Glasgow and West of Scotland Forum of Housing Associations 21 st June 2012

1. Glasgow and West of Scotland Forum of Housing Associations 21st June 2012 Implementing the RSL Model CHP • Paul McFadden • Complaints Standards Authority (CSA)

2. Problems across public services Inconsistent Poor complaints handling Complex and confusing Focused on organisational need not on customer Value for money Benefits Cheaper and quicker Customer good will Fewer repeat complaints Less stressful for staff Greater customer satisfaction Improving services Why changing complaints?

3. 2010-11 SPSO ‘Premature’ rates

4. A standardised, simplified Model Complaints Handling Procedure for each sector Make complaining easier, simpler and more consistent for all customers Consistent process and timescales across whole public sector Complaints Standards Authority centre of best practice Working with each sector to develop and share best practice in complaints handling Complaints Standards Authority Public Services Reform (Scotland) Act (2010)

5. Model Complaints Handling Procedures (CHP) NDPBs & Agencies • Model CHP– adapt and adopt • Customer facing information • Employee guide LAs RSLs FE HE SG Prisons

6. What is / is not a complaint 2 stages, set timescales Standards for recording, reporting, learning and publicising Dealing with unacceptable actions Clear roles and responsibilities Empowering frontline staff to resolve complaints Share outcomes and lessons learnt throughout organisation tenants Share outcomes and action taken with tenants Requirements of RSL Model CHP

7. The major changes – streamlining • Quick response from service staff – at point of service delivery • Resolve or remedy - within 5 working days • Where issues identified apology/explanation and/or redress • Complaint details recorded Informal local resolution Frontline • Full investigation by designated complaints handler • Sign-off by senior manager • Written response within 20 working days Investigation Review by SPSO

8. Roles and Responsibilities • Empowering frontline staff • Senior management ownership • Monitoring • Reviewing cases / learning • Signing off investigations – the final decision • Leading culture change

9. Defining the Management Committee role in Complaints SHR Regulatory Framework - Governance and Financial Management • 5.6 and Regulatory Standard 1 highlight the importance of the Committee concentrating on the strategy and leadership of the RSL rather than getting involved (as a Committee) in operational matters Section 5.6: “When we refer to governance we mean the arrangements for the leadership, strategic direction and control of an RSL.” • Standard 1.1 “The governing body sets the RSL’s strategic direction. It agrees and oversees the organisation’s strategic and financial plans …..” • Standard 1.5 “The governing body provides the necessary challenge and holds the senior officer to account or his/her performance.”

10. Defining the Management Committee role in Complaints • No ‘appeal’ to management committees • Strategic not operational role • However, some scope for individual tenant committee members being involved in Stage 2 – flexibility of approach on individual decisions • Monitoring and review information from complaints • Monitor and review complaints handling performance • Address service improvement issues

11. Recording, reporting and publicising Recording: • Recording of all complaints • Specifies minimum data requirements Reporting: • Quarterly reporting to senior management / executive team • What information do Management Committee want/need? Publicising: • Quarterly – Publicly reporting to tenants on complaints outcomes, trends and actions taken • Show the impact not just stats – stories (you said we did).

12. Complaints being used to improve services Recording, reporting, learning and publicising • Systems in place to record, analyse and report on the learning from all complaints - subject, outcome and action taken. ‘You can’t manage what you don’t measure’ • Service improvements identified through complaints analysis - changes made to services, guidance or policy to prevent the problem recurring • Senior managers receive and act on regular reports - service improvements are agreed, actioned and reviewedquarterly • Processes in place to identify and respond immediately to critical or systemic service failures • Informing complainants about the lessons learnt • Publicly reporting on the number of complaints received and the outcome • Evidence of sector wide sharing of learning

13. Challenges in implementing Culture Change Value Complaints – not all about reducing numbers Empower and support frontline staff – mindset of quick resolution Admit failings - apology Normalise complaints, engrain them throughout your organisation Training and staff awareness Recording systems Definition of complaint / service request Processes in place to analyse, report and learn from all complaints

14. How will compliance with the CHP be monitored? Social landlords manage their businesses so that: • tenants and other customers find it easy to communicate with their landlord and get the information they need about their landlord, how and why it makes decisions and the services that the landlord provides. This outcome covers all aspects of landlords‘ communication with tenants and other customers. It is not just about how clearly and effectively a landlord gives information to those who want it. It also covers making it easy for tenants and other customers to make complaints and provide feedback on services, using that information to improve services and performance, and letting people know what they have done in response to complaints and feedback. It does not require landlords to provide legally protected, personal or commercial information.’ (Emphasis added by SPSO)

15. SSHC / SHR Year 1: 2012/13 Pro-forma to SPSO by October If not fully compliant, provide plans for implementation APSR in early 2013 Year 2: 2013/14 Annual Return on Charter (ARC) includes performance information Performance report to tenants Self-assessment Year 3: 2014/15 (and ongoing) SHR - possible thematic report ARC and self-assessment How will compliance with the CHPs be monitored?

16. 2013/14 - Performance • 2013/14 High-level performance indicators consistent between sectors • Through ARC and self-assessment indicators include: • number and percentage of complaints received and closed at each stage • number of complaints upheld / not upheld at each stage as a % of all complaints closed • the average time in working days to resolve complaints at each stage • measure on customer satisfaction with service (as opposed to outcome). • measures around: Publicising, Reporting, Learning • Benchmarking against peers (e.g. SHBVN, Housemark, CIH etc) • Monitor changes over time (eg % Stage 1, % Uphelds) • However, further discussion and consultation is required

17. Significant Performance Failure Now remit for the Scottish Housing Regulator A significant performance failure is something that your landlord does or fails to do that puts the interests of its tenants at risk, and your landlord has not resolved the failure. This is something that is a systemic problem that does, or could, affect all of your landlord’s tenants.

18. SHR - Significant Performance Failure A significant performance failure happens when: • your landlord is not delivering the outcomes and standards in the Scottish Social Housing Charter over a period of time; or • your landlord is not achieving the regulatory standards on governance or financial management. • A complaint between an individual tenant and a landlord is not a significant performance failure. Significant performance failures are not, therefore, dealt with through the complaints handling procedure.

19. CSA support moving forward Training • E-learning modules Module 1: Understanding the Model Complaints Procedure Module 2: What Is A Complaint? Module 3: What Customers Want When They Complain Module 4: Getting It Right From the Start Module 5: Active Listening Module 6: Finding the Right Solution Module 7: Learning From Complaints Module 8: Managing Difficult Behaviour • Investigation and Frontline classroom-based courses Valuing complaints websitewww.valuingcomplaints.org.uk • Complaints handling developments and good practice resources • Ask each other – cross-sector discussion forum / community • Ask CSA – implementation guidance Networks of complaints handlers • Sharing best practice • Developing standardised categories • Benchmarking performance

20. Discussion What is the biggest challenge you will face? How prepared are you and your staff? What training or awareness programme do you need? Do you record, analyse and report on all complaints? If not how could this be achieved? What might be challenges / barriers to achieving this? Do you regularly review the lessons learned to identify patterns in service failures? How could you improve this? Do you publish information on complaints - volumes / types of complaints/performance? Do your senior management receive and act on regular reports? Do you have processes in place to allow quick response to critical or systemic service failures? What information do Management Committee want/need? How role does your management committee play in complaints? Howe might this be affected by CHP?

21. Any Questions ?

22. Contact Details www.valuingcomplaints.org.uk • Paul McFadden • Head of Complaints Standards • 0131 240 2964 • CSA@spso.org.uk Francesca Richards Complaints Standards Authority Officer 0131 240 8857 CSA@spso.org.uk