B3 Living Limited (202123802)

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REPORT

COMPLAINT 202123802

B3 Living Limited

28 January 2025

Our approach

The Housing Ombudsman’s approach to investigating and determining complaints is to decide what is fair in all the circumstances of the case. This is set out in the Housing Act 1996 and the Housing Ombudsman Scheme (the Scheme). The Ombudsman considers the evidence and looks to see if there has been any ‘maladministration,’ for example whether the landlord has failed to keep to the law, followed proper procedure, followed good practice, or behaved in a reasonable and competent manner.

Both the resident and the landlord have submitted information to the Ombudsman, and this has been carefully considered. Their accounts of what has happened are summarised below. This report is not an exhaustive description of all the events that have occurred in relation to this case, but an outline of the key issues as a background to the investigation’s findings.

The complaint

The resident has complained about the landlord’s:
1. response to outstanding repairs at the property.
2. handling of antisocial behaviour (‘ASB’) reports made against her.
3. response to her request to move to an alternative property.
4. complaint handling.

Background

The resident has an assured tenancy that began on 8 July 2019. The property is a one-bedroom ground floor flat with ramp access. The resident explained to the landlord during the complaints process that she has fibromyalgia, anxiety, and depression. The landlord said its systems recorded the resident had a “physical vulnerability.”
The resident explained to the Ombudsman that during 2020 and 2021, her neighbours made a series of complaints about her. This included reports of noise nuisance and the use of illegal substances The resident felt this was harassment and a series of false reports. The landlord opened several ASB cases, issued the resident warning letters about breaching her tenancy, and liaised with the police. All ASB cases were closed in January 2023 with the consent of all parties involved.
During January 2021, the resident expressed that she wanted to move to an alternative property. She said this was because her anxiety about the ASB reports had made her mental and physical health worse. The landlord liaised with the local council about the resident’s housing options and supported the resident in making a homelessness application. The landlord said it later supported her appeal of the local council’s decision that she was adequately housed. The landlord also directed the resident to Citizens Advice.
The Ombudsman raised a complaint on 31 July 2023 on behalf of the resident. This said:
1. she was unhappy with the landlord’s handling of the ASB reports made against her and its communications about this.
2. she was unhappy with the advice of her landlord regarding her request to move.
The landlord issued its stage 1 response on 15 August 2023 and partially upheld the resident’s complaint. It said:
1. it was “not very good” at communicating with the resident about her housing options. Also, it did not communicate how the resident’s fixed-term tenancy status had restricted her moving options.
2. it recognised that it had since adhered to the resident’s communication preferences. These were to let the resident know before calling or conducting visits to the property.
3. the resident had applied to the local council’s housing waiting list. As a result, the resident, landlord, and the local council had agreed that having homeless points,rather than transfer points, would be of more benefit to her.
4. it recognised the resident was making a further application for reasonable preference on the local council’s housing waiting list. This was because of her medical conditions. It offered further help with the resident’s housing application if she needed it.
5. there were no current ASB concerns from either the resident or her neighbours.
6. between January 2020 and August 2023, it raised 6 ASB cases in response to reports of the resident causing a nuisance to her neighbours. As part of this it sent 6 warning letters to her.
7. it was unable to comment on anything the police had said.
8. it responded to the resident’s complaint in July 2022 and an MP enquiry in October 2022 within the prescribed timescale.
On 23 August 2023 the resident expressed dissatisfaction with the landlord’s investigation into her complaint. She said:
1. the landlord oversimplified the issues, and she was unhappy with the outcome of the investigation.
2. the landlord had a duty of care and had been negligent in her case. This was because it allowed her neighbours to harass her. She also said it had discriminated against her because she had been under investigation by the landlord for 4 years and received unannounced visits.
3. she did not feel an apology and house move was enough to put things right. This was because her life had been “completely destroyed” and her “health deteriorated rapidly” because of how her housing problems had affected her.
4. her complaint had taken an unacceptable length of time to be acknowledged and responded to.
The landlord issued its stage 2 response on 8 November 2023 and partially upheld the resident’s complaint. It said:
1. it apologised that the service the resident had received concerning the complaint had not met its standard. Also, because the resident felt frustrated and distressed.
2. it had raised several repairs following a face-to-face meeting on behalf of the resident that was separate to the complaints process.
3. it had already responded about the level of its communications at stage 1 which it had upheld. It listened to the resident’s concerns and changed the way it communicated with her, and this was working.
4. it had converted the resident’s tenancy from an assured shorthold tenancy to an assured tenancy and confirmed this in writing.
5. it had referred the resident for additional support at her request.
6. it could not uphold the resident’s complaint about the “housing transfer” as it did not maintain the housing list for the local council. However, it would support the resident with her housing application if required.
The resident referred her complaint to the Ombudsman on 26 February 2024 because:
1. she felt the landlord had not followed its allocation policy. This was because it had not considered her for a management transfer. She said she was unhappy that she had been told her only option was to make a homeless application to the local council.
2. the repairs she reported remained incomplete.
3. she felt the landlord needed to retrain staff about how to deal with complaints from vulnerable people.
4. she wanted the landlord to apologise, acknowledge, and compensate her for its failure to treat her fairly against the ASB reports made by her neighbours. Also, how it handled her request to move to an alternative property.

Jurisdiction

When a complaint is brought to the Ombudsman, we must consider all the circumstances of the case as there are sometimes reasons why a complaint will not be investigated. After carefully considering all the evidence we have determined that resident’s complaint about repairs at the property is not within the Ombudsman’s jurisdiction.
The resident made a service request to the landlord during the complaint procedure regarding several outstanding repairs at her property. The landlord raised these repairs, but the resident explained that they remain unresolved at the time of this report.
Paragraph 42.a. of the Scheme states:“42. The Ombudsman may not consider complaints which, in the Ombudsman’s opinion: a. are made prior to having exhausted a member’s complaints procedure, unless there is evidence of a complaint-handling failure, and the Ombudsman is satisfied that the member has not taken action within a reasonable timescale.”
While the repairs were discussed during the course of the complaint procedure, it was appropriate for the landlord to treat the reports as service requests. If the resident is unhappy with the landlord’s handling of the repairs or considers them to be incomplete, she should raise this with the landlord now so that it can investigate her concerns accordingly. Should the resident remain unhappy after exhausting the landlord’s complaints procedure, she may refer the matter back to us as a new complaint.

Assessment and findings

Scope of the investigation

The resident explained that she felt the landlord had discriminated against her when handling the reports of ASB against her.
While the serious nature of the resident’s concerns is noted, the Ombudsman cannot determine whether an individual has been discriminated against. This is a matter that is best decided by a court. The Ombudsman can, however, consider how the landlord responded to the resident’s concerns, and if it treated the resident in a manner that was fair and reasonable overall.
The resident has made a housing application to the local council’s waiting list to be rehoused. The evidence indicated that the resident had to appeal a decision made by the local council relating to this. It is important to note the Ombudsman is unable to investigate how the local council handled the resident’s housing application because this is not within the remit of the Housing Ombudsman. The Local Government and Social Care Ombudsman (LGSCO) may investigate this type of complaint. The resident can refer any complaint made to the local council to the LGSCO if she is unhappy with the outcome. As part of our investigation, we have considered how the landlord handled the resident’s request to be rehoused and if it acted reasonably in the circumstances.

The landlord’s handling of ASB reports made against the resident

It is not the Ombudsman’s role to determine whether ASB occurred or, if it did, who was responsible. What the Ombudsman can assess is how a landlord has dealt with the reports it has received and whether it followed good practice and its legal and policy obligations, taking account of the circumstances of the case.
In line with its policy, the landlord must investigate reports of ASB and respond appropriately. The landlord’s ASB policy states it will:
1. adopt a risk-based approach to cases by taking reports seriously.
2. identify vulnerabilities of all parties.
3. act against perpetrators depending on the merits of the case. This will range from written warnings to more serious consequences such as acceptable behaviour agreements, injunctions, or repossession of the property.
Over the course of 2020 and 2021 the landlord opened 7 ASB cases on its system relating to reports against the resident. The reports concerned the use of illegal substances and loud noises coming from the property. During this time there is evidence that the landlord:
1. regularly reviewed reports made against the resident across the 7 ASB cases it opened.
2. liaised with the police in February 2021 and July 2021 regarding domestic noise incidents and concerns over the use of illegal substances. The police issued a warning letter to the resident about the use of illegal substances in March 2021.
3. regularly contacted the resident to discuss the reports made against her through email, telephone, and face to face visits.
4. liaised with relevant staff members who came into contact with the block of flats as part of their daily duties.
5. conducted announced and unannounced property inspections to assess the reports made against the resident. It noted there was the smell of cannabis at the property at some of its visits.
6. issued 6 warning letters to the resident regarding the reports made against her and explaining her tenancy obligations around noise nuisance and illegal substances.
7. signposted the resident to adult social services through their safeguarding team, a multi-agency risk assessment conference, a coaching service, and her GP.
The Ombudsman acknowledges that during 2020 and 2021 the resident was experiencing difficulties with the reports made to the landlord about her. We also acknowledge that the resident told the landlord this negatively impacted her mental health. The evidence shows that the landlord appropriately responded to this concern by identifying the resident’s mental health vulnerabilities. It then proactively tried to work with her to ensure she was signposted to relevant support agencies such as her GP and local coaching services.
The evidence shows the landlord appropriately conducted an ongoing investigation and regularly reviewed the ASB cases. It then discussed the reports with the resident. This shows it considered matters as a whole before deciding what action would be proportionate to take. It then made reasoned conclusions based on the evidence it had gathered at the time to issue the breach of tenancy letters to the resident. This was a reasonable action based on the evidence gathered at the time from officers and external agencies. Therefore, the landlord’s approach was in line with its ASB policy.
The landlord continued to monitor the open ASB cases through 2021, 2022 and 2023. The evidence shows this was a proportionate action given the reports made against the resident were ongoing. The landlord later closed the remaining ASB cases (in January 2023) due to a lack of further reporting and evidence to progress them. The evidence also shows all parties agreed to the closure of the cases. This was reasonable in the circumstances because the decision based on the evolving position of the parties and the merits of the case.
Given the circumstances of the case, the Ombudsman finds there was no maladministration in the landlord’s handling of this element of the case.

The resident’s request to move to an alternative property

During January 2021 the resident expressed that she wanted to move property. She explained that the reports made by her neighbours were causing her anxiety and this was triggering her fibromyalgia to flare up.
Between January 2021 and August 2023 there is evidence the landlord did the following:
1. appropriately responded to the resident’s initial request to discuss her housing situation in January 2021. However, the landlord was unable to reach the resident.
2. liaised with the local council in May 2021 regarding the status of the resident’s housing application. This was a delay of 4 months from the resident’s initial request for support. There is no evidence the landlord updated the resident during this period. That it did not was a failure to update the resident.
3. contacted the local council on the resident’s behalf in June 2021. It explained the resident appeared confused about her rehousing options and confirmed that her rent account was up to date. This was with the intention to support the resident to be placed on the “transfer” list.
4. liaised with the local council further to discuss the impact of the resident’s fixed term tenancy on the priority she could have on the waiting list. The local council advised that the best option for the resident would be to make a homeless approach based on medical needs. The landlord appropriately provided this advice to the resident by email.
5. responded to the resident’s request for support to fill in her housing application in September 2021. The landlord arranged for the resident to attend its offices in October 2021 to discuss further support it could provide. After the meeting, the landlord referred the resident to a customer coach to help the resident fill in the forms for her housing application. This was positive action.
6. liaised with the resident after the local council decided the resident was “suitably housed”. It explained the resident could look to mutually exchange but to do this she needed to clear the rent arrears she had accrued. This was appropriate advice in the circumstances. It was reasonable for the landlord to highlight the possibility of moving via mutual exchange but important that it managed the resident’s expectations in relation to the status of rent account.
7. in March 2022 the resident said living at the property was impacting her mental and physical health. This was linked to the ongoing ASB being reported about her at the time. The landlord re-iterated its advice about clearing the rent arrears to mutually exchange or to approach the local council to make a homeless application based on medical needs.
8. in April 2022 the landlord arranged for the customer coach to meet with the resident to discuss supporting the resident with moving and her finances. It is unclear what was discussed at this meeting. This should reasonably have been recorded. That it was not, was evidence of poor record keeping and a failure.
9. in August 2022 the landlord agreed to meet with the resident to discuss a rehousing plan and to complete the necessary paperwork to help the resident move. It is unclear if the meeting took place based on the evidence provided by the landlord. This was evidence of poor record keeping as it would have been reasonable for the landlord to have ensured the action it took was documented.
10. the landlord offered to help the resident in completing a homeless application in December 2022. The resident explained to the landlord that she was concerned that she had asked for a management transfer but was being put forward for a homeless application. She said this was an action “[that failed to] secure [her] rights as a tenant”. There is no evidence the landlord responded to the resident’s concerns or that it re-explained how the tenure aspect of the resident’s case impacted her housing options. This was a failing and a missed opportunity to address some of the resident’s concerns.
11. the resident confirmed in February 2023 that she wanted the landlord to look at the “relevant documentation” to help her move but did not require a home visit. The records are unclear about whether the landlord had contacted the resident to try and assist her further. The landlord’s records ought to have recorded the action it took. That it did not was evidence of poor record keeping.
12. in April 2023 the landlord’s notes indicated that the resident was “difficult to engage with”. There was no evidence to indicate the resident was not engaging with the landlord during this time or that the landlord was taking steps to engage with the resident about her application. The basis for the landlord’s comments is therefore unclear. The notes said, “continue to monitor” and “wait for housing application to be completed and processed”. This was not proportionate given the resident was seeking support with her housing application.
13. the landlord contacted the local council in May 2023 to ask for an update on the resident’s housing application. It found the resident had not made a housing application. It arranged for the customer coach to work with the resident to make a homeless application to the local council. There is no evidence about the discussions that took place during this meeting or the agreed actions either party intended to take. This was poor record keeping.
14. in June 2023, the landlord’s records indicated the resident had not completed a housing application because she wanted a management move. The landlord sent an email to the resident in July 2023 summarising the actions it had already taken. It also said there had been a miscommunication because of some of the terminology used when talking about housing options. It reiterated that the resident needed to complete a housing application to be able to move. It offered further support for her to do this. This was reasonable in the circumstances because it was clear about the action it had taken and what it could do to support the resident further.
15. in August 2023 it responded to the resident’s request to consider a management transfer by advising her to complete a housing application. However, it did not respond to the resident’s request to consider adapting a property for her. This was a failure to address all the issues the resident raised.
16. in September 2023 the landlord tried to call the resident to discuss her housing options. It then tried to arrange a meeting in September 2023, but the landlord’s records are unclear about whether this took place. Shortly after the landlord issued its stage 1 response which said that the homeless points would be “more valuable” than the transfer points to progress a move. The landlord’s advice was consistent with the advice it had previously given.
The evidence also shows the resident told the landlord that she was unhappy with the level of service she received from one of the coaches who was supporting her. She said she was “advised to lie” on her housing application. There is no evidence that the landlord considered the resident’s comments further. This was a missed opportunity to investigate the resident’s concerns.
During the complaint the landlord told the resident that it had “gone over and above” to obtain agreement from the local council to move the resident. At the time it offered to meet the resident to agree on a plan but it “did not want to spend the meeting talking about the past”. The landlord’s language was unsympathetic to the resident. Given the landlord had agreed to help the resident with her housing application to the local council, it was unfair to state that its actions were “over and above” what it had agreed to do.
The resident explained to the Ombudsman she was particularly dissatisfied that the landlord had not considered her for a managed move. The evidence shows the resident communicated this to the landlord from November 2021 onwards.
The Ombudsman considers the landlord has discretion under the local council’s allocations policy to consider referring a resident for a management transfer in certain circumstances. However, the evidence shows the landlord chose not to do this because it had relied on advice from the local council, which said that transfer points were less valuable than homelessness points. It was reasonable for the landlord to rely on the advice of the local council. However, there is no evidence the landlord explicitly communicated this to the resident, and this was a failure.
While the landlord’s decision was not inherently wrong it ought to have communicated its position on a management move. The resident was particularly concerned that a homeless application would affect the security of her tenure. If the landlord had explained its decision this could have managed the resident’s expectations and addressed the resident’s concerns about her tenure. This could have helped her make an informed decision about how she wanted to progress her application.
The Ombudsman considers the landlord identified the resident was confused with her housing options and the relevant processes in June 2023. The landlord’s response was clear about the process concerning how the resident could move and what support it could offer her to do this. It also issued this in writing which acted as a record for both parties to refer to. This shows in the latter half of the complaint the landlord took reasonable steps to consider the resident’s vulnerabilities when giving complex advice.
However, it is unclear why the landlord did not relay this advice to the resident at an earlier opportunity. Given the content of the resident’s previous communications with the landlord, it was evident the resident was confused about her options to move, concerned about the security of her tenure, and the process to be rehoused. If this advice had been provided at an earlier stage in a way the resident preferred to receive communications, it could have addressed her distress and uncertainty at an earlier opportunity. It would have also saved the resident time and trouble contacting the landlord to understand the options available to her.
The landlord acknowledged in its stage 1 response that when it tried to explain the housing options available to the resident it did not communicate the complexity of the information very well. However, the landlord did not explain how it would prevent this from occurring again. Overall, there was a theme of the resident approaching the landlord on various occasions confused about her housing options. Given the resident’s vulnerabilities, the landlord could have considered how it could have provided the information in a way that was clearer to the resident.
This failure was linked to the landlord’s understanding of the resident’s vulnerabilities. It is important to note that the landlord’s systems did not record any vulnerabilities for the resident other than a “physical vulnerability”. However, the Ombudsman has seen evidence that the landlord recognised in its communications that the resident had physical and mental health conditions as early as April 2021. There are consistent reports made by the resident throughout her complaint that her health was deteriorating. This meant the landlord missed an opportunity to take steps to understand the resident’s vulnerabilities to a greater degree and assess how it could adjust its communications. This was a failing.

Conclusion

The points awarded on either a transfer or a homelessness basis had to be agreed upon by the local council. As such, there is no evidence that the resident’s position would have been different had the landlord communicated more effectively. This is because the resident still needed to make a housing application for the local council to decide which points to award her based on her situation. The evidence shows the landlord tried to support the resident in completing a housing application on numerous occasions.
Further, it would be unfair to hold the landlord solely responsible for explaining the options available to the resident under the local council’s allocation policy and homelessness duties. The responsibility of the landlord was to support the resident in making an application to the local council for housing support. The evidence shows the landlord made efforts to do this.
The resident’s current position is that she has an active housing register application and is waiting to be allocated a property. She has been advised that due to a short supply of housing, this may take some time. It is unclear whether the resident’s housing application resulted from the landlord’s support and intervention or on what basis the application was banded.
The Ombudsman acknowledges the resident’s frustration at the supply of housing. We recognise that many residents face an extended waiting time to be rehoused through social housing waiting lists. However, the landlord is not responsible for the length of time the local council may take to allocate housing to her through the housing waiting list.
Overall, the Ombudsman considers that this investigation has highlighted a culmination of failures by the landlord which amount to maladministration. This was because:
1. the landlord missed opportunities to identify and address the resident’s confusion about her housing options. This caused time and trouble in contacting the landlord to try to understand her options and the associated processes.
2. there is no evidence that the landlord explicitly communicated its decision not to use its discretion to put the resident forward for a managed move or manage the resident’s expectations around this.
3. the landlord’s language at times was unsympathetic and heavy-handed towards the resident.
4. the landlord missed an opportunity to investigate the resident’s concerns about the coaching service and to ensure the resident was receiving suitable support.
5. the landlord’s overall record keeping was poor at consistent points highlighted in the report.
The landlord recognised during the complaints process that its communication had been poor regarding the resident’s rehousing options. While this was a fair conclusion to draw, the landlord’s response was not proportionate because it failed to recognise or address how its failures contributed to the distress, uncertainty, time, and trouble to the resident.
It was positive to note that the landlord wrote to the Ombudsman to explain it has implemented training programmes. The landlord said this was to focus on enhancing communication skills and ensuring clarity in customer relations. It said it has also commenced a customer experience group to review best practices to implement better ways of working. The landlord said it was drafting a vulnerable customer policy to strengthen its approach to working with a variety of customers with differing needs.
Having considered this, the Ombudsman has reviewed this Service’s ‘Remedies Guidance’ and considers it appropriate for the landlord to pay the resident £400 compensation. This is to address the distress and inconvenience to the resident caused by the failures in its handling of this complaint element.
The Ombudsman’s Spotlight Report on ‘Knowledge and Information Management’ (‘KIM’) reflects on vulnerabilities and the importance of capturing data to ensure information is managed well to benefit both parties. Recording key information ensures that landlords have the opportunity to account for important details about vulnerabilities and when reasonable adjustments are made and to ensure relevant staff members are aware. This is so that they can coordinate their approaches accordingly. Given the frequency of poor record keeping findings in this report, the Ombudsman orders the landlord to review its record keeping practices. The landlord should consider the recommendations set out in the KIM report to align its working practices with best practices.

Complaint handling

The Complaint Handling Code (‘the Code’) states landlords must respond to complaints at stage 1 within 10 working days of the date of acknowledging and logging the complaint. Landlords must also respond to escalation requests at stage 2 within 20 working days. The landlord’s complaint policy aligns with the timeframes in the Code.
The Code also states:
1. landlords must confirm the following in writing to the resident at the completion of stage 1 in clear, plain language:
  1. the reasons for any decisions made.
  2. the details of any remedy offered to put things right.
  3. details of any outstanding actions.
2. if all or part of the complaint is not resolved to the resident’s satisfaction at stage 1, it must be progressed to stage 2 of the landlord’s procedure. Stage 2 is the landlord’s final response.
3. 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.
The resident raised a complaint on 31 July 2023. The landlord provided its stage 1 response on 15 August 2023, this was 12 working days later. The landlord’s response time was not in line with the Code because it did not respond within 10 working days. However, there is no evidence to suggest that the resident was caused distress or inconvenience as a result of the delay.
The evidence shows the resident expressed dissatisfaction with the handling of her complaint on 23 August 2023. The resident continued to communicate further dissatisfaction with the outcome of the stage 1 response through to October 2023. The landlord’s records stated the resident escalated her complaint on 31 October 2023. However, given the resident had expressed dissatisfaction with the landlord’s stage 1 response before October 2023, it is unclear why the landlord did not progress the resident’s escalation request in August 2023.
This was a failure because the landlord did not identify the resident’s escalation request in August 2023. This meant there was an avoidable 2-month delay in progressing the complaint. This also delayed the resident’s ability to seek recourse from this Service. The resident said this caused her distress because she felt that the landlord was not listening to her.
The landlord provided its stage 2 response on 8 December 2023. This was 77 working days later. The evidence shows that the landlord requested an extension on 6 December 2023 explaining that it required more time to respond.
The landlord’s request for an extension was in line with the expectations of the Code where there is an expected delay. However, even based on the landlord’s timeframes, the stage 2 response was due on 29 November 2023 (20 working days after 31 October 2023). Therefore, the landlord failed to notify the resident of its delay until after the timeframe had passed for it to issue the response. This was inappropriate because it failed to keep the resident informed about the progress of her complaint in a timely manner.
The Ombudsman notes the landlord’s template for its complaint responses was positive because the formatting made the information easy to read and accessible. However, the landlord said “there were things we did not get right” but it did not explain what these were. This meant the landlord was not transparent about its failings and this confused the resident. The Code obligates landlords to explain the reasons for any decisions made and the details of any remedy to put things right. Therefore, the landlord did not act in line with the principles of the Code.
Given we have identified several independent service failures, the Ombudsman considers there was maladministration in the landlord’s complaint handling.
The Ombudsman has considered this Service’s ‘Remedies Guidance’ and considers it appropriate for the landlord to pay the resident £100. This is to address the detriment to the resident for the impact of the landlord’s failures. The landlord must also address the failures relating to its working practices against its obligations under the Code. Therefore, the landlord must arrange for complaint handling training for relevant colleagues.

Determination

In accordance with paragraph 42.a. of the Scheme the complaint about the landlord’s response to reports of outstanding repairs at the resident’s property is outside of the jurisdiction of the Ombudsman to investigate.
In accordance with paragraph 52 of the Scheme, there was no maladministration in the landlord’s handling of the ASB reports made against the resident.
In accordance with paragraph 52 of the Scheme, there was maladministration in the landlord’s handling of the resident’s request to move to an alternative property.
In accordance with paragraph 52 of the Scheme, there was maladministration in the landlord’s handling of the resident’s complaint.

Orders and recommendations

Orders

Within 28 days of the date of this determination, the landlord must:
1. write to the resident to apologise for the failures found in this report.
2. pay the resident compensation of £500 comprising of:
  1. £400 to recognise the distress and inconvenience caused to the resident as a result of the landlord’s handling of her request to move.
  2. £100 to recognise the distress and inconvenience caused to the resident as a result of the complaint handling failures that have been identified.
3. arrange for complaint handling refresher training for relevant colleagues to address and learn from the failings set out above.
4. provide evidence of compliance with the above orders.
Within 56 days of the date of this determination, the landlord must review its record keeping practices, focussing on the failures identified by this investigation. The outcome of the review should be shared with the Ombudsman.