould cases on a completely live basis.
Update – July 2023
The damp and mould task force continues to pro-actively monitor and manage our strategic approach to damp and mould, and trends in performance.
The zero tolerance approach is further embedded now, reflected in the first of our public commitments for how we manage reports of damp and mould.
Where we have identified longer-term cases of damp and mould, we are also now trialling smart thermostats in customers homes to assist with both reducing the risk factors of damp and mould and helping customer who could be at risk of potential fuel poverty.
|2||Landlords should consider whether they require an overall framework, or policy, to address damp and mould which would cover each area where the landlord may be required to act. This would include any proactive interventions, its approach to diagnosis, actions it considers appropriate in different circumstances, effective communication and aftercare.||
Our Repairs policy and procedure covers our response to all repairs, including damp and mould issues. We recognise the benefit of an overall policy and procedure covering damp and mould specifically. Through 'Sanctuary Way', any colleague can escalate a case and damp and mould they suspect, whatever their role, to the appropriate senior manager.
The development of the overall policy is being led by the Group Head of Building Safety, supported by colleagues from across Sanctuary, and will be in place by summer 2023.
Update – July 2023
The damp and mould policy has been produced and is now ready for Executive approval.
|3||Landlords should review the accessibility and use of their systems for reporting repairs and making complaints to ‘find their silence’.||
Our repairs reporting and complaints systems are well embedded and 86 per cent of residents have said they know how to make a complaint.
In every case where we have not heard from a resident for two years or more, we arrange to visit them in their homes. Through this visit we can identify issues, including damp and mould, that maybe occurring and put appropriate resolutions in place.
For those residents we haven't heard from for a year, in addition to annual property visits, we’ll be introducing a new feedback survey for residents on the anniversary of their tenancy/lease which will provide an additional opportunity for them to tell us about any issues they are facing so we can address them faster.
|4||Landlords should identify opportunities for extending the scope of their diagnosis within buildings, for example by examining neighbouring properties, to ensure the response early on is as effective as possible.||
We currently capture information on possible or actual damp and mould across a number of data sources and systems. We know we have more to do to be able to spot patterns more quickly and take action more pro-actively. As part of this, we are identifying cases of damp and mould by property type.
With the improvements we are making to our systems as described in recommendation 1, this will enable us to be more pro-active in identifying potential patterns. We will introduce new reporting and analysis to support a monthly review of patterns damp and mould including historical cases, with associated risks for residents and homes, across our operations, starting April 2023.
Update – July 2023
We have developed a new dashboard for damp and mould, tracking trends in cases and the property and tenancy details related to individual cases. When this goes live in August, it will enable us to more easily identify patterns in an even more proactive manner. We have taken the decision that our master record when evaluating is repair and inspection data. Activity is captured in other systems and across other offline data sources is now be captured as an inspection where the case is being investigated, or as an order where works to remedy the issue have been commissioned. We have made amendments to the property repairs history report so that when reviewing repairs completed for individual properties any relating to damp and mould are flagged to that there is visibility of any ongoing or emerging issues.
We have interrogated data relating to properties that previously or currently have works relating to damp and mould to identify at a high level any particular drivers or underlying over representation relating to particular types of property or household
|5||Landlords should implement a data driven, risk-based approach with respect to damp and mould. This will reduce over reliance on residents to report issues, help landlords identify hidden issues and support landlords to anticipate and prioritise interventions before a complaint or disrepair claim is made.||
Where we have void properties, any damp and mould identified is dealt with before re-let. Using data from a wide range of systems to target the work of our Housing 360 team, we have produced analysis based upon a risk rating of the severity of damp and mould combined with vulnerability of residents to visit those properties proactively and identify necessary interventions. We will include a specific category of damp and mould on our void checklist to explicitly capture this and what action we take. We will also embed new analysis using our knowledge of existing cases of damp of mould and model this across similar property types in a locality. This modelling will enable us to plan resourcing more pro-actively.
Weekly and monthly reporting is provided to the Executive Committee and to every Group Board meeting.
|6||Where properties are identified for future disposal or are within an area marked for regeneration, landlords should proactively satisfy themselves that residents do not receive a poorer standard of service or lower living conditions, that steps are taken to avoid homes degrading to an unacceptable condition and that they regularly engage and communicate with these residents.||The explicit commitment is given to residents prior to any regeneration that required maintenance will continue to ensure homes meet the needs of residents (e.g., Page 4 of 'Talbot Gardens Barne Barton - Regeneration Proposals’). Our achievement of this commitment is managed through regular meetings between the Director - Regeneration and Operations Director - Property or appropriate senior staff both for current, and potential regeneration projects.|
|7||Landlords should avoid taking actions that solely place the onus on the resident. They should evaluate what mitigations they can put in place to support residents in cases where structural interventions are not appropriate and satisfy themselves, they are taking all reasonable steps.||Our approach is set out in response to rec 1.|
|8||Together with residents, landlords should review the information, materials and support provided to residents to ensure that these strike the right tone and are effective in helping residents to avoid damp and mould in their properties.||
We reviewed the information we provide in December 2022 making sure it is consistent with our Tone of Voice, being empathetic with residents. There's specific information included on our website, including a video: https://www.sanctuary.co.uk/information-residents/your-home/damp-mould-and-condensation.
Information included in the resident sign up pack has recently been refreshed. Website information is signposted in the current Customer Service Centre Interactive Voice Recording. Website information was signposted in our October 2022 national tenant e-newsletter.
In Spring 2023 we will work with our 'Community of Interest', of about 900 residents, to get their feedback on the clarity and tone of our information and change it, where necessary, based upon what they tell us.
Update – July 2023
We have reviewed the information with our resident community of interest who feedback the information was both clear and positive in tone.
|9||Landlords should be more transparent with residents involved in mutual exchanges and make the most of every opportunity to identify and address damp and mould, including visits and void periods.||
Before a mutual exchange takes place, we complete an inspection of the property with the outgoing resident to identify any repairs. When repairs are established as a resident's responsibility, we arrange a second inspection to check the repairs are completed. Any repairs not completed could result in the exchange not taking place.
For incoming residents, we provide written confirmation detailing the condition of the property. Any emergency repairs will be fixed and there is a plan for other repairs that are needed. We will include a specific category of damp and mould on our void checklist to explicitly capture this and what action we take.
Update – July 2023
We are significantly improving the coverage of property inspection (stock condition) data.
To ensure that we have visibility of works relating to damp and mould we have introduced reporting which analyses the free text descriptions captured against all works order in order to find every instance where key words like damp and mould are mentioned, at the point a repair is reported or subsequently when more detailed information about the works required is added to the order
|10||Landlords should ensure their strategy for delivering net zero carbon homes considers and plans for how they can identify and respond to potential unintended consequences around damp and mould.||
We ensure that our strategy to decarbonise homes plans for unintended consequences around damp and mould by requiring a ventilation assessment on every home during the scoping of energy efficiency works, with any ventilation works identified completed as part of the programme. Our Whole House Retrofit contractors (CCS) are PAS2035 compliant. This standard has the specific requirement for ventilation to prevent issues with damp and mould. Of the 934 properties improved on the Retrofit program this year approximately 95 per cent have had extra ventilation measures and 100 per cent of properties receiving fabric measures have had a technical survey and received extra ventilation and modern extractor fans where required.
We will continue with the commitments in our retrofit programme and on an ongoing basis make sure the necessary ventilation assessment takes place and the required works are completed.
|11||Landlords should review, alongside residents, their initial response to reports of damp and mould to ensure they avoid automatically apportioning blame or using language that leaves residents feeling blamed.||
As set out in our response recommendation 1 we have reviewed our scripts to ensure we aren’t apportioning blame. In Spring 2023 we will work with our communications 'Community of Interest', of about 900 residents, to get their feedback specifically on the scripts our contact centres use to make sure they resonate with how residents would expect us to deal with initial reports of damp and mould. We will change our scripts, where necessary, based upon what they tell us.
Update – July 2023
Our team managers at our Customer Service Centres have worked with our resident ‘community of interest’ of interest to review the guidance we provide to our call handlers when dealing with reports of damp and mould. We have heard positive feedback on how the empathy of call handling has improved more in recent months.
|12||Landlords should consider their current approach to record keeping and satisfy themselves it is sufficiently accurate and robust. We would encourage landlords to go further and consider whether their record keeping systems and processes support a risk-based approach to damp and mould.||
We capture instances of damp and mould across our systems, from initial report from residents to stock condition surveys. We use this data to prioritise cases based upon the severity of damp and mould and vulnerability of residents. We recognise we can improve our record keeping. We will do this by using consistent categorisation for damp and mould across our systems, focussing upon making sure our stock condition data is current and accurate.
Update – July 2023
See recommendation 9.
|13||Landlords should ensure that their responses to reports of damp and mould are timely and reflect the urgency of the issue.||This is based upon our zero-tolerance approach described in recommendation 1. We will continue to devote more resources and improve our systems to support enhanced diagnosis, triage and response to damp and mould cases, with our improved systems enabling us to more effectively track cases through to conclusion on a live basis.|
|14||Landlords should review the number of missed appointments in relation to damp and mould cases and, depending on the outcome of any review, consider what steps may be required to reduce them.||We review the reasons for any appointment being missed. Our focus is to make sure we are dealing with cases of damp and mould in a timely manner. We are currently specifically investigating any missed appointments related to cases of damp and mould, and the reasons for them being missed. These are reviewed on a continual basis and any necessary corrective action taken.|
|15||Landlords should ensure that their staff, whether in-house or contractors, have the ability to identify and report early signs of damp and mould.||
We have an internal Damp and Mould e-learning course detailing practical examples of different types of damp, how to report and what could be done to minimise the effects. This is mapped as mandatory for all frontline staff.
We have created a Housing health and safety rating system (HHSRS) course which explains what mould is, why it's important, what areas to look out for and how to report further action. We have also sourced an external accredited HHSRS inspections course which will provide theory and practical elements of completing a HHSRS correctly including recommended remedial actions. These have been mapped as mandatory for all relevant staff.
We have also sourced online learning about moisture meters, showing staff issued with the equipment the theory behind damp and mould, what piece of equipment to use for which scenario and step by step guides of operation. this is being mapped as mandatory for anyone who has been issued moisture meters. there will also be a QR code available for staff to access the videos when using the kit on the ground. This went live in February 2023.
As part of the Building Safety programme all surveyor roles within the organisation are having a skills audit against them showing which will show any gaps in competence based on new legislative requirements. A formal plan of learning to fill those gaps is being launched from May 2023.
When procuring external contractors, our contracts specify their staff are competent to carry out the necessary tasks, including the expectation to be trained to the required standards.
Update – July 2023
We have a formal learning plan in place, focussing on identifying and treating with cases of damp and mould.
|16||Landlords should take steps to identify and resolve any skills gaps they may have, ensuring their staff and contractors have appropriate expertise to properly diagnose and respond to reports of damp and mould.||
Our approach is set out in response to rec 15.
Update – July 2023
We have created the following courses for our staff which are noew being embedded:
We have identified a provider of accredited HHSRS Practitioners for all surveyors to attend starting August 23.
We have integrated damp and mould aspects within our Safeguarding workshops
Damp and Mould training is in place within the Customer Service Centres, facilitated by the Learning Academy
|17||Landlords should ensure that they clearly and regularly communicate with their residents regarding actions taken or otherwise to resolve reports of damp and mould. Landlords should review and update any associated processes and policies accordingly.||
Through our Local Offers, we are committed to keeping residents 'informed regularly on how we are dealing with their query and complaint, and the reason for any change.' We have this ethos with reports of damp and mould and other issues that are reported to us.
We know how important it is for our residents to be kept informed about what is happening. In 2023, we will be engaging residents in developing new service standards, which will ensure we have the right standard that reflects residents’ expectations.
|18||Landlords must ensure there is effective internal communication between their teams and departments, and ensure that one individual or team has overall responsibility for ensuring complaints or reports are resolved, including follow up or aftercare.||
We have a Group wide, cross functional team approach to dealing with complaints effectively and as quickly as possible, particularly focussing upon completing necessary repairs.
This approach ensures we have an identified lead for responding to each complaint and fosters increased joint working between operations and other teams involved in dealing with complaints which results in resolving complaints faster and more effectively.
|19||Landlords should ensure that their complaints policy is effective and in line with the Complaint Handling Code, with clear compensation and redress guidance. Remedies should be commensurate to the distress and inconvenience caused to the resident, whilst recognising that each case is individual and should be considered on its own merits.||
We carried out our assessment against the Complaint Handling Code in September 2022, working with residents in our complaints 'Community of Interest'. Evidencing that we comply with all aspects of the Code, and our self-assessment report is published at:
|20||Landlords need to ensure they can identify complex cases at an early stage, and have a strategy for keeping residents informed and effective resolution.||
Our process for diagnosing damp and mould at first contact identifies the complexity of the case, the vulnerabilities of any customer and the best approach for keeping our customers informed through to resolution. Through this we ensure we take the right action starting with appropriate cleaning and treatment if mould is diagnosed, through to more intensive resolution when more severe damp is identified.
Our processes have due regard in respect to communication to duties under the Equality Act, for example, residents who are visually impaired, mental health issues, and learning difficulties.
Update – July 2023
We are improving the quality and coverage of protected characteristics data we hold on our Customer Relationship Management system by December 2023.
We are improving the tone and clarity of our letters we use to arrange damp and mould repair appointments related to damp and mould.
|21||Landlords should identify where an independent, mutually agreed and suitably qualified surveyor should be used, share the outcomes of all surveys and inspections with residents to help them understand the findings and be clear on next steps. Landlords should then act on accepted survey recommendations in a timely manner.||Our complaints and disrepairs claims process sets out how we deliver against this recommendation specifically with regard to the use of appropriate surveyors, engaging with residents and taking timely action.|
|22||Where extensive works may be required, landlords should consider the individual circumstances of the household, including any vulnerabilities, and whether or not it is appropriate to move resident(s) out of their home at an early stage.||Our complaints and disrepairs claims process sets out how we deliver against this recommendation specifically with regard to the use of appropriate surveyors, engaging with residents and taking timely action.|
|23||Landlords should promote the benefits of their complaints process and the Ombudsman to their residents as an appropriate and effective route to resolving disputes.||
How to make a complaint is clearly identifiable on the website https://www.sanctuary.co.uk/contact-us/complaints for any resident wishing to contact us.
This information was changed in 2022 to be consistent with our tone of voice, being empathetic with residents. All of our correspondence is compliant with the Complaint Handling Code, and residents are advised of the role and opportunity to escalate complaints to the Housing Ombudsman Service throughout the complaint process.
|24||Landlords should continue to use the complaints procedure when the preaction protocol has commenced and until legal proceedings have been issued to maximise the opportunities to resolve disputes outside of court. Landlords should ensure their approach is consistent with our jurisdiction guidance and their legal and complaint teams work together effectively where an issue is being pursued through the complaints process and protocol.||
Our complaints procedure sets out that when a complaint has been made and the resident subsequently pursues a disrepair claim, we continue to deal with the complaint unless the resident withdraws it.
Our legal team always informs our complaints team of any claim, and they work together to ensure the matters are dealt with effectively.
|25||Landlords should consider how best to share learning from complaints and the positive impact of changes made as a result within the organisation and externally. Systems should allow the landlord to analyse their complaints data effectively and identify themes, trends and learning opportunities.||
Complaint trends, drivers and learning are shared with Executive Committee, Group Housing Committee and Group Board throughout the year. Learning outcomes on individual complaints where issues are highlighted are also discussed and raised with individual managers. Our National Resident Scrutiny Panel receive a complaints update at each formal meeting, with questions and scrutiny on this. We will involve our complaints 'community of interest' more in learning from complaints.
In 2023, we will provide the opportunity for this group to 'deep dive' into case studies to focus on learning outcomes from our residents' perspective.
|26||Landlords should ensure they treat residents reporting damp and mould with respect and empathy. The distress and inconvenience experienced by residents in this area is some of the most profound we have seen, and this needs to be reflected in the tone and approach of the complaint handling.||
We launched a new Tone of Voice (ToV) in 2022 and rolled out a series of communications and training, including an accompanying video. All colleagues in our complaints team have completed this training. We are continuing to embed the ToV with current work including a review by the Plain English Campaign and the creation of a memory aid for staff.
We have also refreshed our values and behaviours this year and will be rolling out further comms and materials to embed this within the organisation - our values support our ambition to treat residents with respect and empathy. We are reviewing its effectiveness so far and reporting back through our resident scrutiny in Spring 2023.