Citizen Housing Group Limited (202501755)

Decision
Case ID	202501755
Decision type	Investigation
Landlord	Citizen Housing Group Limited
Landlord type	Housing Association
Occupancy	Assured Tenancy
Date	19 December 2025

Background

1. The resident lives in a 1-bedroom flat situated in a communal block. She has physical disabilities including sickle cell anaemia and fibromyalgia. She also has mental health difficulties known to the landlord. She has complained about several issues including scratching noises from rodents, which she has advised remains unresolved.

What the complaint is about

2. The complaint is about the landlord’s handling of the resident’s:
   1. Reports of a pest infestation.
   2. Concerns about a transfer request.
   3. Reports of racial harassment.
   4. Concerns about discrimination.
   5. Associated complaint.

Our decision (determination)

3. We have found that there was:
   1. Maladministration in the landlord’s handling of the resident’s reports of a pest infestation.
   2. Service failure in the landlord’s handling of the resident’s concerns about a transfer request.
   3. No maladministration in the landlord’s handling of the resident’s reports of racial harassment.
   4. Maladministration in the landlord’s handling of the resident’s concerns about discrimination.
   5. Service failure in the landlord’s complaint handling.

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

Summary of reasons

Pest infestation

4. The landlord did not act with sufficient urgency and failed to identify the resident as vulnerable or prioritise her case. It delayed instructing pest control after the initial report and there were further unreasonable delays with follow-up treatments. In addition, it did not implement some of the recommendations made by pest control.

Transfer request

5. The landlord’s decision not to offer a discretionary move was consistent with its policy. However, it failed to respond when the resident chased for an update, and it delayed in explaining the evidential requirements for exceptional rehousing.

Racial harassment

6. The landlord’s antisocial behaviour (ASB) records show no evidence that it received or ignored reports of racial harassment.

Discrimination

7. The landlord did not seek to understand the resident’s concerns or conduct a thorough investigation into her allegations of discrimination. It also failed to evidence that it had properly considered its obligations under the Equality Act 2010.

Complaint handling

8. The landlord delayed acknowledging the resident’s stage 1 complaint and issued its stage 2 response slightly late. It did not identify service failings in its handling of the pest reports, despite available evidence. It also failed to log new concerns raised in the escalation request as a separate complaint.

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 provided by a senior member of staff. 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 16 January 2026
2	Compensation order The landlord must pay the resident £1,150 made up as follows: £600 to recognise the distress and inconvenience caused by the errors in its handling of her reports of a pest infestation. £100 to recognise the distress and inconvenience caused by the errors in its handling of her concerns about a transfer request. £300 to recognise the distress and inconvenience caused by the errors in its handling of her concerns about discrimination. £150 for the complaint handling failures identified. This must be paid directly to the resident by the due date. The landlord must provide documentary evidence of payment by the due date.   The landlord may deduct from the total figure any payments it has already made.	No later than 16 January 2026
3	Pest control order The landlord must contact the resident by the due date to: Discuss the reported ongoing pest issues. Provide an update on its position, including a summary of the actions taken to date and findings (as outlined in the pest control investigation report dated 10 December 2025).   The landlord must also: Review the recommendations listed in the investigation report dated 10 December 2025. Provide a clear action plan to both us and the resident by the due date, outlining the actions it intends to take and likely timescales for completion.	No later than 16 January 2026
4	Discrimination concerns order The landlord must write to both us and the resident by the due date, setting out: An explanation of the evidence it reviewed when investigating her reports of discrimination. Its reasons for concluding that there had been no discrimination against her.	No later than 16 January 2026
5	Record keeping order The landlord must contact the resident by the due date to ensure that its health and vulnerability records accurately reflect her household’s circumstances.	No later than 16 January 2026

 

Recommendations

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

Our recommendations
It is recommended that the landlord contacts the resident to see if she needs any support or assistance with making an application for rehousing.
It is recommended that the landlord familiarises itself with our spotlight report on Knowledge and Information Management (KIM). It should consider assessing its internal recording procedures against the recommendations in this report.

Our investigation

The complaint procedure

Date	What happened
March 2023 to August 2023	The resident reported ASB from her neighbour to the landlord.
January 2025	The resident reported hearing scratching noises in her property to the landlord, which she believed were caused by rodents.
18 February 2025	The resident’s local MP complained to the landlord on her behalf. They said that they understood the resident had been in regular contact regarding a rat infestation, but the issue remained unresolved.
12 March 2025	The landlord issued its stage 1 response. It did not uphold the complaint as it said it had been unable to identify any service failures. It explained that pest control had completed follow-up treatments and committed to continue to monitor the situation.
13 March 2025	The resident escalated her complaint. She said she remained dissatisfied as no effective action had been taken to resolve the ongoing pest infestation. She also raised additional concerns regarding a transfer request, racial harassment, discrimination, and the landlord’s complaint handling.
15 May 2025	The landlord issued its stage 2 response. It partially upheld the complaint and apologised for the delay in acknowledging the complaint at stage 1. It offered £100 compensation in recognition of this delay. The landlord did not uphold the other elements of the complaint, stating: The block did not have a pest infestation. It had not received any documents from the resident to support a transfer request. It had not received any reports of racial harassment from the resident. It was committed to promoting equality, diversity, and inclusivity, and had not breached these principles.
Referral to the Ombudsman	The resident asked us to investigate, as she said the pest infestation remained unresolved. She explained that her health had been in constant decline, leaving her at her “wits end”.
3 December 2025	During her contact with us, the resident said she was still hearing scratching noises. As an outcome, she said she would like the landlord to resolve the pest infestation and asked us to consider awarding compensation for the landlord’s handling of her reports. She also stated that she would like to move to another property.

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 landlord’s handling of the resident’s reports of a pest infestation
Finding	Maladministration

9. The landlord does not have a specific pest policy. However, its estate management policy states that it is responsible for dealing with pest infestations in communal areas. The policy does not specify response times for pest treatment.
10. The resident reported concerns about pests on 20 January 2025, advising that she could hear scratching in the wall. She explained the noise was disturbing her sleep and triggering reactions linked to existing health conditions. The landlord raised a job, which was marked as completed on 23 January 2025. However, due to the lack of clear and detailed records, we cannot confirm what action was taken or whether the response was appropriate.
11. On 4 February 2025, the resident chased the landlord for an update, adding to her time and trouble. Pest control attended on 7 February 2025—18 days after the initial report—and confirmed the presence of rats. This delay was unreasonable given the resident had reported sleep disturbance and its impact on her health.
12. Pest control recommended installing an inspection hatch in the hallway of the block to allow baiting and inspection inside the walls, as it suspected this was where the rats were located. It requested further instruction from the landlord but explained that without access to the wall cavity, it could not carry out any treatment. It also recommended a drain survey. The landlord did not act on these recommendations straightaway, which was inappropriate and demonstrated a lack of urgency given the nature of the issue. This likely caused the resident frustration and contributed to her decision to escalate the matter through the complaints process.
13. The resident chased the landlord on 4 occasions between 20 February and 28 February 2025, demonstrating the distress the situation was causing her. She requested an update on follow-on treatment, reported a visible hole, and expressed concerns about rats entering her property. Despite these repeated contacts, the landlord did not respond until 10 March 2025, which was unreasonable. When it did reply, it did not provide a meaningful update, only advising that a drain survey had been requested and that pest control would contact the resident to arrange a further visit. This limited response failed to reassure the resident or demonstrate effective action, further contributing to her distress and inconvenience.
14. In her escalation request on 13 March 2025, the resident raised concerns that the infestation had spread. Pest control inspected again on 18 March 2025 and found no signs of pest activity. It recommended that the landlord seal all external gaps and any gaps inside the resident’s property, check around utility pipes, and provide access to the wall cavity for inspection and baiting. However, there is no evidence that the landlord raised any further repairs in response to these recommendations or discussed a plan to enable pest control to access the wall cavity. This indicates a lack of follow-through on professional advice, which was inappropriate.
15. On 8 April 2025, the resident reported a foul smell in her property, which she believed was caused by dead rodents in the walls. Pest control attended the following day (9 April 2025), which was appropriate given her concerns. It is unclear what was discussed about the smell, but it noted that the resident was still hearing scratching noises. It found no external access points or signs of activity in the false ceiling around the property and concluded there was no evidence of a current infestation. It again recommended a drain survey, suggesting that the access point could be hidden above ground. At this stage, it would have been reasonable for the landlord to progress the drain survey, which it had said was requested a month earlier, but there is no evidence that this happened. This showed a lack of timely action and left the resident with unresolved issues and ongoing distress.
16. Pest control attended again on 16 April 2025, but it is unclear what prompted this visit. The landlord’s records indicate there was no access, yet 2 separate pest control reports give conflicting reasons—one stating the resident refused access and the other that she was not at home. In the landlord’s final response on 15 May 2025, it said the resident had refused access on 16 April 2025 and it still needed to complete treatment. The resident has said she did not refuse access, but due to the inconsistencies in the records, we cannot confirm what occurred.
17. The resident told us that that the stress of living in a rodent–infested building had triggered existing health conditions, resulting in a severe decline in her wellbeing. She also told us in May 2025 that she had been staying away from the property because of the issues, showing the significant impact the situation had on her ability to use her home. While we are not medical specialists and cannot determine impact on health, we can consider the distress and inconvenience caused by any failings in the landlord’s response.
18. The landlord was aware of the resident’s vulnerabilities during its complaint investigation. On 3 March 2025, the resident provided the landlord with a letter from her occupational therapist stating that her living environment was impacting “heavily” on her health and wellbeing. This should have prompted the landlord to act with greater urgency, identify the resident as vulnerable, and prioritise the case. However, it did not do so, which was inappropriate given her circumstances. When we asked for details of any vulnerabilities, the landlord responded with details of the resident’s physical and mental health conditions, but sickle cell anaemia had not been recorded. A relevant order has been made in respect of this.
19. The landlord did not identify any failings in its complaint investigation regarding the pest infestation, and as a result, did not offer any compensation. We consider a payment of £600 to be appropriate. This has been calculated in accordance with our remedies guidance, which recommends awards of this level where there have been failures which had a significant impact on the resident and the redress needed to put things right is substantial.
20. During contact with us in December 2025, the resident reported that she was still hearing scratching noises. When we requested an update as part of this investigation, the landlord provided an investigation report dated 10 December 2025. The report confirmed attempts by pest control to access the resident’s property on 15 and 29 May 2025 but noted no works orders had been raised since then. It stated there had been no evidence of rodent activity in the building since February 2025 and that a specialist drain inspection found no damage or access points for rodents. The report included recommendations for next steps. An order has been made in relation to this matter.

Complaint	The landlord’s handling of the resident’s concerns about a transfer request
Finding	Service failure

21. In her escalation request on 13 March 2025, the resident said she had submitted a transfer request on 19 February 2025 due to both the pest infestation and a recent threat to harm her. She advised that she felt ignored and had received no “meaningful response” from the landlord regarding this request.
22. In its final response on 15 May 2025, the landlord advised that it had spoken to the resident on 19 February 2025 after she reported an incident, during which she advised she wanted to move because she did not feel safe. It said it had informed her that it did not maintain its own transfer list and that applications to move needed to be made via the local authority. There are no contemporaneous notes of the telephone call referenced in the landlord’s complaint response. This demonstrates poor record keeping. As a result, we are unable to verify the landlord’s account or assess whether its response appropriately addressed the issues raised.
23. On 26 February 2025, the resident chased the landlord for an update on her transfer request. However, there is no evidence that the landlord responded, which likely caused frustration and contributed to her perception of being ignored.
24. The landlord further explained in its final response that it recognised exceptional circumstances, such as threats to life or safety, may require rehousing. It stated that in such cases, it would require evidence from the police. Additionally, it advised that where health or disability issues meant remaining in the property would have a permanent detrimental impact, it would require supporting evidence from medical professionals explaining why the property was unsuitable. This approach was consistent with its lettings policy. However, it was unreasonable that it took 3 months from the resident’s initial request for the landlord to explain this to her.
25. In its final response, the landlord concluded that based on the current information available, the resident did not meet the criteria for rehousing outside its normal allocation process. Based on the evidence reviewed during this investigation, this decision was in line with its lettings policy. The landlord appropriately stated it could review the decision if the resident provided the supporting evidence required. It also gave her details of the local authority’s choice-based lettings system, offered to assist with the application, and provided information about mutual exchange. These were positive steps, demonstrating a commitment to supporting the resident despite its limitations regarding a discretionary move.
26. The landlord did not identify any failings in its complaint investigation regarding the transfer request, and as a result, did not offer any compensation. We consider a payment of £100 to be appropriate. This has been calculated in accordance with our remedies guidance, which recommends awards of this level where there was a failure by the landlord in the service it provided, which it did not appropriately acknowledge or fully put right.
27. After the complaints process ended on 15 May 2025, the landlord received a supporting letter regarding the resident’s health conditions and housing situation. The landlord considered this but determined on 17 June 2025 that the resident did not meet the criteria for a discretionary move. It signposted her to the local authority to explore alternative rehousing options. During contact with us in December 2025, the resident confirmed she still wished to move to another property. A recommendation has been made in relation to this matter.

Complaint	The landlord’s handling of the resident’s reports of racial harassment
Finding	No maladministration

28. In her escalation request on 13 March 2025, the resident said she had endured years of racial harassment from a neighbour, of which she had provided evidence to the landlord. She advised that she felt the landlord had not addressed these issues appropriately and had shown a “blatant disregard” for her safety.
29. In its final response on 15 May 2025, the landlord acknowledged that it had previously had open ASB cases following reports from the resident about an ex-tenant, but said it had received no reports of racial harassment from her.
30. While we do not dispute the resident’s account, our findings must be based on documentary evidence. The landlord provided ASB records dating back to March 2023, which show reports from the resident regarding her neighbour about loud music and verbal abuse. However, the records contain no information about racial harassment.
31. Based on the evidence reviewed during this investigation, there is no indication that the landlord received or ignored reports of racial harassment. Therefore, we have not identified any failures in its handling of the resident’s reports.

Complaint	The landlord’s handling of the resident’s concerns about discrimination
Finding	Maladministration

32. The landlord has an obligation under the Equality Act 2010 to consider how its policies and decisions affect people with protected characteristics, such as race and disability. When complaints about discrimination arise, our role is not to determine whether discrimination occurred, as this is a legal matter best suited for a court. Instead, our role is to assess whether the landlord carried out a proportionate investigation into the resident’s concerns, considered its duties under the Act, and responded appropriately.
33. The resident first made the landlord aware of her discrimination concerns in her escalation request on 13 March 2025. She alleged that the landlord had discriminated against her on the grounds of race and disability, stating this was a “violation” of the Equality Act 2010. She advised that the landlord had protected her neighbour (whom she had reported for ASB) because they shared the same race as the landlord’s housing manager. She also said that the landlord had failed to acknowledge her disabilities and the increased health and safety risks posed to her by the rodent infestation.
34. Following the resident’s escalation request, there is no evidence the landlord attempted to contact her to discuss the complaint or clarify her concerns, which was inconsistent with its complaints policy. In its final response on 15 May 2025, the landlord said it needed more detailed information about the resident’s claim of discrimination and invited her to provide this for review. While it was appropriate to request further details, it was unreasonable that the landlord did not make reasonable efforts to contact the resident to obtain this information before issuing its response. This was a missed opportunity to resolve the matter and address the resident’s concerns more effectively.
35. In its final response on 15 May 2025, the landlord disputed the resident’s claims that it had sided with the ex-tenant due to a “shared race”. It explained that the resident’s ASB reports had been investigated: a case was opened, regular reviews were completed, and updates were provided. The landlord concluded it had acted appropriately in line with its policies and procedures. It also stated that it had policies to prevent discrimination and make reasonable adjustments where required. It said that in the resident’s case, it had not breached its commitments, as it had responded to reports such as the pest issue and put measures in place to address them. While this shows some attempt to address the resident’s concerns, its response was lacking and failed to address her specific concerns, particularly in relation to the pest problem.
36. The landlord has a duty under the Equality Act 2010 not to unlawfully discriminate against individuals based on protected characteristics. When allegations of discrimination arise, we would expect the landlord to carry out a full and thorough investigation before responding as part of its complaints process. We have not seen any evidence that such an investigation took place. Furthermore, the landlord’s complaint response did not explain how it had considered or investigated the resident’s concerns, instead simply stating its conclusion. As the landlord cannot evidence that it fulfilled this duty, it is reasonable to conclude that it did not properly consider its obligations under the Act. This was inappropriate and unfair to the resident, and represented a missed opportunity to show it had taken her concerns seriously and restore confidence in its service.
37. The resident said that the landlord’s discriminatory behaviour had a significant impact on her health and wellbeing. The explanation provided in paragraph 17 regarding health also applies to this point.
38. The landlord did not identify any failings in its complaint investigation regarding discrimination, and as a result, did not offer any compensation. We consider a payment of £300 to be appropriate. This has been calculated in accordance with our remedies guidance, which recommends awards of this level where there have been failures that adversely affected the resident and where the landlord’s original offer was not proportionate to the failings identified during our investigation.

Complaint	The landlord’s complaint handling
Finding	Service failure

39. Our Complaint Handling Code (‘the Code’) sets out when and how a landlord should respond to complaints. In this case, the relevant Code was published in April 2024. The timescales outlined in the landlord’s complaints policy were consistent with the requirements of the Code.
40. The landlord took 10 working days to acknowledge the resident’s stage 1 complaint, only doing so after the resident chased on 3 March 2025. However, it did issue its stage 1 response 6 working days later, meaning it took 16 working days in total to acknowledge and respond – representing a one-day delay overall. At stage 2, the landlord acknowledged the escalation and requested an extension within the required timescales. It issued its stage 2 response on 15 May 2025, 22 working days after the extension request, exceeding the timescales set out in its policy and the Code by 2 working days.
41. The resident raised additional concerns in her escalation request that had not been investigated at stage 1. Under the Code, landlords are required to log a new complaint in such circumstances. However, the landlord failed to do so, which was inappropriate. Instead, it addressed the additional concerns within its stage 2 response. By doing this, the landlord denied the resident the opportunity for these issues to go through the full 2-stage complaints process.
42. The stage 2 complaint was the landlord’s final opportunity to review its handling of the substantive issue, yet it did not identify failures in its service that had occurred in managing the resident’s pest reports. This was inconsistent with the available evidence and indicates a lack of thoroughness in its investigation. As a result, the landlord missed the opportunity to remedy the substantive issue and rebuild the landlord-tenant relationship, failing to use its complaints process as an effective tool to put things right.
43. In its final response, the landlord offered £100 in compensation in recognition of its delay in acknowledging the complaint at stage 1. We consider an additional payment of £50 to be appropriate to recognise the additional complaint handling failures identified. This brings the total compensation the landlord is ordered to pay the resident to £150. This is in accordance with our remedies guidance for circumstances where there was a failure by the landlord in the service it provided, which it did not appropriately acknowledge or fully put right.

Learning

44. The landlord should ensure that any new issues arising after the stage 1 complaint response, which are unrelated to the matters already investigated, are logged as a separate complaint. This will ensure any new issues can progress through both stages of the complaints process.
45. The landlord should ensure it conducts thorough investigations when handling complaints and keeps clear records of its findings. Complaint responses should address all aspects of the complaint, providing clear and detailed explanations supported by relevant policies, legislation, and good practice where applicable. 

Knowledge and information management (record keeping)

46. There were notable gaps in the landlord’s records, with some events referenced in its complaint responses missing from its documented records. For example, in its stage 1 response, the landlord stated that pest control had attended and completed follow-up treatments. However, there were no records confirming when these visits took place. This highlights the need for improved record keeping between the landlord and its contractors.
47. There were also references to telephone calls with the resident that were absent from the landlord’s records, indicating further shortcomings in record keeping. The landlord should ensure it has systems in place to accurately record all communication with residents.

Communication

48. There was a lack of effective communication from the landlord, particularly regarding the pest infestation, with the resident left to chase and seek answers regarding further investigations and follow-on treatments recommended. This highlights the importance of maintaining regular, proactive communication and providing clear action plans to address reported issues, ensuring residents feel informed and supported throughout the process.