Havering Council (202225478)

REPORT

COMPLAINT 202225478

Havering Council

16 August 2024

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 complaint is about the landlord’s response to the resident’s report of a flood.
The Ombudsman has also assessed the landlord’s complaint handling.

Background

At the time of the complaint the resident held a secure tenancy with the landlord, which is a local authority. The resident purchased the property on 25 October 2021.
The resident’s mother acted as her representative during her complaint to the landlord. However, it was the resident who contacted this Service to ask us to investigate her complaint. For the purposes of this report the term ‘resident’ refers to both the resident and her mother when acting as her representative.
The property was a 2 bedroom ground floor maisonette. The landlord’s submission to this Service says that it has no vulnerabilities recorded for the resident. However, evidence provided for the purposes of this investigation shows that the resident’s daughter has autism.
On 25 June 2021 the property suffered “major flooding” caused by heavy rainfall which caused the drains to back surge and overflow. Approximately 80 properties were affected in total. The resident and her family moved out of the property to stay with family members. She began her own works to remedial works including plastering and redecoration. Due to the number of properties affected the landlord referred the matter to its insurer.
On 27 July 2021 the landlord carried out an environmental clean of the property. It also began ‘soft works’ including replacing skirting boards. Following completion of all the remedial works the resident moved back to the property on 30 September.
On 4 July 2021 the resident made a stage 1 complaint to the landlord. She said that it had not provided enough information about how long the repairs would take. She was also dissatisfied that it had failed to offer temporary accommodation and that living with her family was difficult. She requested that the landlord provide her with an update.
The landlord provided its stage 1 complaint response on 29 July 2021, the main points being:
1. It understood that the situation “was not ideal” and that the resident had moved out.
2. Its repairs and maintenance team were working “vigorously to ensure they keep to tight work schedules to ensure properties are repaired and habitable.”
3. It carried out an environmental deep clean of the property on 27 July.
4. Some ‘soft’ works had already been completed, however, additional works would be completed within 2 weeks.
5. It apologised if the communication regarding the work-scope had not been “consistent.” It had fed back to the team manager to ensure that the resident was updated and to confirm when it was “safe to move back into the property.”
6. It understood that temporary accommodation was not required due to the resident living with family. However, if circumstances had changed the resident should contact its housing solutions team.
On 17 August 2021 the resident made a further complaint that:
1. 10 weeks on from the flood all the landlord had done was provide 2 dehumidifiers and fit skirting board which later had to be removed.
2. It took the landlord 4 weeks to carry out a clean and it was only done after the resident chased.
3. She had paid for redecoration and plastering because she got “fed up” of waiting for a response, only to be told that the floors had to be replaced because they contained asbestos.
4. She and her 2 young children, the youngest of whom was autistic, were living with her mother.
5. There had been a lack of communication and she “felt ignored.”
The landlord provided its stage 2 complaint response on 23 December 2022, as follows:
1. The time taken to provide its response was “rare and unprecedented” and not in line with its expectations of the level service it provided. It offered its “sincere apologies.”
2. Due to the lapse in time it had spoken to the resident on 30 June to clarify the definition of her complaint.
3. The flood was unprecedented and due to the number of properties affected it made a referral to its insurers for the damage to be assessed. It acknowledged that it was “extremely stressful” for the resident and that its communication did not meet the expectations of those affected.
4. Its surveyor attended the property on 28 June to assess the damage. It considered the property to be habitable which is why alternative accommodation was not offered at the time. Dehumidifiers were provided on 29 June and the electrics tested the same day.
5. Its loss adjusters visited the property on 6 July and concluded that the property needed to dry out before any reinstatement works could begin.
6. It attended on 8 July to set the work specification to start ‘soft works’. When it attended the resident had already commissioned her own decorators who had carried out plastering and redecoration works. This meant there was no visible water on the floors and it could not test the walls for moisture due to works being undertaken.
7. It acknowledged works were redone at a later stage as moisture came through the plastering works. The contractor began carrying out works including flooring removals, rubbish disposal and renewing skirting boards. The skirting boards were fitted but needed to be replaced as the walls had not dried out. This was shown as completed on 22 July.
8. Its request for a new kitchen was declined by its insurer. Following visits by the loss adjuster it identified what properties required minor works and which required extensive repairs. The resident’s property required less extensive works. Therefore only the replacement of flooring and end panels and plinths to the kitchen were carried out.
9. It had to wait for its insurers drying team to give the go ahead before full reinstatement works could begin. Once specification for remedial works was decided the works went out to tender. The instruction to commence works was given on 6 August with works expected to take place the following week. It apologised if this was not explained to the resident at the time.
10. Its contractor replaced the flooring and carried out other remedial works to the walls. However, the moisture levels in the property caused further delays to works being carried out. All works were completed on 22 September and the resident moved back to the property on 30 September.
11. Although there were reasons for the delays they were not explained to the resident at the time and therefore the complaint about communication was upheld.
12. Repair delays were due to the number of properties affected by the flood as well as reasons above and having to refer to insurers and the need to go out to tender, which was a lengthy process. There was a large amount of work involved in the situation and procedures which had to be followed. However, it sympathised with the resident about the amount of time it had taken to reinstate the property and therefore upheld this part of the complaint.
13. Its surveyor had deemed the property to be habitable. However, it acknowledged that the environmental clean was not carried out until 27 July, nearly 5 weeks after the flood. It understood why the resident felt unsafe living in the property with her children “given the type of water which entered the property.”
14. Although the resident was not living at the property she was obliged to pay rent and therefore this part of the complaint was not upheld. The landlord wrote to residents in November about compensation.
15. On 13 December the resident provided evidence of expenditure. It confirmed it would only look at an increase of charges for electricity due to drying equipment being installed. It would not cover the cost of storage as the property was deemed habitable and the resident was not advised to decant or remove furniture. To date, the resident had not received a response for which it apologised as this was below the level of service it expected to provide.
16. It offered a total of £625 compensation to the resident comprised of:
  1. £160 for the time taken to carry out the environmental clean.
  2. £90 for the time taken to carry out works after the clean.
  3. £250 to cover the increase in the resident’s electricity bill while drying equipment was in situ.
  4. £125 for the delays in the handling of the complaint.
On 19 May 2023 the resident contacted this Service to express her dissatisfaction at the amount of compensation offered by the landlord.

Assessment and findings

Landlord’s obligations, policies and procedures

The Housing Health and Safety Rating System (HHSRS) 2006 requires landlords to recognise and test for hazards taking into account the basic physical and mental needs for human life and comfort. This includes personal hygiene, sanitation and drainage.
The landlord’s decant policy says that:
1. It will arrange to move residents in certain situations including when their health and safety would be at risk or there are extensive works which cannot be carried out with them in the property.
2. It will make a full report on the defects in the property to determine if the resident should be temporarily or permanently re-housed.
3. A disturbance allowance will be paid to cover out of pocket expenses that occur as a direct consequence of a resident being decanted.
4. Residents who are temporarily decanted and do not need to be accommodated by the landlord, for example when staying with family, will be entitled to an allowance of £100 per week per household.
Its complaints policy says it will issue stage 1 complaint responses within 10 working days and stage 2 complaint responses within 25 working days.
Its goodwill gesture policy says that it can make goodwill or discretionary payments for time and trouble, distress and inconvenience. It will carry out an assessment based on whether the service failure and impact was “minor, moderate or severe.” It can also make discretionary quantifiable loss payments where residents can demonstrate actual financial loss.

Flood

The flood occurred on 25 June 2021. The landlord’s file notes show that the resident called on 28 and 29 June to advise that she had moved out and asked what she should do. A further file note dated 5 July said that the resident had called to say she had not had any contact from the landlord since the flood. She said she did not know what was happening, including when she could return.
There is no evidence that the landlord contacted the resident immediately after the flood. Given the uncertainty caused by the incident it was important that the landlord proactively updated residents. That it did not do so was a failure.
The landlord’s records described the incident as “major flooding.” It is acknowledged that the flood affected a large number of properties. This created a complex and challenging situation for the landlord to manage.
It would have been appropriate for the landlord to have formed an immediate incident response plan but there is no evidence it did so. The plan should have included contacting residents to assess the individual needs of their household, based on the level of damage caused to their property and their personal circumstances. That it did not was a serious failure because it demonstrated a lack of concern for the resident’s welfare and that of her young family.
The resident made further attempts to speak to the landlord on 5 and 6 July 2021. Its records show that it did try to contact the resident on 5 July but that it first spoke to the resident on 7 July, 11 days after the flood. It failed to exercise its duty of care to the resident which was unreasonable, causing distress and uncertainty. Furthermore, it eroded the landlord/resident relationship leaving her to feel unsupported.
The landlord’s records dated 30 June 2021 show that during a call to the landlord the resident said she was staying with family but “insurance say she will be out for 3 months.” It is unclear whether this was her own insurance company or an agent acting for the landlord’s insurers. She asked for a disturbance payment in the form of a rent refund and to be “rehoused.” There is no evidence that the landlord provided a response to this request, compounding the resident’s frustration and distress.
During her call to the landlord on 5 July 2021 the resident again asked it to provide her with temporary accommodation. However, it also failed to provide a response on this occasion.
The landlord’s file note of 7 July 2021 recorded that the resident’s daughter had autism. However, there is no evidence that it had due regard to its duty under the Equality Act 2010. This was a failure, particularly given the resident’s request for temporary accommodation. Furthermore, the landlord failed to update its data base to record her vulnerability which was a record keeping failure.
On 29 June 2021 the landlord raised an order to carry out an environmental clean. On 12 July the landlord raised a further works order because it had not been carried out. On 21 July it raised a third works order to carry out the clean because when its contractor attended it only removed the water.
An internal email dated 23 July 2021 shows that the resident called to chase the clean because there was “sewage” in the property. A further internal email sent that day said its contractor would call the resident, also on that day, and make an appointment to carry out the clean the following week. The clean was carried out on 27 July. This was 32 days after the flood and 28 days after the works order was first raised which was unreasonable.
The landlord’s position on whether the property was safe for the resident to occupy in the meantime was not consistent. On 15 July 2021 the resident emailed the landlord to enquire about next steps in terms of making the property “safe” to live in. In an internal email dated 19 July the landlord said “I would say the property is habitable (…).”
The landlord’s complaint responses also contradicted one another on this point. The landlord’s stage 1 complaint response of 29 July 2021 said that it would confirm to the resident when it was “safe to move back into the property.” An internal email, also dated 29 July, confirmed the resident could move back in following the clean.
However, its stage 2 complaint response of 23 December 2022 said that when it inspected on 28 June it had deemed the property to be habitable. It then went on to say it understood why the resident felt unsafe living in the property with her children “given the type of water which entered the property.”
There is no evidence that the landlord satisfied itself that the property was habitable given that it had been flooded by wastewater. Therefore it failed to fulfil its obligations under the HHSRS 2006. The resident had 2 young children, one of whom was autistic, and the landlord had a duty of care to ensure that conditions within the property did not cause a health hazard. Its position that the property was habitable showed a lack of regard for the wellbeing of the resident and her family.
In its stage 1 complaint response of 29 July 2021 the landlord said that it had understood that the resident did not require temporary accommodation because she had moved in with family. This is not supported by its own evidence which shows that on 30 June she said she had moved out with family but asked to be rehoused. On 5 July she asked it to provide temporary accommodation.
In accordance with its decant policy the landlord should have made a full report to determine whether the property was habitable. It would then have been appropriate for it to enter discussions with the resident about the suitability of her current living arrangements to ensure that it met her needs and that of her family. In respect of her daughter’s needs it failed to have regard to its duty under the Equality Act 2010.
Its stage 2 complaint response of 23 December 2022 provided a different explanation as to why temporary accommodation was not offered. It said this was because its surveyor had deemed the property to be habitable. Once again, there was a contradiction in its complaint responses.
The evidence shows that the clean was not carried out until 27 July 2021. In her email to the landlord on 17 August the resident expressed her frustration that it had taken 4 weeks for the clean to be carried out and only after “numerous” calls and emails. In its stage 2 complaint response of 23 December 2022 the landlord offered the resident £160 compensation for the delay in carrying out the environmental clean.
In her email to the landlord of 30 June 2021 the resident asked the landlord to make disturbance payments to her. While she remained obligated to pay the rent, it would have been reasonable for the landlord to consider whether she was entitled to disturbance payments because she could not occupy the property until the clean took place. For example, it failed to consider paying the resident £100 per week as set out in its decant policy. That it did not do so was a failure.
In her email to the landlord of 21 September 2021 the resident described her living conditions. Her young children were living in her parents living room on a blow up bed and her husband in his parents living room on the sofa because he worked nights. Therefore, the family was not able to live together in the same property, causing further distress. She also said that she had put her belongings into storage at a cost of £300. There is no evidence that the landlord responded which was inappropriate, compounding the resident’s feelings of frustration and being unsupported.
In its stage 2 complaint response of 23 December 2022 the landlord confirmed it would not pay her storage costs because it deemed the property to be habitable. However, as set out above, there is no evidence that the landlord took the presence of wastewater into account when it deemed the property to be habitable.
The landlord wrote to all resident’s affected by the flood on 21 November 2021. It asked residents to provide evidence of additional costs incurred because of the flood. It said it would be in contact as soon as possible and said the issue was being handled as a “priority.” The evidence shows that the resident supplied evidence of an increase in her electricity bill to the landlord and that in its stage 2 complaint response of 23 December the landlord offered £250 compensation to cover the resident’s electricity bill. The landlord apologised for the delay in making the payment, the amount of which was not disputed by the resident.
On 29 June 2021 the landlord appropriately raised orders to test and inspect the electrics in the property and to supply dehumidifiers and an aquavac.
An internal email dated 6 July 2021 confirmed that property inspections had taken place on 28 June, 1 and 5 July. Despite making a request to the landlord, this investigation has not been provided with copies of any reports following the inspections and/or surveys. The email noted that it had chased dates to fit new flooring and skirting boards. It recorded that it had also submitted a request for a new kitchen to the loss adjuster.
However, there is no evidence that the landlord communicated with the resident about its plan for the repairs. This was inappropriate because it meant she did not know what works would be undertaken and in what timescales, creating uncertainty.
On 19 July 2021 the landlord sent an internal email confirming that it had requested a new kitchen through the loss adjuster. It confirmed that the resident had already begun her own works including stripping wallpaper, plastering walls and redecoration. Therefore, there were no decoration works to be put to the loss adjuster. It had already carried out minor works and the kitchen was the only outstanding issue. It noted that this would take up to 3 months to work through.
During a call with the resident on 23 July 2021 the landlord advised that its insurer had declined its request for a new kitchen and that only “minimal flood damage repairs” would take place. On 26 July the resident called the landlord to seek an update regarding new flooring in the kitchen. She was advised that as this was part of its insurance claim the work could take up to 3 months. This timescale was reasonable.
In its stage 1 complaint response of 29 July 2021 the landlord said that it had already completed some ‘soft works’ and that additional works would be completed within 2 weeks. It is unclear whether this included the new flooring in the kitchen.
In an email to the landlord dated 17 August 2021 the resident said she had carried out works herself because she was “fed up” of waiting for the landlord to carry out remedial works. In the period since the flood all it had done was supply dehumidifiers and fit skirting boards. The boards had since been removed because the property was still damp which, she said, was a waste of time and money.
The evidence shows that the landlord did not communicate effectively with the resident from the outset about what repairs it would carry out and the likely timescales. Had it done so the resident would have been confident that issues would be addressed even if the lead times may be longer due to the insurance process. It did not do so, causing the resident to carry out the works herself.
In an internal email of 19 September 2021 the landlord queried why the drying certificate was not issued until 21 September. It is assumed there was an error on the drying certificate given that the email was sent before the date on the certificate.
Furthermore, the landlord’s stage 2 complaint response of 23 December 2022 said that it had had to wait for the insurers drying team to give the go ahead before full reinstatement works could begin. It said the instruction to commence works was given on 6 August with works completed on 22 September. This could not have been possible if the drying certificate were dated 21 September. This is a record keeping failure.
The response provided to the internal query raised in the email of 19 September 2021 advised that the delay was due to the resident carrying out her own plastering and decorating works. An unfortunate consequence of the resident’s decision to carry out works herself was that the landlord could not fully assess the damage to the property. This because some was masked by the redecoration.
The property had not had enough time to dry out and damp eventually began to show. This delayed the period before the property could be signed off as dry and meant certain works had to be redone. However, the landlord was mitigated to some extent by the resident’s decision to undertake works herself.
The landlord’s file note dated 25 August 2021 shows that the property was part of its domestic asbestos program and was “subject to survey.” In a call to this Service on 12 August 2024 the resident said the flooring was damaged and the asbestos exposed following the floor. However, in an internal email dated 19 September the landlord confirmed that the floor was in a safe condition but needed to be renewed following the flood and that these works would disturb the asbestos. In any case, it is unclear why the issue of flooring, and the related asbestos issue, was not identified earlier in the process. Had it done so it would have carried out the survey sooner and replaced the floors at an earlier date.
In her email to the landlord of 21 September 2021 the resident confirmed she had not moved into the property because works were taking place to remove the floors and relay them with concrete. Electricians were there the whole week to rewire the property, the kitchen floor and replacement of the skirting boards remained outstanding. She was concerned about the lack of communication from the landlord because she was being told different things by different people and people did not call her back. She described the situation as “stressful.” There is no evidence that the landlord provided a response which was inappropriate.
In its stage 2 complaint response of 23 December 2022 the landlord explained that the insurance process was a lengthy one. The general observations it made about timescales were not unreasonable. However, due to its failures it apologised for the overall length of time taken to reinstate the property and upheld the complaint.
It offered the resident £90 for the delays taken to carry out works after the environmental clean. It is unclear why the offer of compensation only dated back to the environmental clean which it failed to carry out within a reasonable timescale. If the landlord was unable to complete works prior to that date because of the condition of the property, its assessment of compensation should have dated back to the date of the flood.
The landlord’s internal file note dated 1 June 2022 noted that the resident was “consistently chasing an update on the repairs to her property and the environmental clean (…).” In its stage 1 complaint response of 29 July 2021 the landlord apologised if its communication had not been “consistent.” It provided the details of a point of contact that the resident should use going forward. While this was a positive step this came late in the process and would have been appropriate in the immediate aftermath of the flood when the resident felt most vulnerable.
The landlord’s stage 2 complaint response of 23 December 2022 upheld the resident’s complaint about its communication, acknowledging that it did not meet its expectations.
The failures identified in this report include the following:
1. The landlord failed to regard to its duty under the Equality Act 2010.
2. The delay in carrying out the environmental clean was unreasonable.
3. It failed to provide a consistent position on whether the property was habitable prior to the clean.
4. It failed to respond to the resident’s request for a decant and failed to provide a consistent explanation of its decision not to grant one.
5. In failed to consider her eligibility for disturbance payments beyond the request for a rent refund.
6. It failed to demonstrate and a genuine understanding of the distress and inconvenience caused to the resident when considering how it could put things right.
7. The resident was caused inconvenience, time and trouble in chasing the clean and updates about repairs.
8. There were delays in considering the presence of asbestos in the property given the need to replace the floors.
In addition to the above, there is evidence of poor record keeping. For example, the landlord has not provided copies of any of the surveys or inspections carried out and has not provided detailed file notes of its telephone conversations with the resident.
In conducting its investigations, the Ombudsman relies on ‘live’ documentary evidence from the time of the complaint to ascertain what events took place and reach conclusions on whether the landlord’s actions were reasonable in all the circumstances of the case. It is vital that landlords keep clear, accurate and easily accessible records to provide an audit trail. If we investigate a complaint, we will ask for the landlord’s records. If there is disputed evidence and no audit trail, we may not be able to conclude that an action took place or that the landlord followed its own policies and procedures.
This failure is due in part to the landlord’s failure to provide a robust and coordinated response to the incident. For example, there is no evidence that it formed a ‘working party’ to monitor the progress of works, allocate tasks to specific individuals and manage communications. The landlord has not provided a copy of its procedure setting out its response to major incidents within its stock. This has been reflected in the orders below.
Considering the above, the landlord’s failures amount to severe maladministration because there were serious failings by the landlord which had a seriously detrimental impact on the resident.
The landlord offered £500 compensation, including £90 for the delay in carrying out the environmental clean. The resident could not live in the property during the period 25 June to 27 July 2021. This amount of compensation is not proportionate to the loss of amenity or distress and inconvenience experienced by the resident because of the landlord’s failures.
During 2021 to 2022 the rent was £129.68 per week. The Ombudsman considers it appropriate to require the landlord to provide financial redress which recognises the loss of amenity. The period considered for this calculation is 25 June to 27 July 2021 which is 4 weeks and 4 days (rounded up to 5 weeks).
In the circumstances the Ombudsman considers it reasonable to require the landlord to pay the resident £648.40 compensation. While the Ombudsman acknowledges that this is not a precise calculation, this is considered to a be a fair and reasonable amount of compensation taking all the circumstances into account.
The amount of compensation offered by the landlord is not proportionate to the detriment caused to the resident by the failings identified by this investigation. The landlord has been ordered to pay the resident £1500. The landlord may deduct the £500 it has offered if this has already been paid.

Complaint handling

The resident made her stage 1 complaint on 4 July 2021. The landlord issued its complaint response on 29 July. This was 18 working days later and 8 days over time. The landlord failed to acknowledge the delay in its response which was inappropriate.
The resident made a further complaint on 17 August 2021. The landlord provided its complaint response on 23 December 2022, over a year later and well outside of its response time.
The Ombudsman’s Complaint Handling Code (the Code) says that complaint responses must not be delayed by more than 10 days without good reason. Where it is necessary to extend beyond 10 days this should be agreed by both parties. In either case the landlord should provide an explanation to the resident containing a clear timeframe for when the response will be received.
It is acknowledged that the landlord recognised the significance of its failure. It is also recognised that the landlord acted appropriately, given the circumstances, by contacting the resident on 30 June 2022 to clarify her current complaint.
However, there is no explanation as to why it took so long and the delay was unreasonable causing distress and frustration to the resident. There is also no evidence as to why it failed to provide updates to the resident as to when she could expect a response. Given the lengthy delay it was important that the landlord demonstrated it had identified what had gone wrong and what it would do differently. That it did not was a further complaint handling failure.
In its stage 2 complaint response the landlord offered the resident £250 compensation for its complaint handling failures to be split equally between the resident and her mother. The £125 offered to the resident is consistent with the Ombudsman’s remedies guidance where there was no permanent impact. However, this cannot prevent an adverse finding of maladministration because while the landlord identified its failure it did not demonstrate learning.
The Code says that landlords should issue stage 2 complaint responses within 20 working days. The response timescale in the updated complaints policy on the landlord’s website comply with the requirements of the Code. Therefore, an order has not been made in relation to this matter.
In a previous determination (case reference 202217236) we recommended that the landlord review its approach to compensation against the Ombudsman’s remedies policy and guidance. In an email to this Service on 23 May 2023 the landlord advised that the recommendation had been noted and was being implemented. The policy on the website has not been updated therefore an order has been made accordingly.

Determination (decision)

In accordance with paragraph 52 of the Housing Ombudsman’s Scheme there was severe maladministration in the landlord’s response to the resident’s report of a flood.
In accordance with paragraph 52 of the Housing Ombudsman’s Scheme there was maladministration in the landlord’s complaint handling.

Orders

Within 4 weeks of the date of the determination the landlord is ordered to:
1. Pay the resident £2148.40 compensation comprised of:
  1. £648.40 for the loss of amenity between 25 June and 27 July 2021.
  2. £1500 for the distress, inconvenience, time and trouble caused by the landlord’s response to the residents report of a flood. The landlord may deduct the £500 it has offered if this has already been paid.
Arrange for the Chief Executive Officer to apologise to the resident for the failings identified in this report. This should be given verbally or in writing depending on the resident’s preference (if verbally it should also be confirmed in writing). A copy should be provided to the Ombudsman, also within 4 weeks.
Review its response to the resident’s request for disturbance payments, including storage costs. It should write to the resident to set out its position and provide a copy to the Ombudsman, also within 4 weeks.
Within 6 weeks of the date of the determination the landlord is ordered to provide the Ombudsman with a copy of its updated compensation policy.
In accordance with paragraph 54(g) of the Housing Ombudsman Scheme, the landlord is to provide the Ombudsman with a review conducted by a senior manager to ensure:
1. Identification of all other residents who may have been affected by similar issues caused by its response to the flood, but not necessarily engaged with its complaint procedure.
2. It carries out an exploration of why the failings identified by this investigation occurred and what it will do differently. This should include a review of its record keeping in line with the Ombudsman’s spotlight report on knowledge and information management.
3. It responds appropriately to emergency incidents within its housing stock.

The landlord is to confirm compliance with these orders to the Ombudsman within 10 weeks of the date of this report.