Complaints Policy

1.1 The purpose of the Complaints Policy is to ensure that Riverside Scotland can resolve customer dissatisfaction as close as possible to the point of service delivery but, if this is not possible, to ensure that staff and customers are clear on the standard of service that should be provided, including timescales for resolution.

1.2 This Policy is in line with the Housing (Scotland) Act 2001, General Data Protection Act 2018, Equality Act 2010, and guidance outlined by the Scottish Public Services Ombudsman (SPSO), and Scottish Housing Regulator.

2.1 This policy is owned by the Managing Director and the Riverside Scotland Senior Management Team, and reflects the wider Riverside Group Complaints Policy.  It is subject to approval via the Riverside Scotland Board.

2.2 The Complaints Policy can be utilised by all our customers where they wish to express dissatisfaction.

2.3 Matters concerning customer dissatisfaction received via Members of Parliament, councillors or directly from customers through the Managing Director will also be treated as complaints under this Policy.

In the following circumstances, we will not consider a reported issue under our Complaints Policy and the associated Procedure:

3.1 Complaints should generally be received within six months of the event concerned to ensure that we are able to conduct a thorough investigation.  We will always accept complaints beyond this where there is a good reason to do so, for example the complaint was not recorded when it should have been, or because it relates to ongoing issues.  We will also seek to resolve issues for customers in other situations when a complaint is made beyond six months of the event occurring but, as a result of the passage of time, a detailed investigation may not be possible.  Where the problem is a recurring issue, we will however consider older reports as background to the complaint if this will help to resolve the issue for the customer.

3.2 Anonymous reports will be considered by Riverside Scotland as useful customer feedback information but, as our aim is resolution which cannot always be achieved without dialogue with the complainant, we will not be able to address anonymous complaints under this Policy and the associated Procedure.

3.3 Any serious allegations of inappropriate conduct, including discriminatory behaviour in relation to a protected characteristic by a member of staff will be investigated under The Riverside Scotland Disciplinary Policy.  Due to the nature of this type of investigation, it is unlikely that the Complaints Policy timescales can always be adhered to.  If the complaint does relate to protected characteristics, an Investigating Manager who has the same or similar protected characteristics to the customer raising the complaint will be appointed to carry out the investigation wherever possible.

3.4 Where legal proceedings have started in relation to the same issue being reported, we will not respond to the same issue through our Complaints Handling Procedure.  We will however take steps to ensure that customers are not left without a response for a lengthy period, for example, where a letter before action has been received or issued but no court proceedings are started, or settlement agreement reached.

3.5 Any matters that have already been dealt with in line with our Complaints Policy and an outcome has been provided.

3.6 We understand customers may act out of character in times of trouble or distress, and that there may have been upsetting or distressing circumstances leading up to a complaint.  We do not view behaviour as unacceptable just because someone is forceful or determined, however, the actions of customers who are angry, demanding or persistent may result in unreasonable demands on, or unacceptable behaviour towards Riverside Scotland staff.  Our Unacceptable Behaviour procedure will be used in conjunction with this Complaints Policy to support customers and complaint handlers in such cases.

3.7 In all cases where an Investigating Officer decides not to accept a complaint, a detailed explanation will be provided to the customer setting out the reasons why the matter is not suitable for the complaints process and advising the customer that they have the right to challenge this decision to the Scottish Public services Ombudsman (SPSO).  The SPSO will then, if appropriate, instruct a landlord to take on the complaint.

3.8 Whilst a customer does not have to explicitly use the word ‘complaint’ in order for it to be treated as such, occasionally a customer may be unhappy with actions or services provided but may not wish for a formal investigation or to log a complaint. Where this is the case, the details will still be recorded as part of our Policy and a resolution offered to the customer, which will enable us to quickly respond and to learn from this. If the customer later wishes to log a complaint, then they will be able to do this.

3.9 Petitions will be recorded and acknowledged but will not be dealt with under our Complaints Policy.  Details of petitions will be shared with the Managing Director and Senior Management Team.

3.10 A routine first time request for a service.

3.11 A request for compensation only.

3.12 a concern about the actions or service of a different organisation where we have no involvement in the issue, (except where the other organisation is delivering services on our behalf).

We have adopted the Scottish Public Services Ombudsman (SPSO) Model Complaints Handling Procedures: -

• Promoting the SPSO to customers to ensure that they are aware of the support that is available to them,
• Adopting the SPSO definition of a complaint, which is “an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents”,
• Frontline resolution of complaints within five working days.
• A maximum investigation stage of 20 working days, which provides the organisation’s final decision (however the Association’s aim will be to provide a response to Stage 2 complaints within 10 working days as far as possible).
• Recording of all complaints
• Resolving matters as quickly as possible by being open, accountable and focussed on outcomes,
• Resolving complaints at the first point of contact where possible,
• Ensuring all complaints are addressed and dealt with in accordance with published timescales wherever possible,
• Recording, monitoring and evaluating feedback to improve service delivery, with themes or trends assessed by senior management to identify any systemic issues, serious risks or areas for improvement for appropriate action,
• Seeking to put things right when there has been a service failure,
• Respecting confidentiality of information given where appropriate and act at all times in accordance with our Privacy notice,
• Allowing complaints to be made via an advocate/representative where appropriate,
• Learning from complaints by ensuring that we record any lessons learned after each complaint and then evaluating this feedback on a quarterly basis in order to improve how we deliver our services, and
• Operating a two stage complaints process, as explained further below.

5.1 We operate a service-led approach to complaint handling because our frontline colleagues have the specialist knowledge needed to resolve complaints quickly and effectively. A response may therefore be provided directly to a customer by any staff member of Riverside Scotland, which does include our maintenance and repairs contractors and services.

Stage One

5.2 A complaint may be made verbally to a member of staff (in person or over the telephone), submitted via the website or one of our verified social media accounts, or in writing (letter, email or using our printable feedback form).

5.3 The officer who will deal with the complaint (the Investigating Officer) will aim to contact the complainant by telephone by 5pm on the next working day after receipt of the complaint. We also aim to acknowledge the complaint in writing (either by letter or sending this letter via email) within 2 working days.  In this letter, we will confirm the details of the Investigating Officer and our timescales for resolving the complaint.

5.4 We will aim to respond and put complaints right within 5 working days.  If this is not possible, we will provide an explanation and a date by which this stage one response should be received.  This should not exceed 10 days without good reason.

5.5 We will provide a written response to all complaints, addressing all points raised and providing clear reasons for any decisions, referencing relevant policies, law or good practice where appropriate.

Stage Two

5.6 If a customer remains dissatisfied with the outcome of the complaint at Stage One, then the customer will have the option to ask for it to be escalated to Stage Two either immediately, when they have been advised of the outcome, or at any point within 30 days of closure of the stage one complaint.

5.7 We aim to acknowledge the complaint escalation in writing (either by letter or sending the acknowledgement letter via email) within 2 working days of the request to escalate the complaint being received.  This letter will also advise which senior manager will review the complaint at Stage Two and our timescales for reviewing the complaint.  The review will be conducted by a senior manager who was not involved with the Stage One response.

5.8 We aim to provide a written response at Stage Two within a maximum of 10 working days from receipt of the request to escalate.  In exceptional circumstances only where this is not possible then the senior manager conducting the review will contact the customer in order to agree an extension. In every case a response to a Stage Two complaint will not exceed 20 working days.

Referral to a designated person or the Scottish Public Services Ombudsman

5.9 If a customer has completed both stages of our internal Complaints Procedure and they remain unhappy with the outcome then they can refer the matter to the Scottish Public Services Ombudsman (SPSO).

5.10 Customers can contact the SPSO by calling them on 0800 377 7330, or by using their online form on the website www.spso.org.uk, or by writing to them at Bridgeside House, 99 McDonald Road, Edinburgh, EH7 4NS.

If your complaint is regarding our Housing First for Families Service - this service is registered with the Care Inspectorate and you can also make a complaint to the Care Inspectorate, Compass House, 11 Riverside Drive, Dundee, DD1 4NY. They can also be contacted on 0345 600 9527 or by email concerns@careinspectorate.gov.scot

Disciplinary Policy

Equality, Diversity & Inclusion Policy

People Policy

Complaints Procedure

Financial Redress Procedure

Unacceptable Behaviour Procedure

Warning Marker Procedure

‘Making a comment, compliment or complaint’ customer leaflet

Online ‘Make a complaint’ form

Privacy notice

• Customer Service Advisers and Front-line colleagues
  • Receiving an initial report of dissatisfaction from a customer across any channel and seeking to achieve a resolution for the customer wherever possible during this first contact
  • Where this is not possible, recording the details of the issue as a complaint and allocating it to the relevant business area to investigate and resolve as a complaint
• Complaint Handlers (Investigating Officers at Stage One and Senior Managers at Stage Two)
  • Contacting the customer as soon as possible but within the maximum timescales set out to acknowledge receipt of the complaint and obtain further details where necessary to enable a thorough investigation to be completed
  • Dealing with complaints on their merits, acting independently and having an open mind
  • Taking measures to address any actual or perceived conflict of interest, and keep the complaint confidential as far as possible, only disclosing information only disclosed if necessary to properly investigate the matter.
• Complaint Compliance Team
  • Providing analysis of complaint trends, themes and lessons learned for business leads to inform service development and improvements
  • Checking process and procedure compliance on a monthly basis, and providing guidance to colleagues and managers where needed
  • Provision of an annual report to The Riverside Scotland Board at the end of each financial year, including all SPSO determinations and it's Landlord Performance report, as well as actions taken to improve performance and service delivery
  • Provision of complaints information for inclusion in the Riverside Scotland Annual Landlord Report to Customers.

Scottish Public Services Ombudsman Model Complaint Handling Procedures

8.1 The Scottish Public Services Ombudsman looks at complaints about registered providers of social housing, including housing associations, who are required by law to be members of this scheme.  Riverside Scotland is a member of the scheme and this Policy and the associated procedure comply with the SPSO Model Complaints Handling Procedures. A condition of membership is that all members agree to be bound by the decisions and adjudications of the Scottish Public Services Ombudsman, regardless of whether the member agrees with the outcome or not. The Ombudsman may report a member’s complaint handling failure to any appropriate regulatory agency and/or the board, committee, panel or senior officer of the member along with any related details as the SPSO sees fit. We will respond positively to all Ombudsman enquiries, investigations and recommendations and undertake to comply promptly with any determinations.

Customer experience

8.2 We acknowledge that there are some gaps in our delivery of consistent high quality service that customers trust.  However, our risk appetite for adverse customer experience is reducing and therefore our focus on closing those gaps is increasing. We will be less tolerant of service failure and/or any actions that negatively impact customer satisfaction and trust.  We will only accept changes that have a temporary adverse service impact where there is a clear articulation of the potential impact and an agreed action plan to return to acceptable levels.

8.3 We are aware of increasing customer expectations regarding service levels, which are further encouraged and strengthened by the Scottish Social Housing Charter, and we want to respond positively to those higher expectations.  We are also mindful of the potential for greater visibility of any service failure and the associated reputational risks, partly as a result of greater use of social media (which we are actively promoting both as a service channel and a route to improved engagement).

8.4 We acknowledge that we don’t always get things right first time for customers; whilst doing so will always remain our aim, we will also seek to put things right at the earliest opportunity through our complaints handling process and have a zero tolerance of adverse findings by the SPSO.

8.5 We have a full suite of customer experience KPIs which are scrutinised by our Management team and the Board.

Riverside Scotland is committed to Equality, Diversity & Inclusion. We strive to be fair in our dealings with all people, communities, and organisations, taking into account the diverse nature of their culture and background and actively promoting inclusion. This policy aligns with Riverside Scotland Equality, Diversity and Inclusion Policy and has been subject to an Equality Impact Assessment.

When dealing with a complaint, we will:

• Keep the complainant informed about the complaint at all stages using their preferred method of communication, which includes using an interim address for survivors of domestic abuse or victims of hate crime or harassment.
• Allow complaints to be made via an advocate/representative where appropriate and support customers to access Language Line or our online services, through which customers can use online tools such as Browse Aloud which can make websites more accessible.  Our customers can also use Next Generation text when they call our Customer Service Centre.