Westminster City Council (202121186)

REPORT

COMPLAINT 202121186

Westminster City Council

15 June 2023

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 handling of:
1. Repairs from commencement of the void (empty) period.
2. The resident’s reports of damp and mould in the property and associated repairs.
3. The associated complaint.
This Service has also taken into consideration:
1. The landlord’s regard to the resident’s vulnerabilities.
2. The landlord’s record keeping.

Background and summary of events

Background

The resident lives in a three-bedroom ground floor maisonette with her two children. The flat is owned by the landlord, a local authority. She has a sole secure tenancy that began on 1 June 2020.
The resident moved to the property as the result of a decant. The resident was required to move from their previous home due to an ongoing regeneration project at her previous housing scheme.
The landlord informed this Service that the resident has no recorded vulnerabilities. The landlord’s records show that the resident disclosed to the landlord that she was living with a mental health condition.

Scope of investigation

The resident submitted over the course of 2020-2021 a number of complaints, complaint escalation requests and written expressions of dissatisfaction.
The formal complaint under consideration in this investigation is that submitted January 2021, after the intervention of this Service. The Ombudsman will not review the landlord’s handling of the previous complaints as part of its investigation. While the resident did make efforts to escalate their complaints, the landlord did not exhaust its formal complaints process. The former complaints did not therefore fall into the remit of this Service.
However, it is appropriate that this Service considers the period of investigation for the other components of the complaint as from the void period or tenancy commencement. There is evidence that the resident repeatedly sought to require the landlord to review the matters considered by this investigation. The landlord had ample opportunity to review these matters by its complaints process.
The resident has informed the Ombudsman that the landlord’s handling of matters raised had a negative impact on her health and wellbeing. This Service is unable to look into and make a decision about the cause of, or liability for, any impact on health and wellbeing. This is in accordance with paragraph 42(g) of the Housing Ombudsman Scheme which says the Ombudsman will not investigate complaints which concern matters where the Ombudsman considers it quicker, fairer, more reasonable, or more effective to seek a remedy through the courts, a designated person, other tribunal, or procedure. Determinations about liability for any impact to health would more usually be dealt with as a personal injury claim through the courts. Nonetheless, consideration has been given to the general distress and inconvenience which the situation may have caused the resident.

Summary of events

The resident said that she accepted a decant to the property on condition of the landlord’s promise to refurbish the flat ahead of her move. This Service has been provided with very limited records concerning the void period. There is no record of the contact between the resident and the landlord at viewing or on the subject of decant.
The landlord records show a lock change on 20 December 2019. This appears to be the start of the period that the property was empty, up to 1 June 2020 when the resident moved in.
The landlord’s repair log lists some works undertaken during this period:
1. Gas repairs
2. ‘Void repairs’ and ‘void works. A number are noted cancelled.
3. An upgrade to the boiler and radiators.
4. Flooring and window ‘coverings.
The landlord’s internal emails in March 2020 refer to the resident being given early access to the property. On 11 March 2020, the landlord emailed the resident stating that the property was not finished. The resident responded the same day to advise she had been told it was ready and emailed the landlord photographs of areas of the property including holes to walls, exposed piping and what appears to be damp marks on a wall.
An internal email of 13 March 2020, from the landlord to its contractor records a list of further work completed. The following day a repair is logged as ‘void works; additional works throughout’. The records subsequently list these works as cancelled on 11 August 2020.
The landlord’s records refer to a delay to the decant caused by the pandemic that led to government-imposed restrictions from mid-March 2020. Void repairs are logged on the landlord’s repair records the first two days of the tenancy, including ‘decant void works’ and a deep clean. No date of completion is noted, however an invoice recorded accepted 4 June 2020.
On 11 June 2020, the resident sent an email to the landlord attaching photographs of the property including of holes to plaster and boarding in various locations and around sockets and exposed piping.
On 8 July 2020, the resident wrote to the landlord expressing her formal complaint concerning its handling of the void works. She reported outstanding items and other presenting issues, including damp and mould in the hallway and issues with the toilet drainage.
The landlord replied on 9 July 2020, to advise that it had referred matters for consideration by a surveyor. The resident was informed that essential repairs only were being handled due to the pandemic.
Repairs labelled by the landlord as ‘decant void works; various items’ were logged on 21 July 2020. The job status is described as accepted for invoice on 17 March 2021.
The landlord’s record show that a number of repairs were required to the water and drainage systems at the property in September 2020:
1. Recorded 1 September 2020, cleared the same day.
2. Recorded 2 September 2020, completed 9 September 2020.
3. Reported 10 September 2020, the repair status recorded by the landlord was invoice accepted 9 November 2020.
4. Logged 14 September 2020.
On 14 September 2020, the resident submitted a complaint form to the landlord. She raised issues with repairs to the drainage, functioning of the toilets and outstanding void works.
The landlord in subsequent correspondence made reference to a visit by a surveyor on 28 September 2020. There are no further recorded details.
On 7 October 2020, the resident raised further concerns in writing about the conditions at the property and void works. She reported further toilet blockage. She informed the landlord the issues had caused an adverse impact to her mental health and her day-to-day life.
The landlord’s drains contractor attended the property on the same day and stopped a leak. It advised a blockage was caused by a build-up of paper. The landlord decided it would assess this further given repeat issues.
On 8 October 2020, the landlord logged on its repairing system the need for ‘void repairs’. The job status referred to an invoice accepted May 2021.
On 16 October 2020, the landlord wrote to the resident. It stated that the drainage and toilet issues were repaired within its timeframes. It apologised for potential miscommunication concerning some void works and made assurances of further investigations and works, including a full drains survey.
The resident replied to the same date. She reported a further blockage and ongoing issues with the toilet. She explained that the frequent issues at her home and effort involved raising these were causing her depression.
On 20 October 2020, the landlord logged a job for ‘void repairs. This was noted cancelled 21 December 2020 due to ‘failed accesses. There is no record of the works intended or notice of arrangements to the resident.
On 30 October 2020, the landlord’s contractor completed a drains survey. It found 5 defects including repair to an intruding item to the toilet drain, debris in the line and a broken pipe. The recommended repairs were logged as ‘void repairs. The job status was noted as invoice accepted in March 2021.
The resident’s text messages across November and December 2020 show contact with the landlord chasing outstanding works.
Further blockages to the toilet were reported and cleared on 14 and 23 December 2020. The landlord’s contractor initially advised that the blockage was due to ‘wipes’, however noted a recommendation at the later date for further investigation due to the appearance of a displaced joint or seal.
The resident wrote to the landlord on a separate matter on 31 January 2021. She advised the circumstances at the flat were having a worsening impact on her health. She described herself as ‘at breaking point’ and ‘at risk’. She reminded the landlord the issues with the drainage and toilet blockages were ongoing. She added that cracks and damp to the walls were worsening.
The landlord’s records stated that appointments were booked for inspections on 25 March and 8 April 2021 and cancelled by the resident. This Service has seen no evidence of any prior notice given by the landlord to the resident.
On 15 April 2021, the landlord’s surveyor completed an inspection. Its ‘works specification’ recorded rising damp in the hallway and recommended remedial works to inject a damp proof course and waterproof render. The surveyor also reported the presence of cracks to the lounge and hallway walls and noted providing advice to the resident to fill these in. The surveyor noted an outstanding repair to the toilet pipe.
On 7 May 2021, the landlord’s internal email referred to a call with the resident, describing her as ‘really upset’ when chasing outstanding repairs including to the toilet, cracks, and conditions in the hall.
A further internal email of 10 May 2021, referred to the landlord having spoken to the resident. It is noted that the toilet was being investigated.
The landlord’s repair logs record that a plumber tried to conduct toilet pipe repairs on 1 June 2021, but there was no access. There is no record of any prior contact with the resident of the intended arrangements.
The resident’s complaint and the landlord’s internal emails refer to inspection by a surveyor in July 2021. The landlord’s emails of 7, 8 and 15 July 2021 discussed:
1. Outstanding works following a chaser from the resident for an update.
2. ‘Post void works’ to fencing and a bedroom shelf arranged for 6 August 2021.
3. Ongoing concern reported by the resident of cracks in the property.
On 1 October 2021, the resident sent a text message to the landlord stating she had received no contact regarding damp in the hallway. The resident chased a reply 7 October 2021. There is no evidence of a reply.
In November (date unknown), the resident sent a further text message to the landlord seeking update. On 9 November 2021, the landlord replied with an apology and a promise to seek update. The resident sent chaser messages 26 November 2021 and 6 December 2021. There is no evidence of a reply.
On 24 November 2021, the landlord’s contractor highlighted to the landlord outstanding damp works recommended by surveyor. This appeared to refer to the damp remedial works specified following inspection April 2021.
On 9 December 2021, the resident wrote to the landlord seeking to raise complaint about its handling of repairs. She raised the following issues:
1. The condition of the property on letting and outstanding void works.
2. The landlord’s manner of communication.
3. Its delayed diagnosis and repair to remedy the flooding/ blockages.
4. There was ongoing ‘severe damp’ in the lower floor of the flat.
5. Cracks on the walls and ceilings throughout the property. These cracks were said to be present at viewing and reported immediately on moving. The resident advised she had been told to wait 6 months for the plaster to settle due to replastering completed at void stage.
6. The issues had caused her stress and anxiety.
On 13 December 2021, the landlord wrote to the resident. It apologised for outstanding repair issues and advised having referred this to its surveyor.
On 21 and 22 December 2021 a series of emails took place between the landlord and its contractor in which it was stated that:
1. The landlord’s building surveyor was unable to recall a conversation about damp but commented this ‘doesn’t mean it didn’t happen’.
2. The landlord agreed to complete ‘void works to the door stops and handles.
3. There was an open repair job for the leaking toilet.
4. Damp works were completed at the property during the void period. It was ‘not unusual’ for the area concerned to be ‘damp’.
5. The cracks were minor and naturally occurring. That advice was given in April for a further review in 6 to 9 months.
6. It made contact with the resident on 21 and 22 December 2021.
On 23 December 2021, the landlord sought an update from its contractor regarding a mould wash and attendance by a damp specialist. A ‘wash down’ was chased on 24 December 2021 with appointment on 29 December 2021.
On 13 January 2022, this Service wrote to the landlord. The landlord was advised there was no evidence it had escalated the resident’s complaint in December 2021 and recommended to consider in line with procedure. The resident’s complaint was logged by the landlord on 18 January 2022 as at ‘stage 1’, using part of the summary of complaint provided by this Service.
The landlord undertook further investigation into damp across January:
1. 14 January 2022, the landlord said its damp contractor attended the property and advised the suspected cause was a leak.
2. 20 January 2022, the landlord’s surveyor conducted an inspection. The landlord’s subsequent complaint response advised it found damp proofing works were required to the hallway, living room, toilet, and bathroom. The landlord recorded the resident’s agreement to allow access for void repairs and damp remedial works on 11 February 2022. The resident was advised to be taking time off work for these repairs.
On 31 January 2022, the landlord internally queried why the remedial damp works raised April 2021 were outstanding. It noted that there were 2 outstanding but different lists of recommended damp works. On 3 February 2022 the landlord noted it would complete works in line with the April 2021 specification.
On 14 February 2022 the landlord’s internal emails recorded that:
1. The resident had called the landlord ‘very distressed’, reporting that its damp contractor attended the flat but did no works. The resident raised issue of being left without details of what work would be done and when.
2. The damp contractor had been unable to complete the ordered remedial works because the prior work needed were incomplete e.g., removal of the kitchen units to access wall. The damp contractor recommended a more extensive waterproof render than previously specified due it noting further development and extent of damp areas.
On 21 February 2022, the landlord provided its stage one complaint response to the resident. It found her complaint to be upheld and stated it:
1. Was sorry that she had to raise a complaint to get movement on the outstanding repairs.
2. Recently completed some works on 11 February 2022 by way of toilet repairs, door stoppers and knobs.
3. Acknowledged there was further works outstanding:
  1. Cracks to the ceiling and walls.
  2. Damp proofing in accordance with recommendation from the surveyor’s inspection of 15 April 2021. It advised more extensive remedial works had been identified and were now awaited.
4. Apologised that the damp remedial works did not take place on 14 February 2022, because the scope of work was ‘not accurate’. It acknowledged this was ‘unacceptable’ and caused inconvenience. It provided assurances about works and keeping the resident updated.
5. Offered compensation of £843 to recognise the delay experienced awaiting damp proofing works. The landlord identified 24 May 2021 as the date by works should have been completed in line with a 40 days’ timescale. It also offered sums for distress and inconvenience, time, and trouble and £10 for delay providing its complaint response.
On 22 February 2022, the resident submitted a request for escalation of her complaint to stage two. She made the following submissions:
1. The landlord failed to address her complaint about its handling of the drainage and toilet blockage issues.
2. The landlord did not deal effectively with her reports of issues, forcing her to frequently chase contact causing distress.
3. The landlord delayed unreasonably dealing with her reports of damp and cracks. She raised frustration of being left without the issues resolved despite taking unpaid time off work.
4. The basis of calculation for compensation was disputed. The date cited did not address all issues and the value did not reflect the detriment.
5. The resident provided photographs of the ongoing and former issues, including mould, damp patches and cracks.
On 22 February 2022, the landlord’s internal emails noted dispute as to the type of damp identified at the property and referred to a report by its damp contractor ‘when it was void’. The landlord decided that it would order the remedial damp works recently recommended by its damp contractor. However, on 2 March 2022, the landlord’s emails show further internal discussion about which list of remedial damp works was agreed. It then determined that a damp specialist company would return to inspect.
On 2 March 2022, the landlord’s damp specialist attended the property and conducted a further inspection. An order was raised as ‘urgent’ to source and resolve a leak before repair work could be done to damp affected areas. The resident is noted to have been contacted with an update and apology.
On 14 March 2022, the landlord attended the property. The landlord’s plumber found the pipework to be in working order, but left checking pipes that required disruptive removal of panels and ducting at the resident’s request. The inspection found high moisture readings throughout the hallway at low level and not isolated to the wall described as ‘deteriorating’. A working cause of damp was suggested to be a leak from the mains water supply.
The landlord’s emails of this date noted it was in receipt of differing opinions concerning the type and cause of damp and the remedial work required. Further intrusive inspection was recommended. It noted the resident’s request for further disruption to await the end of Ramadan, May onwards.
On 15 March 2022, the resident wrote to the landlord adding to her complaint. She raised issue with the landlord’s communication of intended inspections and seeking access. She advised of attendances made without prior notice and receiving calling cards warning she had failed to allow access. She detailed text messages received from the landlord’s contractor up to and after the visit 14 March 2022 that did not accord with previously agreed arrangements. She advised its handling had caused her additional stress.
On 17 March 2022, the deadline for the stage two responses was noted within an internal email to have been extended to 28 March 2022.
At the end of March 2022, date unknown, the landlord suggested to the resident attending for the intrusive investigation. The resident reminded the landlord of her previous request of no disruptive works during Ramadan. The resident subsequently agreed for the inspection on 12 April 2022.
On 7 April 2022, the landlord provided its stage two complaint response. It stated to the resident that:
1. It was sorry for its handling of the reported cracks and accepted there had been delay. It apologised that remedial work was outstanding and advised this should have been completed by 5 March 2022. It noted the inspection booked for 12 April 2022.
2. It accepted and apologised that nobody had taken ownership of communication to explain the disruption and changes to recent appointments in March 2022. It advised it would be reviewing effective communications with its contractor.
3. It increased its offer of compensation by £126 to recognise the ongoing delay concerning works to the cracks and damp from 5 March 2022, up to 28 March 2022. It added a further £84 for delay and £42 to recognise time and trouble.

Post-complaint

On 12 April 2022, the landlord completed a further inspection of the property and noted no further progress identifying the cause of damp. It repeated suspicion of a leak that may have ongoing for some years. It listed proposed works.
On 25 April 2022, the resident accepted the compensation offered by the landlord in its stage two complaint response.
On 28 April 2022, the landlord’s internal communications referred to contact with the resident chasing confirmation of planned works. It recorded advising her that cracks at the flat were her responsibility. It also noted her offer to take time off work for works in May and request to avoid the inconvenience of relocation of the water mains because this had not been confirmed as the cause of damp.
The landlord delivered a letter of 29 April 2022 to the resident on 3 May 2022. It set out its plan to carry out works the week of 23 May 2022 to damp in the hallway and to the bath panel It recorded her request not to relocate the incoming water mains and repeated its recent advice that cracks were her responsibility.
On 10 May 2022, the resident requested an update about the intended works.
On 1 June 2022, the landlord’s internal emails refer to it having completed work to the hallway and extending tiling to the kitchen. It advised of outstanding works to be agreed with the resident for access. It noted the resident’s recent expressed dissatisfaction awaiting a written plan of works.
The landlord fixed further dates with the resident on 6 and 11 June 2022 to complete electrical works, refix a radiator and repairs to a door. The carpentry works were noted outstanding because the resident ‘didn’t allow access until gone 9am’. A further appointment was made for 24 June 2022. There is no record of this date.
On 7 July 2022, the landlord’s internal emails record the resident’s request that outstanding further work be completed on a weekend. It noted to advise the resident that she must provide access during the week, otherwise it would not complete repairs. It is unclear if this was actioned. The contractor raised concern that this position was inconsistent with its previous accommodation of her needs.
The landlord’s records referred to work intended to be completed on 9 July 2022 to the drainage and pipe work at the property.
The landlord’s summary to this Service advised it carried out ‘works’ between 17 July and 12 August 2022. The landlord advised this Service that ‘all works’ were completed to the property August 2022.
The resident disputes that the damp and mould issue and cracks have been remedied. By email to this Service of 12 April 2023, the landlord advised it was due to conduct a joint visit to the property by a surveyor and damp and mould specialist and would report further. No update has since been provided.

Assessment and findings

The Ombudsman’s Dispute Resolution Principles are:
1. Be fair.
2. Put things right.
3. Learn from outcomes.

This Service will apply these principles when considering whether any redress is appropriate and proportionate for any maladministration or service failure identified.

The landlord’s obligations

This Service has not been supplied with a copy of the full terms and conditions of the tenancy agreement, only the signed cover pages. The tenancy cover pages cross reference the landlord’s tenants’ handbook. The version provided by weblink to this Service relates to a version post-dating the start of the tenancy.
The 2021 version advised that the landlord is responsible for repair of services and equipment that supply water, drains and sanitary fittings. It set out target times for repairs:
1. Issues posing an immediate health and safety risk: attendance within 2 hours and make safe in 24 hours.
2. Plumbing works, blockages: 3 days.
3. ‘More substantial repairs e.g., joinery, plastering, damp proof courses’: 28 days.
The handbook stated a tenant as responsible for repairing minor cracks found during the course of redecorating. The landlord stated it may pay a decoration allowance if it has competed repairs such as replastering.
Section 11 of the Landlord and Tenant Act 1985 is an implied term of the tenancy agreement requiring the landlord to keep in repair the structure and exterior of property and keep in repair and proper working order the installations for the supply of water, gas, electricity, sanitation, space heating, and heating water.
The landlord must also ensure that its homes meet the Decent Homes Standard. This was updated in 2006 to take account of the Housing Health and Safety Rating System (HHSRS). For a home to be considered ‘decent’, it must be free of ‘serious’ hazards. Hazards arise from faults or deficiencies that could cause harm and include the presence of damp and mould growth, risks presenting from pest entry and sanitation and drainage issues.
It is further implied into the tenancy by the Homes (Fitness for Human Habitation) Act 2018 that a landlord must ensure its dwelling is fit for human habitation at the beginning of, and throughout, the tenancy. The existence of any hazard as defined by the HHSRS is one of the factors that may be considered when assessing fitness.
The landlord is required to have regard to a complainant’s disability in line with its obligations under the Equality Act 2010. Where on notice, it must consider when making decisions and providing a service whether its decision making/ actions could place the person at a particular disadvantage due to their vulnerabilities. The landlord is also required to make reasonable adjustments taking into account a known disability.
In accordance with its complaint’s procedure, the landlord’s response to the resident’s’ complaint at stage one is required within 10 working days of the complaint and the stage two response in 20 working days.
The landlord operates a compensation scheme detailing the factors it should consider when assessing appropriate financial redress if it has identified failings and guideline rates.

The landlord’s handling of repairs from commencement of the void period

There is minimal evidence provided by the landlord of the process undertaken to assess the property during the void stage or the works completed to ensure it met requisite standards. There is no record of relevant conversations with the resident or any record of agreed works. The shortcomings in its records placed limitations on this Service’s ability to make findings about how the landlord handled works to the property while empty.
The resident in correspondence repeatedly referred to failed assurances given about refurbishment of the flat prior to decant. There is evidence consistent with her assertions. For example, the landlord in an email of 11 March 2020, referred to an hour-long conversation with her about the condition of the property. The resident’s repeat expressed understanding is not challenged by the landlord. There is record of her chasing items for work across the first few months of the tenancy, logged by the landlord as ‘void repairs’ and ‘decant void works’. The landlord’s repair records in those first months show completion of certain works that were noted as required when the property was empty. Works labelled ‘void repairs’ are noted completed as late as August 2021, over a year later.
The information considered shows that the landlord made promises to the resident about a number of items for repair or refurbishment prior to letting but failed to complete these items to standard or at all before the resident moved in. Whilst the onset of the pandemic and related contact limitations reasonably would have caused some delay, this cannot account for the period prior to restrictions or the full extent of delay. The delay to completion of void works was unreasonable.
In view of the multiple condition issues presenting at an early stage of the tenancy, it is reasonable that the resident raised concern about the adequacy of any void inspection(s) or works. It is not clear whether any assessment was given at void stage to the proper functioning of the drainage system or any previous known issues. The presence of damp was noted during the void period and unknown works completed. However, subsequent assessment by the landlord later found its remedial work inadequate. The resident was by this stage living with worsening damp conditions that could possibly have been prevented at void stage. The Service has not seen any quality checks or post void works inspections completed to assure the landlord as to the adequacy of works undertaken. This is a failure by the landlord to follow a reasonable process to satisfy itself that the property was let to the required standards.
There is scant evidence of any best practice void actions such as void inspection with an according report/ list of findings and readiness for let/ lettable standard assessment at close of void works and immediately prior to re-let. There is no evidence that potential risks e.g., previous damp were flagged for close monitoring. The landlord failed to provide a void policy or procedure. There is no evidence of the landlord following an internal void checking/ works process e.g., checklists, forms. It is unclear whether the landlord has a void policy/ procedure or lettable standard that it was required to follow to guide its actions.
The landlord should operate an effective process to ensure its property meets the decent home standard and is fit for human habitation prior to letting. There is no evidence that the landlord handled the void process in a competent manner to meet required standards by 1 June 2020. In doing so, it missed a key opportunity to prevent the detriment subsequently suffered by the resident and considered further in this investigation.
It is recognised that the landlord provided an apology in its correspondence in October 2020, for some ‘miscommunication’ concerning one of the items highlighted by the resident as promised but incomplete. While the landlord took steps to remedy its failings, this apology did not go far enough. There is no evidence that it otherwise reviewed its handling of void works to appreciate the delay caused to the resident or the inevitable detriment. This prevented an opportunity to address the detriment to the resident or learn from any identified failings to its approach.
The resident is noted to have reported issues with the functioning of a toilet flush early July 2020 and drainage at the start of September 2020. Frequent reports of drain blockages and issues with draining of the toilet and water systems followed over a prolonged period, being referenced on the landlord’s records up to April 2021, some 9 months later. Its records show little detail on the repairs effected and it is unclear whether effective repair was completed in service timescales.
The records do show that on at least some of the dates when issues were reported, attendances were made, or repairs completed outside of the service timescales in the current tenant’s handbook or a reasonable period. There are no records of the calls made from or to the resident concerning this matter. There is very little evidence of the resident being provided updates to the works being planned or undertaken to resolve the repeat issue. Contact with the resident on these matters appears to have been largely left to the contractor, resulting in onus being placed on the resident to report or chase further contact. This represents a failure by the landlord to pro-actively communicate with the resident or take ownership for resident engagement.
The landlord relied on the opinion of a specialist drainage company to guide its approach to the cause of the issues and remedial work. It was reasonable that the landlord adopted an approach based on a specialist view of the initial identified cause of blockages. Despite this working diagnosis, the landlord is noted to have instructed a full CCTV survey of the drainage system. This assessment was completed within a reasonable period of time.
The report of the drainage contractor found 5 defects impacting the drains. A series of works were recommended and raised by the landlord in October 2020. There is no record of when this work was completed. There is evidence that the contractor’s invoice was accepted in March 2021.
Reports of blockages continued across December 2020. The landlord is noted to have attended within a reasonable timescale to stop the leak. However, it is not apparent that the ongoing cause of the issues was identified or repaired. At the landlord’s attendance on 23 December 2020, the landlord’s repair logs noted a displaced joint or seal requiring further investigation. The landlord’s surveyor referred to ongoing blockages in their summary of its 15 April 2021 inspection. The surveyor raised a further job for toilet works on 19 April 2021.
The resident advised the landlord in her complaint that an effective repair to the drainage issues was completed only after investigation and repair undertaken in Spring 2021. This account is consistent with the landlord’s limited records. This is a significant and unreasonable delay. There is no evidence to suggest that this full delay was reasonable. The landlord failed to conduct a repair within a reasonable period of time, contrary to its repairing obligation.
There is no evidence that the landlord’s unreasonable delay was the result of lack of access. While there is some reference to the resident failing to grant access, there is no record the resident was given requisite prior notice of attendance(s). At or around the same, the resident is observed to be repeatedly chasing the landlord for action and allowing access to the landlord for other attendances.
The landlord unreasonably delayed conducting an effective repair to the water drainage system/s at the property, affecting blockages and the toilet. Only ‘make do’ repairs were completed for many months, leaving the resident to endure the consequence of repeat flooding and unpleasant drainage overflows. The landlord’s response to the resident’s complaint failed to identify its delay or acknowledge its impact on the resident or provide redress.
The resident said that cracks to the plasterwork at the property were apparent on moving in and raised shortly afterwards. The resident said the landlord resolved to review remedial work required once the plasterwork had settled over 6 months.
There is no recorded evidence of contact concerning cracks to the plasterwork until the resident’s correspondence of 31 January 2021. However, this Service is conscious this does not mean earlier conversations did not take place. When mentioning the cracks to the landlord, the resident repeatedly referred to these as void works. In her email of 31 January 2021, the resident advised that cracks had worsened, assuming the landlord’s pre-existing awareness. There is no record produced by the landlord to counter the resident’s assertion that cracks were discussed and raised at an early stage in the tenancy.
The landlord’s summary of an inspection of 15 April 2021, noted that cracks were present to the lounge and hallway walls and the resident advised that filling of the cracks was her obligation. The landlord has produced no record of this conversation, its inspection report or any follow up confirmation advice correspondence to the resident showing its efforts to secure her understanding.
The resident’s subsequent correspondence continued to chase repair to the cracks as ‘void repairs’ May and July 2021. The resent raised the landlord’s handling of repairs to the cracks within her complaint at both stages. The landlord by its first complaint response apologised for its failure to complete work to the cracks and promised to complete remedial work on 11 February 2022. On this date, the work was not completed. Within its stage 2 response, the landlord apologised for its handling of the cracks and accepted delay on its part. It acknowledged delay outstanding since an inspection in January 2022. It offered compensation in conjunction with that offered for its accepted failings re damp and mould, increased to recognise ongoing delay.
Repairs to plasterwork do not necessarily fall within the landlord’s implied repairing obligations. It depends upon the nature of the damage and whether this is to be treated as impacting the structure of the property. The recorded view of the landlord’s surveyor was that the cracks are minor and not affecting the structure. It is reasonable that the landlord would rely on this qualified view. It does not however follow that the resident was therefore responsible for completing the repairs herself. The landlord when reviewing the resident’s complaint, acknowledged it had delayed completing the work, albeit a shorter delay than suggested by its records, and committed to do works.
The landlord’s handling of the cracks was subject to unreasonable delay and its communication led to an inconsistent approach, leaving the resident unclear of what works, if any, the landlord would undertake to remedy the issue. The landlord did acknowledge it delayed unreasonably completing works to cracks when reviewing the complaint and apologised. However, within weeks of completion of the complaint process, it wrote to the resident advising it would no longer carry out the work. This added further to the inconsistencies in its handling and aggravated the detriment incurred by the resident. The Service notes that the repair was outstanding for at least a further 4 months post-complaint.
The compensation offered by the landlord in respect of the cracks was inadequate financial redress. When it addressed the matter in its stage 2 compensation offer, it did not add any additional amount to reflect its former delay on top of that offered for the damp issues, except for its most recent delay.
This Service has found a series of significant failures in the landlord’s handling of repairs from and including the void period in service which had seriously detrimental impact on the resident.
The landlord’s failure to undertake appropriate steps to ensure the property met requisite standards at let or appropriately monitor potential risks left the resident to incur significant time and trouble from the outset of her tenancy and throughout. Outstanding void works and effective repairs to the water drainage issues and cracks were unreasonably delayed for significant periods. Repairs were driven not by the landlord, but by the resident’s frequent chasers. Further, the landlord had little regard to the effect these matters had on a vulnerable resident, despite her expressly citing significant resulting distress.
This landlord’s failings amount to severe maladministration. The landlord’s Chief Executive is ordered to apologise to the resident. The Ombudsman’s remedies guidance suggests financial redress of between £600 to £1,000 where a severe maladministration finding is made but where the impact was significant but not severe and long term. Owing to the length of delay suffered by the resident and evident distress caused, compensation is ordered at the higher end of this band.

The landlord’s handling of repairs reported concerning damp and mould.

The landlord was aware of a history of damp at the property from commencement of the tenancy in June 2020. The resident’s email during the void period forwarded a photo of what presents as a damp patch. The landlord’s records show it completed damp works during the void period to the same principal area of concern, later accepted as inadequate. The resident says that she raised the matter further with the landlord shortly after moving in. The resident further alerted the landlord in an email July 2020 to damp and mould development around a vent in the hallway.
The reappearance of damp should reasonably have indicated to the landlord that prompt action was required to diagnose the further issues and assess the adequacy of its damp proofing. There is no evidence that any action was taken by the landlord until after the resident wrote to the landlord by email of 31 January 2021, advising that damp was worsening. This appears to have triggered the landlord’s inspection by its surveyor on 15 April 2021. However, this did not lead to effective or timely remedial works. As at completion of the complaint process in April 2022, the matter remained under investigation and no remedial works had been completed. The latest update from the landlord of 12 April 2023 suggested damp and mould issues have continued to persist for a further year, despite the assurances in its complaint responses.
The landlord failed to take reasonable steps to undertake repairs for which it was responsible and ensure that the property was fit for habitation within a reasonable period. Its responses were significantly outside of its own publicised target time for repair. There was no mitigation for the delays and failings were significant and extended over a prolonged period of time.
The landlord’s diagnosis of the problem was extremely protracted and its mobilisation to conduct works unreasonably delayed. From review of records, a number of common features present as contributing to significant delay:
1. It is apparent the landlord’s record keeping was inadequate to give a sufficient point of reference of the history of the damp issues, resident’s reports, technical findings/ recommendations, or the current status. This had an impact on effective progression.
2. The landlord’s cross-departmental / contractor emails repeatedly displayed confusion about which technical inspection was current, the status of recommended works and its communication with the resident. The information should reasonably have been readily available from its recording system/s. These exchanges contributed to delay and inconsistency of approach.
3. There was no clear ownership for resolving the issue and internal co-ordination was largely ineffective. The landlord is not shown on the records provided to be driving resolution of the issue with its contractor. The contractor is noted on several occasions to seek approval or clarity of instruction from the landlord for works and this was delayed or unanswered.
4. Internal emails show that the principal driver of progress to discuss works required was the resident’s chasers and investigations triggered by her complaints. There is very little evidence of proactive steps being undertaken by the landlord.
There is suggestion by the landlord that some delay was that of its contractor. There is little evidence this was a principal cause of delay. Nonetheless, the landlord remained responsible to ensure the property was fit for habitation. The landlord should reasonably have ensured it had processes in place to effectively manage the delay of a contractor. There is no evidence of such processes and little record of proactive management.
There were a variety of diagnoses of the root cause of damp. The landlord undertook multiple survey inspections. The April 2021 inspection failed to identify the presence of a leak, later commented by a subsequent surveyor as likely ongoing for some years. The earlier inspections and remedial work undertaken prior to let failed to adequately diagnose the issue. There is no evidence the landlord reviewed arrangements for preferred damp specialists/ its instructed expertise in view of the apparent updated diagnosis.
There was a lack of prioritisation by the landlord to conduct its response in a way that recognised risks presenting at the property. Once placed on notice of further concerns, this should have led to a response taking the matter seriously in line with its repairing obligations and published timescales. However, it failed to respond appropriately and only prioritised actions once the resident had complained. The landlord was also aware that the resident’s 2 children formed part of the household and that she reported her living conditions causing adverse mental health effects. Despite this, the landlord failed to make any adjustments to ensure the assessment of potential risk/s or address any further needs of the resident and her family.
The landlord’s internal communications show arrangements for investigations being planned without any consideration for notice to be given to the resident or her disclosed needs. Contact took place often at the last minute and not at the earliest possible opportunity to ensure a customer-centred approach. Over the period under investigation, there is evidence of only one update letter sent to the resident and this was following her request for written confirmation. There is no evidence that the landlord followed best practice to share full details of recommended works schedules or inspection reports. There are some references on records to calls with the resident, however no evidence of the calls have been produced. The landlord’s communication in its response to the damp and mould was inadequate and failed to show regard for the resident’s ongoing experience at the property. It is apparent that the poor communication added to a deterioration of trust in the landlord and resident relationship.
The impact of the above failings meant the resident and her children lived with spreading damp and mould for a prolonged significant period, first noted June 2020 and evidently ongoing April 2022 at conclusion of the complaint. The landlord’s records by December 2021 referred to the need for a mould wash, suggesting that sufficient, potentially harmful spores had appeared on the walls so as to require this temporary treatment. The resident herself in January 2021 described the damp to the landlord as ‘severe’. It is evident earlier steps could and should have been taken by the landlord to tackle damp at the property.
The resident described feeling that her efforts to secure remedial works by the landlord were like ‘fighting a battle’. On review of the evidence, it is clear she went to repeat and persistent lengths to highlight the potential hazards within her home and to try secure an effective response. She was put to significant time and trouble chasing the landlord over a prolonged period. She placed the landlord on notice repeatedly that her living conditions were leading to adverse mental health impacts. She notified the landlord that she had taken time off work, some unpaid, to accommodate access. She suffered repeat disruption to her home life.
This Service has identified a series of significant service failures above. These amount to severe maladministration, taking in account the impact to the resident. This Service acknowledges the landlord did identify failings within its complaint response and recognised unacceptable delay causing inconvenience. It is appropriate that it provided an apology and offered compensation to the resident. However, while the landlord did identify ineffective internal communications, it did not acknowledge or address the full extent of the failings identified by this investigation. Nor was the compensation proportionate to the extent of its delay and other failings or the impact on the resident. It failed to learn from its mistakes and did not take steps to remedy the issue, with works still left unresolved. While it acknowledged failings, it did not take appropriate steps to address these and put things right.
The landlord offered compensation to the resident to recognise delay and ineffective communication as from its April 2021 inspection, calculated at £500 per annum. This rate is stated in its compensation scheme as for ‘minor’ repairs.
Based on the evidence considered by this Service, the landlord failed to identify the seriousness of its failings or significance of the delay suffered by the resident when assessing redress. Given the expressed detriment to the resident and risks presenting from the ongoing conditions and level of failings, this Service orders financial redress based on a rate of £1000 per annum. This figure is in line with the landlord’s compensation scheme banding for repairs causing ‘significant impact on daily life’ and this Service’s guidance on remedies where severe maladministration has been identified.
The relevant calculation period should begin from July 2020, when early indications of ongoing damp issues at the property were given to the landlord. The pro-rata payment for July 2020- April 2022 to compensate the resident for the landlord’s service failings is therefore £1,750. After subtracting the previously accepted compensation, the amount payable is £1,333.
The landlord made additional payments of £333 for distress and inconvenience and £209 for time and trouble. It is appropriate the landlord considered the impact to the resident and offered redress. However, it failed to fully reflect her individual circumstances and known vulnerabilities on calculation of this award.
The landlord’s compensation guidance recommends a figure of between £500-£2,000 per year to compensate for distress and inconvenience dependent on severity, number of people affected and risk to health and safety. This Service finds that it was reasonable for the landlord to have offered compensation at the higher level of £1,000 for distress and inconvenience due to the stated impact to the resident and her household’s known vulnerabilities. The pro-rata payment for July 2020 to April 2022 is therefore £1,750 and net £1,417 after account is made of the previous paid compensation.
The landlord did not use the relevant period when calculating its financial award to reflect the time and trouble incurred by the resident. The landlord is required to pay compensation for time and trouble at its identified rate of £250 per year from the January 2021 resident correspondence (14 months). The amount is £82.67.

The landlord’s record keeping.

The records provided to this Service by the landlord point to failures in effective record keeping practices.
As part of this investigation, the landlord was requested to provide relevant information that would reasonably be recorded and retained by the landlord. The documentation provided was limited. Although the records demonstrated a series of inspections undertaken by surveyors to assess the damp and mould, not a single survey inspection report was produced. The findings of the surveyors are referenced within internal emails or in brief invoices. These do not provide the level of detail reasonably expected to be recorded and readily accessible when dealing with a repeat problem that carries potential health risks e.g., the areas inspected, full technical findings, photographs taken, any testing for example moisture readings.
It is reasonable to conclude the landlord’s record keeping hindered the timeliness and effectiveness of its response to issues reported by the resident. The landlord’s internal emails show confusion on a number of occasions over the most recent damp inspection and approved works. This should have been clearly recorded and accessible. Instead, the landlord’s internal communications show its apparent difficulty seeking to keep track of its own actions and coordinated response.
There are no logs or records of any of the calls made with the resident, despite reference to the landlord having spoken with her on numerous occasions. References to calls are made only within internal emails. This is not an effective way of the landlord recording resident contact history. Access to such key information should be centrally accessible to ensure a co-ordinated approach to communication.
The landlord advised this Service that it has no record of resident having vulnerabilities, despite it having correspondence from the resident detailing her mental health concerns.
It is reasonable to conclude that its record keeping adversely impacted its communication with the resident and its approach to taking into account her needs. This Service has found patterns of inconsistencies in the approach outlined to the resident, failures to take into account her needs or act in line with previous assurances state to have been given. If the landlord is failing to record key details of what it has discussed with the resident, this inevitably has an impact on the Service provided to the resident.
This Service finds there was maladministration in the landlord’s record keeping. It was unable to demonstrate adequately how it responded to a situation with health and safety implications involving a vulnerable resident. This hindered its response, her complaint, and this investigation. The landlord is ordered to pay compensation to the resident for the resulting distress and inconvenience.

The landlord’s regard to the resident’s vulnerabilities

The resident advised the landlord on numerous occasions in correspondence about the impact to her and her family and the distress caused. The resident on occasion expressed this impact in severe terms when describing the impact to her mental health.
The landlord is required in line with the Equality Act 2010 to give consideration as to whether the resident has a disability as defined by law and consider whether its decision making/ actions could place her at a particular disadvantage as a result. The landlord is also required to make reasonable adjustments taking into account the resident’s disability. Outside of its disability related obligations, it is expected practice that a landlord would take into account any other vulnerability disclosed by a customer to ensure a sensitive and linked-up approach by its record keeping, appropriately tailored communication where appropriate and offers of relevant support.
This Service has seen no evidence that the landlord considered the resident’s vulnerabilities during the course of its contact with her concerning any of the above matters relating to her living conditions or when handling her complaint. There is no record that the landlord acknowledged the mental health concerns she stated were connected to the outstanding repairs by offering her relevant additional support or referral to appropriate safeguarding consideration.
The resident’s vulnerabilities were relevant factors to inform the nature, tone, and communication of the landlord’s handing of the items considered above. It failed to consider whether it could have communicated with the resident in a way that took account of any additional support needs she may have had.
There is evidence in the landlord’s records that the resident was offered ‘other support’ by the landlord mid-January 2021, in response to a matter outside of the scope of this investigation. This sole offer of unspecified support is noted to have occurred a significant period after the resident’s worsening mental health was first raised to the landlord. It is unclear what support was offered. This single offer of support did not go far enough and failed to effectively take into account the resident’s needs to understand what appropriate support may have looked like.
The landlord failed to engage reasonably over the course of a significant period with its awareness of the resident’s mental health concerns. This was a failure by the landlord across the course of this period to have regard to its duties under the Equality Act 2010. It failed to actively engage in a conversation with the resident that would have enabled it to understand her needs and accordingly make relevant reasonable adjustments. This represents additional significant detriment experienced by the resident. Its failure to properly assess and accordingly take appropriate steps aimed at meeting her needs was a missed opportunity for the resident to have engaged in support services. It failed to assess the ongoing risk to her from the ongoing housing condition issues as relevant to the urgency it might place on remedial investigations and works.
The landlord’s lack of consideration of the resident’s vulnerabilities and associated risks constitutes severe maladministration. Compensation is ordered in accordance with this Service’s remedies guidance to reflect the level of failing assessed, the significant period over which it occurred and the unnecessary distress and inconvenience caused to a vulnerable resident.

The landlord’s complaint handling

The landlord’s response of 21 February 2022, to the resident’s complaint at stage one of its complaints process was delayed and outside of the timescale required by its complaints policy. Its stage one response was provided within 24 working days, 14 days outside of the landlord’s required timeframe.
The landlord advised this Service that it sent a holding response to the resident on 1 February advising of delay with an updated timescale of response by 15 February 2022. Despite the requests of this Service, no copy of this relevant complaint correspondence was produced by the landlord.
This Service notes that the landlord did not update the resident of the expected delay until the day that its response was due. From the landlord’s internal communications at the time of its stage one investigation, it was apparent that its response may be required to be delayed. This Service would expect the landlord to have been proactive in keeping the resident updated of progress.
No further update was recorded as provided to the resident by the landlord before or after 15 February 2022, when it became apparent it was no longer able to meet its own extended timescale. This Service’s Complaint Handling Code (‘the Code’) requires a landlord to keep its resident’s regularly updated about progress. The landlord failed to do so.
This Service is unable to consider any reason provided to the resident for the complaint response delay due to the lack of information provided by the landlord. Review of the landlord’s internal communications suggests that there was unreasonable delay in responses from different departments to inform the reply. In all the circumstances, this Service finds that the landlord’s delay to provision of its stage one response was unreasonable and contrary to its own policy.
A similar pattern is repeated in respect of the stage two response. The landlord’s response of 7 April 2022 is provided 12 days past of the 20 working days required by its policy. Again, the landlord advised having sent a holding response with an extended timescale, within two weeks of the resident’s escalation request. No copy has been produced for this Service to consider.
The extended deadline of 5 April 2022 was not met by the landlord. There is no record of any further interim update to the resident of the change to its timescale as required by the Code.
The landlord apologised at stage one for its delayed first response and offered compensation. The delay at stage two was not addressed by its final response.
Whilst the above delays and failings in communication are not at a serious level, these took place involving a known vulnerable resident that the complaint accepted had already incurred unreasonable delays to service provision and unacceptable service. The complaint process was an opportunity for the landlord to begin to restore trust in its communications by keeping her well informed, sticking to promises made and avoiding unreasonable delay. Whilst it provided holding responses, it later failed to stick to promises made or update the resident. It did not acknowledge the detriment caused by its delay at all at stage two. The landlord’s complaint handling failures, in particular its delayed communication and failure to provide progress updates amounted to maladministration.
The apology and compensation of £10 provided by the landlord are inadequate redress for the totality of complaint handling failings identified. This Service orders that the landlord pay the resident compensation to adequately reflect the avoidable inconvenience arising from its complaints handling failings and apologise to the resident for those it previously did not acknowledge.

Determination (decision)

In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was severe maladministration in the landlord’s handling of repairs from commencement of the void period.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was severe maladministration in the landlord’s handling of repairs reported concerning damp and mould.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration in the landlord’s record keeping.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was severe maladministration in the landlord’s regard to the resident’s vulnerabilities.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration in the landlord’s complaint handling.

Reasons

There is no evidence the landlord reasonably carried out an effective process while the property was empty to check it was ready to let to required standards. This left the resident raising issues immediately upon her moving in. The landlord unreasonably delayed in its handling of void works, effective repairs to the water drainage system/s at the property and cracks to the plasterwork at the property. Its approach to the resident on the matter of the cracks was inconsistent. The landlord’s failure to complete repairs within a reasonable period left the resident to suffer distress and inconvenience over a significant length of time, putting her to serious detriment. It did not acknowledge some of these identified failings at all or provide redress adequate to reflect the extent of failings.
Despite the landlord’s awareness of a history of damp at the property, the landlord failed to take prompt and effective action over a significant period to resolve the issue. Its handling was inconsistent and hampered by its own poor record keeping. It was left to the resident to act as the principal driver to progress its remedial works, the landlord’s response being largely reactive. It failed to adequately recognise the risks presenting from the damp conditions to give the matters sufficient urgency. Whilst it undertook multiple inspections, these failed to lead to any actual remedial work within the period of investigation and compounded its own confusion about the appropriate diagnosis. The landlord demonstrated a failure to comply with its legal obligations as to the condition of the property, unreasonable delay, and incompetent handling of a potential health risk over a significant period of time. These failings lead to a vulnerable resident and her children living unnecessarily with spreading damp and mould.
The landlord’s record keeping across all of the condition issues reviewed by this investigation were inadequate. Its poor record keeping adversely impacted its handling of these issues, including its communication with the resident relevant to her needs and the direction of its investigations into condition issues.
The landlord failed over a significant period of time to engage reasonably with the notice provided repeatedly by the resident of her vulnerabilities. It failed to make any reasonable adjustment to its service to the resident or appropriately assess the ongoing risk to her.
The landlord’s complaint responses at stage one and stage two of its internal process were unreasonably delayed. The landlord failed to keep the resident adequately updated of progress.

Orders and recommendations

Orders

Within 4 weeks of the date of this decision, the landlord is ordered to:
1. Arrange for an apology in writing to the resident from its Chief Executive for the failings identified in this report.
2. An appropriate senior representative of the landlord is to offer to meet with the resident, should she confirm her desire to discuss her complaint further, to provide the parties an opportunity to rebuild the landlord-tenant relationship.
3. Pay the resident £5,032.67 compensation. This figure is net of the compensation paid to the resident in April 2022. It is comprised of:
  1. £900 to reflect the distress and inconvenience caused to the resident by the failings identified in the landlord’s handling of repairs from and including the void period on decant.
  2. £2832.67 to address its handling of the damp and mould. This figure takes account of the previously paid compensation and comprises:

(1) £1333.00 for the unreasonable delays completing the repairs and the associated impact on the property and the resident’s use of it.

(2) £1417.00 for the distress and inconvenience caused to the resident taking into account the particular vulnerabilities of which the landlord was aware.

(3) £82.67 for the time and trouble to the resident for repeatedly chasing the landlord for progress, submitting complaints, and being left in circumstances to raise the matter to this Service.

£400 to reflect the distress and inconvenience resulting from the landlord’s poor record keeping.
£700 to recognise the avoidable distress and inconvenience arising from the landlord’s inadequate regard to the resident’s vulnerabilities.
£200 to recognise the distress and inconvenience caused by its failures in complaint handling.

The landlord is also to conduct a review as to whether, on the basis of the findings of this report, further compensation is due for further delays, distress and inconvenience and time and trouble incurred by the resident after 7 April 2022. The landlord’s decision is to be signed off by the senior member of staff carrying out the below ordered review. The landlord is to then to write to the resident and this Service to confirm what its position is and to provide an explanation for this.
Arrange for a qualified surveyor to inspect the property at a time mutually agreed with the resident to assess whether any further works are required. If repairs are identified, a schedule of works with timescales for completion should be agreed.
Carry out a review of the handling of the repairs and the complaint to determine what action the landlord should take to prevent a reoccurrence of the failings identified. The review should include assessment of:
1. Any reasonable adjustments required to take into account the resident’s needs, to be agreed with her and confirmed in writing and appropriately recorded on relevant central systems.
2. Whether it has existing policies and/or procedures that cover the below:

(1) Works during void period.

(2) Lettable standards.

(3) Responding to customer vulnerabilities.

The landlord should provide a copy of the review to the Ombudsman with any proposals within 4 weeks of the date of this report.

Recommendations

It is recommended that the landlord:
1. Consider whether it can action some of the recommendations in this Service’s damp and mould Spotlight report including the development of a damp and mould policy or framework.
2. Assess its internal recording procedures against the recommendations of this Service’s Spotlight report on Knowledge and Information Management.