Sanctuary Housing Association (202439524)

Background

1. The property is a 2-bedroom top-floor flat that the resident has occupied since 2002. The resident has medical needs making it difficult for her to manage the external steps and access the bathing facilities in the property. At the time of our investigation, this issue remained unresolved.

What the complaint is about

2. The complaint is about the landlord’s handling of the resident’s:
   1. Request for adaptations at the property and associated rehousing request.
   2. Associated complaint.

Our decision (determination)

3. We found that:
   1. There was severe maladministration in the landlord’s handling of the resident’s request for adaptations at the property and associated rehousing request.
   2. There was reasonable redress in the landlord’s handling of the resident’s complaint.

We have made orders for the landlord to put things right.

Summary of reasons

Request for adaptations at the property

4. The landlord failed to manage the resident’s aids and adaptations request effectively, causing prolonged delays, poor communication, and unnecessary stress. Furthermore, the delays and burden on the resident continued after the complaint process ended in March 2025.

Complaint handling

5. The resident’s escalation request was acknowledged 5 months after her request and only after intervention from us. The landlord offered £175 compensation as reasonable redress.

Putting things right

Where we find service failure, maladministration or severe maladministration we can make orders for the landlord to put things right. We have the discretion to make recommendations in all other cases within our jurisdiction.

Orders

Landlords must comply with our orders in the manner and timescales we specify. The landlord must provide documentary evidence of compliance with our orders by the due date set.

Recommendations

Our recommendations are not binding, and a landlord may decide not to follow them.

Our investigation

The complaint procedure

What we found and why

The circumstances of this complaint are well known by the parties involved, so it is not necessary to detail everything that’s happened or comment on all the information we’ve reviewed. We’ve only included the key information that forms the basis of our decision of whether the landlord is responsible for maladministration.

6. The landlord’s aids and adaptation policy says that it aims to support residents with disabilities or infirmities to live independently and maintain a good quality of life. It may seek advice from an independent occupational therapist to determine necessary adaptations. If major adaptations are impractical or not in a resident’s best interest, the landlord will assist them in finding more suitable accommodation.
7. The policy goes on to say that major adaptations include stair lifts, level access showers, and external ramps. The landlord aims to complete approved major adaptations within 26 weeks of receiving the OT referral, though this may be delayed by factors such as planning permission, building regulations, tendering, or budget agreement. The landlord will also consider whether alternative accommodation with greater support would be more appropriate, and will discuss this with the resident.
8. It is not disputed that the resident made significant efforts between June 2023 and August 2024 to obtain the landlord’s assistance following the OT report and its recommendations. In its stage 1 response, the landlord acknowledged that the resident had repeatedly provided documentation to support her aids and adaptations request. To recognise its lack of communication and the distress and inconvenience caused, it offered £100 and confirmed it would escalate her concerns to the aids and adaptations team. This represented a positive step towards resolving the matter and demonstrated the landlord’s intention to address the issues raised. However, the amount offered did not sufficiently reflect the level of distress and inconvenience the resident experienced over an extended period – over one year.
9. Internal communication dated 11 September 2024 stated that the landlord did not have an active case regarding the resident’s aids and adaptations request and advised that she should submit a referral to its email address which was provided. This approach was unreasonable, as the resident had already supplied the required information multiple times, and the landlord had stated in its stage 1 response that it would escalate the matter with the relevant team as part of resolving her complaint. The landlord could have taken a more proactive approach to ensure the correct procedure was followed and to prevent further delays.
10. On 22 September 2024, the resident requested that her complaint be escalated to stage 2. However, between September 2024 and March 2025, the landlord failed to take any meaningful action to progress the matter. It eventually issued its stage 2 response on 7 March 2025, in which it provided a timeline of events and acknowledged that it had significantly failed the resident in assisting with her adaptation request. The landlord also confirmed that the resident had been awarded priority A banding for rehousing. This is the highest priority status available, and timing of a move was dependent on property availability. While the allocation of priority A banding was reasonable given the circumstances, the extended delay in addressing the complaint and the lack of proactive engagement represented a serious service failure. The landlord could have acted sooner to mitigate the impact on the resident and to demonstrate a commitment to resolving her concerns effectively.
11. The landlord acknowledged that the resident had made multiple follow-up attempts, experienced poor communication throughout the process, and was provided with an incorrect email address, all of which significantly contributed to the delays in addressing her request. These failures reflect a lack of clear guidance and effective case management, which placed an unnecessary burden on the resident and prolonged the resolution of her concerns. In recognition of these shortcomings, the landlord offered the resident £600 in compensation. This was a positive and appropriate step towards putting things right; however, while the financial redress demonstrates an attempt to remedy the situation, it does not fully mitigate the inconvenience and distress caused by the prolonged delays and repeated communication failures.
12. In April 2025, the landlord liaised internally and noted that minor adaptations would need to be recommended by an OT. It confirmed that the OT had already recommended a level access shower, but also advised that, in the long term, the resident would require a more suitable property to meet her needs. Despite this, in May 2025, the aids and adaptations team stated that it still had no record of the original request, though it would seek urgent approval for the OT’s recommendations. Later that month, the resident contacted the landlord again, highlighting that it had been 2 months since she last received an update. The landlord responded by advising that it would only make contact once a suitable property had been identified.
13. This approach was unreasonable. It is good practice for landlords to maintain regular communication with residents, even when there is no new information to share. Providing periodic updates demonstrates that a landlord is actively managing the case and taking the resident’s concerns seriously. Failure to do so can lead to increased frustration, uncertainty, and a perception of being ignored or unheard, particularly in cases involving health-related adaptations where timely action is key.
14. On 30 May 2025, the landlord’s complaint handler instructed that the resident be contacted with an update as a “matter of priority” and suggested that minor adaptations be implemented while she awaited a move. This demonstrated a resolution-focused approach and reflected a genuine effort by the complaint handler to assist the resident and mitigate the impact of ongoing delays. This is an example of good practice, as the landlord sought to provide interim solutions rather than leaving the resident without support.
15. Following this, the landlord contacted the resident and advised that she would need an up-to-date OT assessment, requesting that she contact social services to obtain one. This was particularly unfair and unreasonable, given that the resident had already been waiting over 2 years for her original request to be considered and had provided copies of the initial OT report on multiple occasions. By placing the responsibility back on the resident at this stage, the landlord failed to acknowledge the significant delays and its own role in the lack of progress. This approach not only placed a further burden on the resident but also undermined her confidence in the landlord’s commitment to resolving the matter effectively.
16. On 2 July 2025, the resident raised further concerns, stating that the landlord had not fulfilled the commitments made in its stage 2 response. Specifically, she had not been rehoused, and no adaptations had been approved. In response, the landlord appropriately opened a new complaint and issued its stage 1 response on 16 July 2025.
17. In that response, the landlord explained that the resident remained on the highest priority banding but that no suitable properties were currently available. It suggested widening her search area to increase the chances of a quicker move. The landlord also confirmed that an urgent request had been submitted to the minor adaptations team on 14 April 2025, but regrettably, no update had been received since then.
18. The complaint was upheld, and the landlord offered £100 compensation. While this gesture was a step toward remedying the situation, it did not address the significant and ongoing delays the resident continued to experience. Despite previously acknowledging its substantial failings, the landlord had still made no tangible progress.
19. On 30 June 2025, the resident escalated her complaint because she was dissatisfied with the landlord’s response. The landlord issued its stage 2 response on 4 August 2025, increasing its compensation offer to £200. In this response, it acknowledged that there had been a delay in processing the resident’s aids and adaptations request and offered an apology. However, it stated that it was reasonable to request an updated OT assessment, as the previous assessment was over 2 years old.
20. The landlord further explained that a request for a walk-in shower could not be approved in a general needs property while a property transfer application was active. According to the applicable policy, where a resident is on the transfer list and a move is expected within 6 months of an application for a major adaptation, the request will be considered on a case-by-case basis. Importantly, the policy does not categorically prohibit major adaptations in general needs properties.
21. Throughout the complaint period—spanning more than 2 years—the landlord failed to demonstrate any clear decision making regarding the adaptation request. This prolonged inaction left the resident in a state of uncertainty, with no improvement to her living conditions, where she had no suitable access to bathing facilities.
22. The resident had been assigned priority banding for rehousing for over 2 years, yet no suitable property was offered during this time. While it is acknowledged that there is a nationwide shortage of social housing, landlords are still required to manage their housing stock effectively, ensuring that homes are allocated to those most in need. The key questions for this investigation are whether the landlord followed its policy and procedure, treated the resident fairly, and communicated with her effectively. The evidence indicates that it did not. The landlord’s policy states that adaptations should be considered on a case-by-case basis if a transfer is expected within 6 months. Despite being aware of the resident’s prolonged wait for rehousing, the landlord made no attempt to consider interim adaptations or arrangements that could improve her quality of life (such as access to other nearby bathing facilities). This failure is considered unreasonable given the length of time the complaint has been ongoing.
23. In summary, the landlord repeatedly failed to manage the resident’s aids and adaptations request effectively, resulting in prolonged delays, poor communication, and unnecessary burden on the resident. Although the landlord acknowledged its failings and offered compensation, these actions came too late to prevent significant inconvenience and distress. Importantly, the delays and onus placed on the resident continued even after the initial complaint process concluded in March 2025, further undermining her confidence in the landlord’s ability to resolve the matter. For this reason, we consider it appropriate to require the landlord to provide financial redress that reflects the resident’s loss of use of the bathroom. Under the landlord’s compensation policy, a rent reduction is recommended where there has been a total or partial loss of bathroom facilities. The loss of use for the resident was evident from the OT reports.
24. The period for this calculation is from 13 June 2023 to 8 December 2025, starting when the landlord received the occupational therapy report and continuing to the present date, as the issue remains unresolved. A reduction of 10% of rent has been applied for this 30-month period. An additional award has been made for distress and inconvenience.

25. The landlord’s complaints policy in place during the period of the complaint states that stage 1 complaints will be responded to within 10 working days, and stage 2 complaints within 20 working days. In addition, the policy requires that all complaints are acknowledged within 5 working days of receipt.
26. The landlord acknowledged the resident’s complaint within 2 working days, which was consistent with its policy timescale. The stage 1 response was sent one working day outside of its policy timescale, but this was not considered an unreasonable delay.
27. The resident requested escalation of her complaint to stage 2 on 22 September 2024. The landlord responded on 26 September 2024,stating the matter would be passed to the complaints team. However, this did not constitute a formal acknowledgement under its policy. Following intervention from us on 7 February 2025, the landlord formally acknowledged the stage 2 complaint the same day and issued its stage 2 response on 7 March 2025. This was one day outside its policy timescale. Nevertheless, the resident had initially requested to escalate her complaint over 5 months earlier. In its stage 2 response, the landlord acknowledged its complaint handling failure and offered £175 compensation, which we consider sufficient to put things right.

Learning

28. Our investigation found the following points of learning for the landlord:

Knowledge and information management (record keeping)

29. The landlord’s record keeping was inadequate throughout the process. Key information, such as the resident’s original aids and adaptations request and OT recommendations, was either missing or not properly logged, leading to repeated confusion and unnecessary delays. Accurate and consistent record management is essential to ensure timely action and prevent avoidable escalation. Our spotlight reports on complaints about repairs and knowledge and information management can assist with this.

Communication

30. This case highlights the need for proactive case management, clear communication, and timely escalation to ensure residents receive the support they require without prolonged uncertainty.
31. The landlord’s complaint handler prioritised updating the resident and proposed minor adaptations while awaiting a move. This showed a proactive, resolution-focused approach and good practice by offering interim support rather than leaving the resident without assistance.