Castles & Coasts Housing Association Limited (202532143)

Decision
Case ID	202532143
Decision type	Investigation
Landlord	Castles & Coasts Housing Association Limited
Landlord type	Housing Association
Occupancy	Assured Tenancy
Date	16 April 2026

 

Background

1. The resident reported to the landlord ongoing anti-social behaviour (ASB), and a staff conduct incident. He also reported the landlord did not respond to his subject access request (SAR) in line with General Data Protection Regulations (GDPR).  The resident was unhappy with the way the landlord handled the incidents and his associated complaints.

 

What the complaint is about

2. The complaint is about the landlord’s handling of the resident’s:

a)     Reports of staff conduct.

b)     Reports of ASB.

c)     Subject Access Request (SAR).

d)     Associated complaints.

 

Our decision (determination)

3. We have found:

a)     Reasonable redress in relation to the landlord’s handling of the resident’s report about staff conduct.

b)     Service failure in relation to the landlord’s handling of ASB.

c)     The landlord’s handling of the SAR is outside of our jurisdiction.

d)     Service failure in relation to associated complaint handling.

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

 

Summary of reasons

Report of staff conduct.

4. The landlord acted reasonably in carrying out a formal disciplinary investigation into the alleged misconduct in line with its policies and procedures. It apologised and took learning from the incident. Although it failed to offer a financial remedy at stage 1, it acknowledged and apologised for its failure to recognise the resident’s distress and inconvenience and offered a fair and proportionate amount of compensation to resolve the complaint at stage 2.

Report of ASB.

5. The landlord took proportionate action to respond to the resident’s reports but on some occasions, it did not acknowledge or respond to ASB within its policy timescales. On occasion it failed to keep the resident adequately updated about the actions it had taken. It did not recognise this or the impact on the resident in its complaint responses.

SAR Request.

6. We are unable to investigate a complaint that falls within the jurisdiction of another organisation to consider. Complaints about the landlord’s data handling processes would be more suitable for the Information Commissioner’s Office to consider.

Complaint handling.

7. The landlord delayed its stage 1 response in relation to the staff conduct complaint by 5 working days. It did not notify the resident of an extension, which does not align with its complaints policy. It failed to recognise the delay or provide an appropriate remedy in its final complaint response.

 

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.

Order	What the landlord must do	Due date
1	Apology order The landlord must apologise in writing to the resident for the failures identified in this report. The landlord must ensure: The apology is specific to the failures identified in this decision, meaningful and empathetic. It has due regard to our apologies guidance.	No later than 14 May 2026
2	Compensation order The landlord must pay the resident £150 to recognise the distress and inconvenience caused by its handling of the resident’s ASB reports. This must be paid directly to the resident by the due date. The landlord must provide documentary evidence of payment by the due date.	No later than 14 May 2026

 

Recommendations

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

Our recommendations
The landlord should pay the resident the sum of £500 offered in its stage 2 response for the impact of its staff conduct complaint, if it has not done so already. The finding of reasonable redress is based on this sum being paid to the resident.

 

Our investigation

The complaint procedure

Date	What happened
9 June 2025	The resident complained about ongoing ASB issues which included repeated noise nuisance, fly-tipping, animal nuisance and no follow up on tenancy breaches. The resident said he had already submitted a Subject Access Request (SAR) for his personal data to the landlord.
25 June 2025	The landlord issued its stage 1 response. It said: Its investigation included a review of the resident’s emails and noise application recordings which identified in addition to normal living housing noise, some noise it would class as ASB. It kept the resident updated in line with its ASB and GDPR policy. It addressed the matters in writing with the alleged perpetrators and warned them of potential a tenancy breach and enforcement steps. It could not discuss tenancy breach rent arrears matters in relation to other tenants due to GDPR. It’s confirmed its pet policy and confirmed it issued a verbal warning to the relevant resident about communal mess. It sought confirmation of arrangements made for its local authority to remove waste. It said if it would close the complaint by 8 July, but it could review it again and escalate to stage 2 if the resident remained dissatisfied.
3 September 2025	The resident made a report of staff misconduct alleging a member of staff urinated on his porch wall one metre from his window. The resident alleged the same staff member engaged in an inappropriate conversation and used offensive language.
30 September 2025	The landlord issued its stage 1 response to the staff conduct complaint. It upheld the resident’s complaint and said: It addressed the employee conduct through its disciplinary policy but could not share the outcome with the resident due to confidentiality. Its employee admitted the conduct, showed remorse for their actions, and offered mitigation on medical grounds. It offered an apology to the resident on behalf of its employee for any offence caused. It assured the resident it completes criminal background checks and highlights its code of conduct in relation to all employees. It said it had learnt lessons following the resident’s complaint. It sent reminders to its workers setting out the standards expected and circulated details on what employees should do in similar circumstances.
9 – 10 October 2025	The resident escalated both complaints to stage 2. He said: There were systemic failures and lack of accountability by the landlord, which he said was also reflected in how it had handled his ongoing ASB issues. The landlord failed to adhere to GDPR obligations in relation to its handling of his SAR.
10 and 13 October 2025	The landlord acknowledged the resident’s stage 2 escalation request and said it would open a new stage 1 complaint about the SAR issues.
23 October 2025	The landlord issued its stage 1 complaint response in relation to the SAR matter. It did not uphold the resident’s complaint. The resident disputed the landlord’s approach to its complaint handling as an abuse of its process because it had dealt with this complaint separately rather than as part of his overall escalated complaints.
5 November 2025	The landlord issued its stage 2 complaint and concluded: Staff conduct It acknowledged the resident’s views about staff conduct matters but explained it had not intended to minimise the resident’s experience by not disclosing the outcome of its disciplinary proceedings which was due to confidentiality. It said it had upheld the resident’s complaint at stage 1 and identified learning but apologised it had not offered a remedy. It awarded the resident a sum of £500 to reflect the distress and inconvenience caused. ASB It reviewed its previous stage 1 response and the landlord’s actions following reports of ASB since. It concluded its actions were proportionate and in line with its ASB procedure. Complaint handling It said it did not intend its timeframe for complaint closure to be a barrier. It said would always consider a review of a complaint matter outside of the set timescales in view of the circumstances and a resident’s vulnerability. Its Customer Experience Team had not previously recorded a formal complaint about the landlord’s handling of the resident’s SAR which it set up as a new stage 1 complaint for investigation in line with its procedure. SAR It provided its stage 1 response which found no breach of GDPR therefore it did not refer itself to the Information Commissioner’s Office.
Referral to the Ombudsman	The resident referred his complaint to us before the landlord issued its stage 2 complaint. He said he wished for the landlord to be accountable for its failure to follow its procedures and for it to for it to take effective action to address ongoing ASB. The resident said he wanted to be compensated for the distress and inconvenienced caused by the landlord’s failure to follow its own policies.

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.

Complaint	The handling of the Subject Access Request (SAR).
Finding	Outside jurisdiction

8. The resident’s complaint relates to how the landlord handled a SAR and whether it followed its internal data handling processes.
9. Concerns about the handling of personal data and compliance with data protection requirements fall outside our role and are more suitable to be considered by the Information Commissioner’s Office which is responsible for overseeing data protection matters.
10. For these reasons, we are unable to investigate the resident’s complaint about the handling of their SAR.

Complaint	The handling of the staff conduct.
Finding	Reasonable redress

11. On 2 September 2025, the resident reported that he had witnessed alleged misconduct by a contractor working on the landlord’s behalf. He said the contractor urinated in public and engaged in an inappropriate conversation while on the estate, which caused him distress and made him fearful for his safety. The resident provided mobile phone video footage in support of his report.
12. We cannot consider the merits or outcome of disciplinary action taken against an individual. Our assessment focused on whether the landlord followed a fair and transparent process in line with its policies and whether it took appropriate steps to address the impact on the resident.
13. The landlord’s disciplinary policy states that it will investigate allegations of misconduct either informally or formally depending on their seriousness. A formal investigation includes meeting with the individual subject to the allegations, considering any evidence provided and keeping confidential records of the process and outcome. The evidence shows the landlord’s Human Resources team carried out a formal disciplinary investigation into the resident’s report. This included reviewing the video evidence submitted by the resident, meeting with the staff member concerned and requesting additional evidence to understand the circumstances of the incident. The staff member admitted the conduct alleged and expressed remorse. He also provided mitigation in relation to his conduct, which the landlord considered as part of its investigation.
14. While the landlord could not share the detailed disciplinary records with the resident due to confidentiality, the information provided to us demonstrates that it followed its disciplinary procedure and took the allegation seriously. Based on the evidence available, the landlord acted in line with its policy and carried out a reasonable investigation into the reported misconduct.
15. In its stage 1 complaint response, the landlord explained that it had investigated the incident, apologised to the resident for the distress caused, and gave reassurance that it carries out appropriate background checks on its staff. It also explained that it had taken learning from the incident and shared this with employees to reduce the risk of a similar situation occurring again.
16. The resident remained dissatisfied as he felt the response minimised the seriousness of what he had witnessed and did not adequately recognise the distress and inconvenience he experienced. He was also unhappy that the landlord had not offered a financial remedy. While we accept the landlord could only disclose limited explanations regarding its investigation into staff conduct because of confidentiality, its apology and acknowledgment of the resident’s experience was appropriate. However, at stage 1 it did not fully address the impact of the incident on the resident through its redress. Given the serious nature and resident’s reports about how it had impacted the resident an offer of compensation would in our view also have been appropriate.
17. At stage 2 of the complaint process, the landlord acknowledged that it had not previously offered a financial remedy to recognise the distress and inconvenience caused by the incident and its handling of the matter. It apologised and offered compensation to reflect the impact on the resident. This was reasonable in the circumstances. The landlord recognised that although it had followed its disciplinary process, the conduct of its contractor had caused the resident distress. The compensation offered aligns with our compensation guidance where a landlord’s service failure has adversely affected a resident but has not had a permanent impact.
18. The landlord confirmed it had identified learning from the incident and had taken steps to share this with staff. This demonstrates that it sought to put things right for the resident and to reduce the risk of recurrence in line with our dispute resolution principles to act fairly, to put thing right and learn from outcomes. Therefore, the landlord’s overall response at stage 2, including its apology, compensation and learning was reasonable and proportionate to the circumstances of the case.

Complaint	The handling of the ASB.
Finding	Service failure

19. The landlord is expected to take reasonable and proportionate steps to address reports of anti-social behaviour (ASB) associated with their properties. Our role is to assess whether the landlord responded reasonably to the reports of ASB and whether it acted in line with its own ASB policy and good practice.
20. The landlord’s ASB policy explains that it assesses reports on a case-by case basis. It aims to acknowledge new ASB reports within one working day. It also aims to review further noise monitoring application submissions within 5 working days. Where it assesses a first report as medium risk, the policy states that it will complete a risk assessment within 5 working days, and that it will complete further risk assessments only if there is a significant change in circumstances.
21. The resident submitted evidence of ASB through the noise monitoring application and shared other evidence via an online shared drive. The incidents related to noise nuisance and other ASB relevant to a particular neighbour between January and November 2025. The records show following the resident’s online report on 12 January 2025 it contacted the resident and completed a risk assessment on 17 January 2025. This was within the timescale set out in the policy. The landlord assessed the case as medium risk. Having considered the nature of the noise reported, we find this assessment was reasonable and consistent with the landlord’s policy classifications at the time.
22. The evidence shows the landlord did not always acknowledge or log the resident’s reports within its one-day target. However, for most reports it responded within 5 working days. There were some delays that fell outside of its policy timescales, including a report made on 12 February 2025 which it responded to on 20 February, and a report made on 16 March which it responded to on 27 March. These delays represent a failure to fully comply with the landlord’s own ASB procedure. While limited, the delays would likely have caused frustration and uncertainty for the resident about whether the landlord was actively addressing the resident’s concerns.
23. The landlord’s internal records show that in January and February 2025 it contacted the relevant neighbour and issued ASB warning letters in response to noise reports. However, there is no evidence that the landlord clearly communicated these actions to the resident at the time. It was reasonable for the resident to expect updates on what action the landlord had taken following his reports in a timely way. The landlord’s failure to keep the resident informed about warning letters and contact with neighbours was a service failure.
24. Following the landlord’s closure letter of 10 April 2025, the resident disputed the landlord’s statement that he had provided no further evidence. The resident raised concerns about a lack of communication. While the landlord had taken some action, the lack of clear and timely updates undermined the resident’s confidence in how the landlord was managing the case. The records do not show the landlord agreed to take further action following the resident’s noise concerns which was unreasonable.
25. The evidence shows the landlord responded within its policy timescales to reports made between April and June 2025 relating to animal nuisance and fly tipping. It also updated the resident in July about progress in addressing the ASB with the relevant individuals, which was reasonable.
26. In relation to noise reports made on 23 August 2025, the landlord decided that the evidence did not meet the threshold for ASB and it issued a closure letter on 28 August. The landlord acted reasonably in assessing whether the threshold for ASB had been met. It was proportionate for the landlord to decide whether to close a case or escalate action on an ASB case based on its assessment of the evidence available relating to each reported occurrence.
27. The landlord recorded that it attempted to contact the resident by telephone about reports logged on 14 October 2025 and when unsuccessful, emailed on 28 October 2025 to close the case. However, there is no evidence that it made further attempts to acknowledge the reports or agree a clear communication plan with the resident before closing the case.
28. There is an absence of evidence of an action plan having been agreed with the resident throughout, which would have been appropriates the landlord could set out how it would respond to the resident’s noise application submissions and how it would keep the resident updated. The landlord’s ASB policy states it will agree how and when updates will be provided to the resident to manage expectations. The absence of this shows a service failure in its communication and record-keeping.
29. Overall, despite minor delays and some communication failures, the evidence shows the landlord was aware of the resident’s ongoing concerns and took a range of actions to address them. This included risk assessing the case, monitoring evidence, contacting neighbours, issuing warning letters and taking proactive steps to address animal nuisance and fly tipping.
30. There were occasions where the noise evidence provided did not meet the landlord’s ASB threshold. On those occasions, it was reasonable for the landlord to decide not to escalate action and to close the ASB case. It provided an explanation to the resident of its decisions in those cases, which was reasonable.
31. However, the landlord did not consistently follow its own communication timescales. It did not always keep the resident informed about the actions taken and did not maintain clear and auditable records of communication with the resident. These failures caused the resident avoidable uncertainty about how the landlord was managing their reports and required the resident to chase updates.
32. Where we have identified service failure, we must consider whether the landlord acted fairly to put things right and learn lessons in line with our dispute resolution principles. In its complaint responses, the landlord stated that it followed its ASB procedures, but it did not adequately acknowledge the impact on the resident of minor delays and poor communication. Therefore, in line with our compensation guidance, an apology and a payment of £150 is appropriate to recognise the uncertainty caused to the resident as well as the time and trouble he spent in pursuing updates about how the landlord was handling his ASB reports.

Complaint	The handling of the complaint
Finding	Service failure

33. The landlord has a published complaints policy which sets out the definition of a complaint and the timescales for acknowledging and responding to complaints. This aligns with the Code. The policy states the landlord will acknowledge complaints within 5 working days and respond within 10 working days at stage 1, and 20 working days at stage 2. It also allows for an extension of up to a further 10 working days in complex cases, provided if informs the resident in advance.
34. The resident made a stage 1 complaint about ASB issues on 9 June 2025, acknowledged by the landlord on 11 June. The landlord issued its stage 1 response on 25 June 2025, within its 10-working day timescale set out in its policy. The resident did not escalate the complaint at this time.
35. On 3 September 2025 the resident made a stage 1 complaint about staff conduct. The landlord acknowledged the complaint on 9 September 2025, which was within its policy timescale. However, it did not issue its stage 1 response until 30 September, which was around 5 working days outside of its published timescale. We have not seen evidence that the landlord informed the resident of an extension in advance, in line with its policy and the expectations set out in the Code.
36. On 10 October 2025, the landlord acknowledged the resident’s request for escalation. The resident had raised concerns about the landlord’s handling of his SAR, alongside his dissatisfaction with the landlord’s response to his ASB and staff conduct complaints. It was reasonable for the landlord to treat the SAR issue as a new stage 1 complaint, as it was a matter that it had not previously considered through its complaints process. The landlord issued its stage 1 response on this issue within 9 working days on 23 October. It also issued its stage 2 response in relation to the ASB, and staff conduct complaints on 5 November, within its 20 working day policy timescale.
37. Having considered the quality of the landlord’s stage 2 response, the response addressed all the issues raised by the resident. The landlord provided an explanation for its actions, and it set out the outcomes on each complaint. The landlord also progressed the ASB complaint to stage 2 in recognition of the resident’s continued dissatisfaction, which was appropriate. While the landlord issued a separate stage 1 response in relation to the SAR, it also demonstrated it had considered the resident’s wider concerns as part of its overall complaint handling, which was reasonable.
38. We recognise the complexity of the landlord’s internal disciplinary investigation, which likely contributed to a delay in responding to the staff conduct complaint at stage 1. However, it did not communicate an extension to the resident in line with its policy or the Code. This represents a minimal failure in the landlord’s complaint handling that did not affect the overall outcome. We therefore order the landlord to apologise to the resident to reflect the short delay in recognition of the inconvenience caused.

 

Learning

Knowledge information management (KIM) (record keeping)

39. This case highlights the importance for landlords to maintain clear, auditable records of contact with residents to clearly demonstrate it acted in line with its policies and procedures as is highlighted in our Spotlight report, ‘On the record’ (May 2023).

Communication

40. The landlord did not communicate with the resident in line with its ASB policy timescales. This impacted on its ability to show how it was managing the resident’s concerns to avoid uncertainty for residents and prevent the resident from chasing it for updates and information. The landlord should reflect on learning resources available in our Centre for Learning in relation to its response to reports of ASB.

Complaint handling

41. The landlord delayed its complaint handling at stage 1 and did not show it had informed the resident of a complaint extension. While the delay did not prevent the landlord from addressing the matters, clearer communication would have managed the resident’s expectations and avoid unnecessary frustration. The landlord should reflect on learning resources available in our Centre for Learning hub which provides guidance on meeting the Code.