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The Institute of Customer Service welcomes the opportunity to respond to the Housing Ombudsman’s consultation on its Complaint Handling Code. 

Social housing is an essential service for many across the country. Oftentimes, many who live in a social rent home do not get a choice of who the provider of that home is, similar to the customers of water companies, the users of many train service routes and other essential services. But social housing is also a public service – making the experience a customer has from their social housing provider central to customers’ well-being and to social cohesion.  

The Institute produces the bi-annual UK Customer Satisfaction Index (UKCSI). The UKCSI, launched in 2008, has become a key part of how organisations assess their performance, including those in the social housing sector. It is a 6-monthly survey (published every January and July) of over 10,000 consumers that are demographically representative of the UK population. Its 52,000 responses cover 13 key sectors of the economy, including housing, with a minimum of 3,500responses per sector and it provides a unique insight into the quality of customer service in the country as a whole. 

Evidence from the UKCSI shows that average customer satisfaction with housing associations is significantly below the UK average of 13 sectors and below the average the Public Services (Local) sector. Given recent high-profile cases regarding the condition of existing housing stock and various interventions from the Housing Ombudsman and from the Department for Levelling Up, Housing and Communities on certain serious cases, it is clear that the social housing sector as a whole needs to re-build trust with its customers; the sector’s customer service will have a significant bearing on the well-being of customers.  

More widely on customers, in the July UKCSI, Institute Chief Executive Jo Causon notes:

“The UKCSI shows evidence of a growing polarisation in financial well-being. 18% of customers feel their financial well-being is poor or very poor, up from 12% a year ago. The number of customers who rate their financial well-being as very good or good has dropped. There is a growing expectation that organisations demonstrate fairness and a social purpose in relationships with all their stakeholders, including customers, employees, suppliers, shareholders and the wider community.” 

As housing providers, this is particularly key to note for the social housing sector as people’s financial well-being comes under pressure, so does their ability to pay rent and bills which will, in turn, affect their overall well-being and also social cohesion. 

Given aforementioned high-profile maladministration cases, and the drop in financial well-being affecting many customers, trust is a key element to focus on between organisations and their customers, particularly in the social housing sector. Despite customers not being able to move housing providers, a focus on building trust in these uncertain economic times must still remain front and centre of both social housing providers’ business plans and how social housing providers communicate with their customers, particularly around responses to complaints.  

Institute research on trust, ‘Who do you Trust?’ noted, “For housing association customers, well-trained staff is the leading source of trust. In addition, several factors appear to be more particularly important to trust in housing associations, including the views of friends and family, treating suppliers fairly, providing a named contact, a balance between respecting privacy and personalised service and people’s comments on social media.” 

The research goes on to state that, “The nature of the relationship between housing associations and their customers has led to a prominent focus on co-creation and direct engagement. Customer committees and forums are a key mechanism for housing associations to engage and involve customers. Ensuring that these forums represent customers’ interests, are well managed, and their outcomes effectively communicated is essential to developing trusted relationships between housing associations and their customers.”  

Our starting position therefore is that for consumers to trust businesses and be satisfied with the services or products being offered by businesses, those businesses must ensure they are focusing on the way in which they serve those consumers and on customer experience with a ‘right first time’ approach – and the social housing sector should be no different. Complaints from customers should, of course, be dealt with in a diligent, responsive and respectful manner, ensuring that customers who complain are communicated with using clear and easy to understand language and using channels that are best for the customer. Social housing providers should also be clear about what the difference between a service request and a complaint is and the Institute agrees that this difference should be set out clearly in easy to find and navigate documents for customers.  

However, the Institute would contend that the Housing Ombudsman’s Complaint Handling Code, whilst useful and clearly needed to ensure that organisations deal with complaints in an aforementioned manner, a focus at social housing providers, as an essential service, should be on ensuring a proactive, positive customer experience, rather than a reactive focus on dealing with complaints when they occur. Whilst complaints will inevitably be raised, a focus on, and understanding of, what proactive, positive customer experience and satisfaction is will in turn build customer trust.  

As such, businesses and organisations must invest in training, development and professionalisation of their customer service staff. However, complaints handling and proactive, positive customer service and associated training, development and professionalisation needs to be part of a wider organisational culture that enables, supports and encourages high levels of customer service standards and service excellence. Our research has shown that satisfaction with complaint handling is influenced by the reaction a customer receives when reporting a problem, timeliness of the response and following up to ensure a problem has been resolved.   

The Institute would also urge that social housing providers are measured on how they engage with their customers, their customers’ satisfaction levels and how they drive down exclusion of vulnerable and/or digitally excluded customers as well.  

On complaints and the complaints process 

It is understood that some complaints from customers will arise due to repairs and other maintenance works. We would therefore urge a focus is put by providers on timely, consistent and easy to understand communications are sent to customers ahead of such works to ensure that customers are kept aware of works ahead of time. Contact details should also be provided by providers to customers of a customer liaison officer or customer service team, should they have any questions or queries about such works.  

The Institute would also recommend feedback is taken by providers from customers following works undertaken in their building to understand customers’ thoughts of the quality of the works undertaken and any steps that customers would suggest to improve communication from providers to those customers. This will help to drive trust and a strong, positive relationship between provider and customer. 

Finally, noting that different customers will have access, and preferences, to different methods of communication, providers should be cognisant of this and provide communications to customers across channels and using language that customers can both understand and access.  

On communicating with customers on complaints submitted 

The COVID-19 pandemic forced many organisations, including social housing providers, to prioritise communications through online channels. However, there is likely to be range of customer needs across those living in socially rented and/or affordable homes and preferences relating to channels used to interact with organisations. These needs may also vary according to the type of issue or complaint. Some customers may more confident and better equipped to use digital channels than others. Organisations should therefore take into account customers’ needs and preferences in designing their channel strategy and their complaints response process. Customers should be able to use channels that are appropriate to their needs and should receive a consistent quality of service whichever channel they use to complain. Registered providers should also give customers clear information about how to make contact and submit complaints through different channels. 

As such, social housing providers should ensure that they are mapping customer preferences for each type of situation rather than a ‘one channel fits all’ approach. Further, such an approach will clearly bring forward the need to staff several customer service channels. Social housing providers should build into their recruitment and business plans the need to ensure that adequate staffing levels for each channels during their opening hours are provided to ensure the best customer service possible. As our breakthrough research ‘A Connected World? Ensuring the right blend of people and technology for customer service’ notes, “Managing customer contacts through digital and voice channels is fundamental to organisations’ deployment of technology because it has a direct impact on customer satisfaction and the expansion of inbound contact channels requires organisations to decide how they resource and prioritise different channels.” 

On self-assessment, reporting and compliance 

The Institute agrees that monitoring performance and service improvements made by social housing providers is key. However, the Institute would urge a monitoring and benchmarking principle is added that encourages social housing providers to build trust with their customers and increase their customers’ satisfaction levels. Such a principle should also put in place the ability of the Housing Ombudsman to monitor the trust and satisfaction levels of customers for their social housing providers, simultaneously benchmarking this against other public services and regulated sectors. The Institute would be happy to discuss how the Housing Ombudsman could utilise the UKCSI and other Institute measurements and research in order for social housing providers to fulfil this new principle.   

On building a culture of service excellence that focuses on proactive, positive customer communications to build trust and reduce the level of complaints from customers 

In order to achieve long term goals, build trust, reduce the volume of complaints and in order to continue serving customers to the best of an organisation’s ability, the culture of a focus on service at an organisation must be consistently reflected not only by front-line customer service staff, but by all employees, particularly senior managers and leaders. However, such cultural changes and an enhanced understanding of customer service can be difficult to manage, track and continually improve on. The Institute’s ServiceMark accreditation provides a framework to develop organisational culture and behaviours that enable and support high levels of customer service standards. ServiceMark accreditation is based on a combination of customer feedback, employee feedback and an independent assessment. ServiceMark gives evidence of an organisation’s commitment to and achievement in customer service. As such, we would maintain that ServiceMark accreditation be undertaken by social housing providers, using customers’ money in order to not only demonstrate commitment to high levels of customer service and a culture that supports and encourages high levels of customer service standards, but also to allow some organisations to improve their customer service standards to the point where they remove and reduce the volume of complaints submitted by customers as far as possible, which, in turn, will build trust.

The Institute of Customer Service

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