Wandle Housing Association Limited (202439761)
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Case ID |
202439761 |
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Decision type |
Investigation |
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Landlord |
Wandle Housing Association Limited |
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Landlord type |
Housing Association |
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Occupancy |
Secure Tenancy |
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Date |
24 December 2025 |
- The resident lives in a ground floor flat in what is understood to be a Victorian conversion. She complained about the landlord’s handling of multiple repairs and the impact of these.
What the complaint is about
- The complaint is about the landlord’s handling of:
- Window repairs.
- Damp and mould repairs.
- Roof, gutter and leaks repairs.
- Repairs for a bath tap, a living room electric socket and a wet room door.
- Kitchen sink waste pipe repairs.
- Wet room repairs.
- Crack repairs.
- The associated complaint.
Our decision (determination)
- There was service failure in the landlord’s handling of window repairs.
- There was reasonable redress in the landlord’s handling of damp and mould repairs.
- There was reasonable redress in the landlord’s handling of roof, gutter and leaks repairs.
- There was reasonable redress in the landlord’s handling of repairs for a bath tap, a living room electric socket and a wet room door.
- There was reasonable redress in the landlord’s handling of kitchen sink waste pipe repairs.
- There was service failure in the landlord’s handling of wet room repairs.
- There was no maladministration in the landlord’s handling of crack repairs.
- There was no maladministration in the landlord’s complaint handling.
We have made orders for the landlord to put things right.
Summary of reasons
Window repairs
- The landlord did not meet its commitments about windows in a reasonably timely way.The compensation awarded will not go far enough to remedy the full extent of the delays, frustration and time and trouble that will have been caused to the resident.
Damp and mould repairs
- The landlord offered reasonable redress to remedy the service issues and impact evident.
Roof, gutter and leaks repairs
- The landlord offered reasonable redress to remedy the service issues and impact evident.
Repairs for a bath tap, a living room electric socket and a wet room door
- The landlord offered reasonable redress to remedy the service issues and impact evident.
Kitchen sink waste pipe repairs
- The landlord offered reasonable redress to remedy the service issues and impact evident.
Wet room repairs
- The landlord did not meet its commitments about the wet room in a reasonably timely way. The compensation awarded will not go far enough to remedy the full extent of the delays, frustration and time and trouble that will have been caused to the resident.
Crack repairs
- The landlord tried to meet commitments to complete the repairs that were originally reported, and which were identified in response to the complaint, in a reasonably timely manner.
The associated complaint
- The landlord responded to the complaint in line with its policy and our Complaint Handling Code.
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.
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Order |
What the landlord must do |
Due date |
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1 |
Compensation order The landlord must pay the resident £990 to recognise the distress and inconvenience caused by the failings identified. This comprises:
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 21 January 2026 |
Recommendations
Our recommendations are not binding, and a landlord may decide not to follow them.
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Our recommendations |
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The landlord is recommended to liaise with the resident to obtain copies of her utility bills and review whether she incurred any additional utility costs for:
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Our investigation
The complaint procedure
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Date |
What happened |
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17 October 2024 |
The resident complained:
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1 November 2024 |
The landlord responded at stage 1:
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21 November 2024 |
The resident escalated her complaint:
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27 December 2024 |
The landlord responded at stage 2 after speaking to the resident:
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7 January 2025 |
The landlord increased its compensation offer to £490 after correspondence from the resident. |
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13 January 2025 |
The landlord detailed works its supervisor had identified, which operatives would attend for in addition to the windows works. |
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Referral to the Ombudsman |
The resident asked us to investigate. She raises dissatisfaction with delays, management and communication in respect to the repairs. She raises concerns with delays resolving some issues, including ones the landlord initially only did superficial repairs for. She raises dissatisfaction with the impact on her mental health and finances. She seeks compensation to recognise these and delays she experienced. |
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.
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Complaint |
Window repairs |
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Finding |
Service failure |
- The resident complained about the windows appearing insecure and causing her significant anxiety. She also raised frustration with the process she experienced. This included her making plans to accommodate windows repairs over 2 days in October 2024, only for the operatives to recommend replacement of the windows, which she had suggested previously.
- The evidence shows that the landlord raised a repair for 4 windows in August 2024, after the resident chased the outcome to a surveyor inspection. The landlord’s records suggest this inspection happened in February 2024. This means the repair was raised 6 months later, which exceeded the 28-day timeframe for routine repairs and the 90-day timeframe for major repairs. This was not reasonable.
- The subsequent August 2024 visit was within the 28-day timeframe for routine repairs, and it was not unreasonable that the operatives decided that more time was required due to the repair’s complexity. The further October 2024 visit exceeded 28 days, but this was within a 90-day timeframe for more major and complex repairs, which was reasonably applicable.
- We understand the resident will have been frustrated that the window repairs were not completed, and that replacement was recommended as she had previously suggested. But it was not unreasonable for the landlord to attempt the repair before deciding this was not possible. It is not evident until the operatives attempted the repair in October 2024 that replacement was recommended.
- The landlord confirmed it would progress a quote to replace the 4 windows, acknowledged issues and the impact on the resident, and awarded £490. This seemed proportionate to service issues and evident impact. There was a lengthy delay in progress after the February 2024 surveyor inspection. The resident went to time and trouble to chase the repair. She likely experienced frustration with a lack of communication and management of her expectations, which the lack of completion of the window repairs likely added to.
- The landlord made an appropriate commitment to progress matters by arranging a quote to replace 4 windows. It then said on 7 February 2025 that a quote of around £20,000 was too high and it would revisit repairing the windows, prior to replacing them under a major works programme in the 2026 to 2027 financial year.
- The resident will have found this disappointing, but this was not unreasonable. The landlord is entitled to consider the cost effectiveness of works, and we do not have the expertise to decide when window replacements should be carried out. Its major works team reviewed the windows and have not considered them to require replacement earlier than scheduled.
- The landlord shows it met commitments to address the windows, as it took action to progress and complete the repairs. It said on 8 April 2025 that the major works team’s contractor would assess if they could repair the windows. It then confirmed on 8 May 2025 that this was possible after the contractor visited on 17 April 2025. On 11 July 2025, the contractor scheduled the window repairs for 1 September 2025, and completed them on 13 November 2025. This delay was due to issues during the works such as glazing breaking and having to be ordered.
- However, the landlord did not meet the commitment in a reasonably timely way. The resident had concerns that the windows looked insecure, and that they affected warmth in winter months, and the landlord recognised repairs were needed. It is therefore not reasonable that, while the windows were old and had complexities, the repairs were completed over a year after the original October 2024 appointments to overhaul the windows, and 11 months after the stage 2 response.
- The compensation awarded will not go far enough to remedy the full extent of the delays, frustration and time and trouble that will have been caused to the resident. We do not make decisions about liability for the impact on mental health, finances and lost wages, as this is for the courts. But a further £250 is reasonable to recognise this, considering the service issues and impact evident.
- This is in line with what our remedies guidance says is applicable where there has been maladministration, and a failure which adversely affected the resident, but no permanent impact. We would have found maladministration had the landlord not gone some way to remedy the complaint.
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Complaint |
Damp and mould repairs |
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Finding |
Reasonable redress |
What we did not investigate
- The landlord completed works in February 2025 that it identified after the resident’s complaint. It did some further works In May and June 2025, to treat mould in the wet room, and remove some rusted metal by the bathroom window and re-plaster and re-paint. We have not considered these as these occurred after the original works the landlord identified and completed. The resident has the option to ask the landlord to raise a new complaint about any additional issues, and to refer it to us for a separate investigation.
What we did investigate
- The resident complained that mould had been left untreated in a bathroom. The evidence shows that the landlord raised a repair in August 2024 to install a new bathroom fan, after she chased the outcome to a surveyor inspection. The landlord’s records say this inspection happened in February 2024. The August 2024 installation of the new bathroom fan was within the 28-day timeframe for routine repairs, but there was a 6-month delay in raising the repair. This was not reasonable.
- The resident then complained in October 2024 that while the bathroom fan had been replaced, mould had been left untreated and was also spreading in bedrooms (which she has linked to rear roof issues). It is unclear these were previously reported or formed part of the fan works. There is a lack of records about the February 2024 surveyor inspection, which is not entirely satisfactory. However, the landlord was reasonable to arrange an inspection for issues that included mould and to confirm this in its stage 1 response, to review current repairs required.
- The landlord’s stage 2 response confirmed the supervisor who inspected would effectively manage identified works, which it went on to detail in follow-up correspondence. It also acknowledged issues and the impact on the resident, and awarded £490.
- This seemed proportionate to service issues and evident impact. The 21 November 2024 supervisor inspection did not happen. The resident went to some time and trouble. She likely experienced frustration with poor communication about the supervisor visit as she was told on the day that this was happening. She also likely experienced distress and inconvenience due to the delay in resolution to the issue.
- The supervisor identified works to mould wash and stain block the wet room ceiling, and mould wash and stain block the ceilings and walls of the bathroom and 2 bedrooms. Operatives attended for works for these on 25 February 2025 at the resident’s request. This was not within the 28-day timeframe for routine repairs, but the previous rescheduled appointment was. This shows that the landlord reasonably met commitments to complete the repairs that were originally identified.
- The resident later reported that some personal belongs were damaged during the mould treatment. The landlord liaised with her to consider this and later paid £169.98 to reimburse her for the damaged belongings. This reasonably resolved this and overall, the landlord offered reasonable redress to remedy the service issues and impact evident, considering its compensation policy and our remedies guidance.
- The resident raised concerns, after the landlord’s stage 2 response, about damp stains running across bedroom ceilings and said that a rear roof above the kitchen and bedrooms needed to be investigated. The landlord subsequently told her that on 8 May 2025 that its major works team were managing the bedroom damp issue. On 13 November 2025, a specialist attended for the crack issue and said there were leaks to the rear and front flat roofs. The landlord says some interim repairs were done on 13 November 2025 and repairs to the roof were being progressed.
- As noted above, these are further issues which the resident has the option to raise a new complaint about and refer to us for a separate investigation.
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Complaint |
Roof, gutter and leaks repairs |
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Finding |
Reasonable redress |
What we did not investigate
- The resident’s original complaint was about repairs to the front roof and gutters that related to a living room leak. The resident has referred to issues that were raised after the original complaint and the landlord’s stage 2 response, such as concerns about a rear roof and their causing damp in bedrooms. As this was not the subject of the complaint that the landlord responded to at stage 2 in December 2024, we have not investigated these. The resident has the option to ask the landlord to raise a new complaint about any additional issues, and to refer it to us for a separate investigation.
What we did investigate
- The resident complained that roof works were outstanding after a contractor visit months prior, and that this affected repairs to reinstate a living room socket and re-paint the living room ceiling. The evidence shows that she contacted the landlord on 5 August 2024 and said she had not heard anything since a March 2024 surveyor inspection. The following day, the landlord raised 2 repairs on 6 August 2024, after speaking to the resident.
- The landlord requested for a leak that was causing water damage to the living room to be traced and remedied, under a repair raised for a shower issue. It also raised a repair to repaint the living room ceiling, noted to be after the surveyor’s inspection. The landlord’s records say this inspection happened in February 2024. This means the ceiling repair was raised 6 months later, which exceeded the 28-day timeframe for routine repairs and the 90-day timeframe for major repairs. This was not reasonable.
- On 7 August 2024, an operative attended for the shower issue, but made no notes about a leak, and an operative then attended on 28 August 2024 for the living room ceiling. They said a roof leak needed to be resolved before the ceiling was painted. They said this was probably due to an issue with lead flashing on the porch at the front of the property, and the landlord later raised a repair for this report on 11 September 2024.
- The resident then complained on 17 October 2024 that the roof repair remained outstanding. The landlord’s 1 November 2024 stage 1 response confirmed the repair had been assigned to a contractor, which then completed roof and gutter repairs on 18 November 2024 and painted the living ceiling on 20 November 2024.
- The resident subsequently raised dissatisfaction that the roof repair was unannounced, said she had to rearrange work commitments at the last minute for the internal decoration works, and raised concern whether repairs were actually done. The landlord’s 27 December 2024 stage 2 response acknowledged issues and the impact on the resident, awarded compensation, and said that someone would review the roof work.
- The landlord updated on 20 January 2025 that a surveyor had checked the contractor report and photos and these showed they were complete. It said that lead flashing which had come away from brickwork was re-bedded and pointed, and guttering was also cleared out. It said this should stop any water running down the back of the lead flashing and into the property. The resident expressed satisfaction with this and said her confusion had been due to staff giving her the impression that the lead and roof had been replaced.
- The above shows that the landlord reasonably met its commitments to complete repairs that were originally identified. It also met commitments to review concerns whether the works were done. Its conclusions about this was reasonable. The report and photos appear to confirm that gutter and lead flashing works were completed in line with what was identified. The contractor’s report said no additional works were required. However, there were some delays and the landlord’s approach was unclear at times.
- The operative attended on 7 August 2024 for issues that included the leak but made no findings about this. This was confusing, although it is noted the 28 August 2024 visit that recommended works was within the 28-day timeframe for routine repairs, which include minor leaks and roof repairs.
- The landlord also did not raise a repair until 2 weeks after this visit. This does not seem reasonable. This seemed to lead to the roof and gutter repair taking 104 days, from 6 August 2024 when the repair was raised, to complete. This exceeded the 28-day timeframe for routine repairs as well as the 90-day timeframe for major works.
- The landlord was therefore right to acknowledge service issues, and its actions and compensation offered reasonable redress to remedy the service issues and impact evident, considering its compensation policy and our remedies guidance.
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Complaint |
Repairs for a bath tap, a living room electric socket and a wet room door |
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Finding |
Reasonable redress |
- The resident complained that works were outstanding for a bath tap, a living room electric socket (isolated due to leaks), and a wet room door.
- The evidence shows that the landlord raised a repair on 6 August 2024. This was for separate works but asked to change a washer on a bath tap if there was time. This was attended the same day and on 7 August 2024, a follow-on repair was raised to renew the bath tap. This was completed on 28 August 2024. This was reasonable as this was within the 28-day timeframe for routine repairs.
- The landlord’s notes for a 12 September 2024 visit requested to check water ingress to an electric socket. The operative reported that a front room socket had been disconnected due to water coming in when it rained. This was reasonable as the landlord seemed to take timely action when it received reports about the socket.
- The resident then complained in October 2024 that the bathroom tap did not function property, the living room electric socket was still isolated, and a wet room door was rotten and smelled. The socket repair was dependent on completion of the roof repair being progressed, and it is not clear reports were made about the wet room door or issues with the bath tap since the works, so the landlord was reasonable to arrange an inspection for these and to confirm this in its stage 1 response.
- The landlord’s stage 2 response confirmed the supervisor who inspected would effectively manage identified works, acknowledged issues and the impact on the resident, and awarded £490. Operatives were initially booked to attend for the works on 22 January 2025, but the resident later requested for the appointment to be rescheduled to 25 February 2025, where the socket and tap works were completed. The wet room door works were subsequently completed on 27 March 2025.
- The landlord shows it met commitments to complete the repairs, but there were some issues and delays. As noted in the assessments for other issues, the 21 November 2024 supervisor inspection did not happen. The resident went to some time and trouble. She likely experienced frustration with poor communication about the supervisor visit as she was told on the day that this was happening. She also likely experienced distress and inconvenience due to delays with the socket and tap repairs, which exceeded the 28-day timeframe for routine repairs, and the wet room door works, which exceeded the 90-day timeframe for major repairs.
- The landlord was therefore right to acknowledge service issues, and its actions and compensation offered reasonable redress to remedy the service issues and impact evident, considering the circumstances, its compensation policy and our remedies guidance.
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Complaint |
Kitchen sink waste pipe repairs |
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Finding |
Reasonable redress |
What we did not investigate
- The resident’s original complaint was about the lack of replacement of the kitchen sink waste pipe. After this was replaced, she raised issues with further blockages and wider concerns about the plumbing and drainage. These were not clearly the subject of the complaint that the landlord responded to at stage 2 in December 2024, so although related, we have not fully investigated these. The resident has the option to ask the landlord to raise a new complaint about later events, and to refer it to us for a separate investigation.
What we did investigate
- The resident complained that a kitchen sink waste pipe had not been replaced despite a surveyor’s instruction.
- The evidence shows that the resident contacted the landlord on 5 August 2024 and said she had not heard anything since a March 2024 surveyor inspection. The following day, a repair was raised, noted to be after the surveyor’s inspection, to unblock the kitchen sink, and an operative unblocked the sink on 7 August 2024. This was overall reasonable in the circumstances, as it responded to the most recent report of a blockage in a timely way.
- The resident then complained in October 2024 that the kitchen sink waste pipe had not been replaced despite a surveyor’s instruction. It is not evident that the kitchen sink waste pipe was identified to be replaced , or that it was part of the repairs instruction, so the landlord was reasonable to arrange an inspection for these and to confirm this in its stage 1 response.
- The landlord’s stage 2 response confirmed the supervisor who inspected would effectively manage identified works, acknowledged issues and the impact on the resident, and awarded £490. Operatives were initially booked to attend for these on 22 January 2025, but the resident later requested for the appointment to be rescheduled to 25 February 2025, where an operative noted they had replaced the kitchen sink waste pipe. This was not within the 28-day timeframe for routine repairs, but the previous rescheduled appointment was.
- The resident subsequently continued to raise concerns about kitchen blockages and the wider drainage, which the landlord has taken action for in March, May, September and October 2025 and now seems to have resolved. We understand this will caused ongoing frustration and distress to her. But for the repairs she originally reported and that were identified in response to her complaint, the landlord shows it reasonably met commitments to complete these.
- However, there were some issues and delays. As noted in the assessments for other issues, the 21 November 2024 supervisor inspection did not happen. The resident went to some time and trouble. She likely experienced frustration with poor communication about the supervisor visit as she was told on the day that this was happening. She also likely experienced distress and inconvenience due to the issue.
- The landlord was therefore right to acknowledge service issues, and its actions and compensation offered reasonable redress to remedy the service issues and impact evident, considering its compensation policy and our remedies guidance.
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Complaint |
Wet room repairs |
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Finding |
Service failure |
What we did not investigate
- The resident’s original complaint related to flooring damage and an issue with the pump not completely removing the water. She reported after the September 2024 works that the wet room pump was turning on more than it should, leading to high electricity costs. These issues were not the subject of the complaint that the landlord responded to at stage 2 in December 2024, so although related, we have not investigated these issues. The resident has the option to ask the landlord to raise a new complaint about any additional issues, and to refer it to us for a separate investigation.
What we did investigate
- The resident complained about damage to the wet room flooring and that the wet room pump did not complete remove the water.
- The evidence shows that the resident reported issues with the wet room on 6 August 2024, and an operative unblocked the wet room on 7 August 2024. The same day, the landlord raised a repair to repair or replace damaged wet room flooring. This was attended on 28 August 2024 and an operative reported that new flooring was needed, which was referred to a contractor.
- This was reasonable, as the visit was within the 28-day timeframe for routine repairs. The landlord’s policy also provides scope for a repair to take longer if it cannot do it at a visit, and it took action to progress the repair.
- The resident then complained in October 2024 that the floor had not been repaired and dampness was spreading to the wall, and on 30 October 2024, the landlord requested a supervisor inspection for issues that included a malfunctioning and leaking pump.
- The landlord’s 1 November 2024 stage 1 response confirmed a supervisor would visit to assess repairs on 21 November 2024. It also said that a contractor would make contact to replace the flooring and this was replaced on 14 November 2024.
- The landlord seems reasonable to arrange an inspection for the issues and to confirm this in its stage 1 response. It was also appropriate to confirm actions for the flooring. The flooring replacement met its commitment in a reasonably timely way, as this was within the 90-day timeframe for major repairs.
- The resident then raised dissatisfaction that the supervisor had not attended, and she raised dissatisfaction that while the flooring works were completed, the pump was still not completely taking away water. The supervisor subsequently attended on 10 December 2024 and identified works to check the pump and renew this if needed, which the landlord’s stage 2 response confirmed the supervisor would effectively manage.
- The operatives completed various other works in visits from 25 February 2025 onwards, but it is not clear that the water not draining in the wet room was properly inspected until 17 April 2025, where a plumber visit was recommended. There were then further visits on 27 May 2025, 25 June 2025 and 30 July 2025.
- The landlord later agreed works recommended at the 30 July 2025 visit to remove and replace the flooring and relocate and box in the pump, which started on 2 September 2025. These were suspended, after the concrete under the floor was found to be wet, and completed on 10 September 2025 after use of a dehumidifier to dry this out. The resident confirmed that water no longer pooled on the floor after these works.
- This shows that the landlord met commitments to complete the repairs that the resident originally reported, and which were identified in response to her complaint, in September 2025. The issue clearly had complexities, but the landlord did not meet the commitment in a reasonably timely way. The September 2025 works were 9 months after the December 2024 supervisor inspection and stage 2 response. They also exceeded the 28-day timeframe for routine repairs and the 90-day timeframe for major repairs.
- The property has 2 bathrooms and the evidence is not clear that the issue caused a significant impact to the resident or the property. However, the compensation awarded will not go far enough to remedy the full extent of the delays, frustration, time and trouble and disruption that will have been caused to the resident. A further £250 is reasonable to recognise this, considering the service issues and impact evident. This is in line with what our remedies guidance says is applicable where there has been maladministration, and a failure which adversely affected the resident, but no permanent impact. We would have found maladministration had the landlord not gone some way to remedy the complaint.
- It is noted that after the September 2025 works, the resident reported that the pump regularly reactivated after use of the shower, which she was concerned impacted electricity costs. She also raised concerns that there was an undiagnosed drainage issue. The landlord arranged further investigation and it agreed to convert the wet room to a normal shower. These have been scheduled to 24 December 2025 after being initially scheduled for 17 December 2025. As noted above, these are further issues which the resident has the option to raise a new complaint about and refer to us for a separate investigation.
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Complaint |
Crack repairs |
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Finding |
No maladministration |
- The resident complained in October 2024 that there were wall cracks in the bedrooms located in an extension and these were worsening. On 30 October 2024, the landlord requested a supervisor inspection for issues that included bedroom cracks. It is not clear that previous reports were made about cracks, so the landlord was reasonable to arrange an inspection for these and to confirm this in its November 2024 stage 1 response.
- The resident then raised dissatisfaction that the supervisor had not attended, and she said repairs were outstanding for cracks in the bedrooms and kitchen. The supervisor subsequently attended on 10 December 2024 and identified works that included works to repair cracks in 2 bedrooms, which the landlord’s stage 2 response confirmed the supervisor would effectively manage.
- The landlord detailed the works on 13 January 2025. These included works to repair cracks in 2 bedrooms. Operatives were initially booked to attend for these on 22 January 2025, but the resident later requested them to be rescheduled to 25 February 2025, where an operative attended for crack repairs which the resident declined.
- This was not within the 28-day timeframe for routine repairs, but the previous rescheduled appointment was. This shows that the landlord tried to meet commitments to complete the repairs that were originally reported, and which were identified in response to the complaint, in a reasonably timely manner.
- The resident evidently declined works to repair cracks as she was concerned there was subsidence. While we understand these concerns, it is not evident that the December 2024 supervisor identified any subsidence concerns, so the landlord was reasonable to attempt to do the repairs it identified.
- This is supported by later events where both the landlord and a structural expert have both confirmed that cracks were due to expected movement between the property and an extension, not any structural issues.
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Complaint |
The handling of the complaint |
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Finding |
No maladministration |
- The landlord has a 2- stage complaint process. It aims to acknowledge complaints within 5 working days. It then aims to provide a formal response at stage 1 within 10 working days, and at stage 2 within 20 working days. The landlord provided acknowledgements and formal response at both stages within the timescales set out in its policy and our Complaint Handling Code.
Learning
Communication and Knowledge information management (record keeping)
- There were issues with communication, such as when a supervisor did not attend on 21 November 2024 as promised.
- The resident also appeared to be made promises at visits that were not reflected in subsequent reports, and the landlord’s records were unclear at points. This includes the February 2024 surveyor inspection, and the investigation of the roof, gutters and leaks.
- The landlord could reflect on how to ensure that it communicates effectively and that its records and reports accurately reflect visit outcomes and recommendations.
Complaint handling
- The resident continued to contact the landlord about issues during and after her complaint, some of which raised new issues or happened after initial commitments were met. The landlord’s responses lacked detail about all the issues and its review of previous service was not as detailed as it may have been for roof issues. It could reflect on how it could be more detailed in its responses and draw clearer distinctions between complaint issues and new issues.