2.1.1 Registered providers (RPs) must have an accurate record at an individual property level of the condition of their stock, based on a physical assessment of all homes and keep this up to date
Yes
• All CCHA properties are subject to a physical Stock Condition Survey (SCS) on a rolling programme every five years by independent, third party consultants. This is designed to ensure records represent the current real time status of all property components as closely as possible. These surveys include HHSRS assessments tracked and reported.
• Information is held within the OPENHousing (OH) system. Checks are undertaken on data both prior to uploading and subsequently following upload to ensure relevance, accuracy, and correct configuration.
• An annual process is in place to ensure regular reviews of data held in OH, to allow for continual updating of components following replacement.
Further Strengthening:
This is ongoing as we are continuously updating our SCS data – continuous cycle.
Internal Audit, including one of the new SHAPE tool. To be completed by March 2025.
• Annual Asset Management report to July Board which reports position on SCS and impact on 30-year investment requirements.
• The new SHAPE asset performance tool allows an annual refresh of this data and its impact on property NPVs
2.1.2 RPs must use data from across their records on stock condition to inform their provision of good quality, well-maintained and safe homes for tenants including:
a) Compliance with health and safety (H&S) legal requirements
b) Compliant with the Decent Homes Standard
c) Delivery of repairs, maintenance and planning improvements to homes, and
d) allocating homes that are designed or adapted to meet specific needs appropriately.
Yes
• The stock condition data held in OH is reviewed on a regular basis by the Asset Investment Manager and Stock Condition Manager. Audits take into account and follow any significant data input, configuration of the system or changes to component parameters.
• All Safer Buildings property compliance component lifecycles, condition, servicing, testing and inspection are recorded and managed through OH and fire door software, with all fire doors QR tagged. Live BI reporting is used for management, and H&S and Safer Buildings KPIs are agreed and monitored.
• The stock condition data held in OH is based on a snapshot in time, at the most recent point of survey. It is updated to capture changes which are constantly being made through day-
• H&S and Safer Buildings KPIs reported to Board, A&RC and Management. Safer Buildings Policy reviewed Annually in November.
• Damp & Mould (D&M) KPIs added to A&RC H&S KPIs in February 2024.
• Board Champion for H&S Deep Dive in November 2022.
• Annual Safer Buildings Compliance Audit
Do we comply?
Comments and evidence for compliance
to-day emergency component replacements, alongside planned component replacement programmes which equate to thousands of component replacements per annum. OH system records delivery of all repairs to enable trend analysis and inform future works.
• Compliance with the Decent Homes Standard is reported to F&IC at end of Q2,3 & 4 and including ongoing tracking of any Cat 1 or 2 HHSRS Hazards. This ensure there is clear visibility of compliance with Decent Homes and tracks any potential non-decent properties.
• EPC C performance is a Board KPI with specific targets set by our Asset Management Strategy for 80% by 2025 and 100% by 2028 ahead of the 2030 target. Progress is reported quarterly. Intelligent Energy software is also in operation to support investment decisions to meet EPC targets.
• When properties are advertised, they clearly identify any adaptations and applicants’ banding would reflect their specific needs for an appropriately adapted property.
• The allocation of adapted homes is covered within the Tenancy Standard, section 2.1.
Further Strengthening:
Whilst we have multiple systems in place with SHAPE bringing together large amounts of data, being able to cross-referencedata to get a full picture needs to be developed further. Timescale to be agreed by end of 2024/25.
The Government’s consultation on Awaab’s Law is currently ongoing, and this may lead to areas to be strengthened in the future once the law has been enacted.
Mapping of governance reporting
• Decent Homes performance, including potentially non-decent properties and HHSRS hazards, are tracked by F&IC at end of Q2, Q3 and Q4.
• Annual Investment Programme approved by F&IC and performance tracked at end of Q2, Q3 and Q4.
• EPC C reportedto Board on a quarterlybasis. EPC investment works also reported to F&IC at end of Q2, Q3 and Q4.
• Delivery of repairs including spend and budget performance tracked by F&IC at end of Q2, Q3 and Q4 including adaptations and number of planned components completed.
2.2.1 RPs must identify and meet all legal requirements that relate to the H&S of tenants in their homes and communal areas
Yes
• Our Safer Buildings Policy is reviewed annually and approved by Board. This policy clearly sets out that all homes and communal areas are assessed within following legislation and guidance:
o Health and Safety at Work Act 1974
o The Landlord and Tenant Act 1985
o The Housing Act 2004
o Management of Health and Safety at Work Regulations 1999
o Environmental Protection Act 1990
o The Regulatory Reform Fire Safety Order 2005
o Electricity at Work Regulations 1989
o The Gas Safety (Installation and Use) Regulations 1989
o Construction (Design and Management) Regulations 2015
• H&S and Safer Buildings KPIs reported structure agreed with Board to Board, A&RC and Management KPIs. Safer Buildings Policy reviewed Annually in November
• D&M KPIs added to A&RC H&S KPIs in February 2024
• Board Champion for H&S Deep Dive in November 2022
• Annual Safer Buildings Compliance Audit
• Decent Homes performance, including potentially non-decent properties and HHSRS hazards, are tracked by F&IC at end of Q2, Q3 and Q4
Do we comply?
Comments and evidence for compliance
o Control of Substances Hazardous to Health Regulations 2002
o Control of Asbestos Regulations 2012
o Fire Safety Act 2021
o Building Safety Act 2022
o Smoke and Carbon Monoxide Alarm (England) Regulations 2022
o The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER)
Further Strengthening: The Government’s consultation on Awaab’s Law is currently ongoing, and this may lead to areas to be strengthened in the future once the law has been enacted.
Mapping of governance reporting
2.2.2 RPs must ensure that all required actions arising from legally required H&S assessments are carried out within appropriate timescales.
Yes
• Requirements arising from Safer Buildings property compliance assessments are all completed in line with the prescribed timelines within each individual area. These are documented within the CCHA Safer Buildings Policy.
• There is an extensive suite of H&S and Safer Buildings KPIs reported to Board A&RC and Management as appropriate to risk level including new D&M KPIs. All property compliance is managed through our IT systems and live reporting from Power BI dashboards provide effective and timely data insights.
• All reports of D&M subject to a Risk Assessment to ensure an appropriate response
• H&S and Safer Buildings KPIs reported to Board, A&RC and Management KPIs. Safer Buildings Policy reviewed Annually in November
• D&M KPIs added to A&RC H&S KPIs in February 2024
• Board Champion for H&S Deep Dive in November 2022
• Annual Safer Buildings Compliance Audit
• Decent Homes performance, including potentially non-decent properties and HHSRS hazards, are tracked by F&IC at end of Q2, Q3 and Q4
2.2.3 RPs must ensure that the safety of tenants is considered in the design and delivery of landlord services and take reasonable steps to mitigate any identified risks to tenants.
Yes
• There are safeguarding and ASB, and Domestic Violence policies with risk assessments to support the safety of tenants. Additionally, staff receive appropriate training and CCHA work in partnership to support the safe delivery of landlord services.
• Risk assessments are also undertaken before the commencement of major works. In the design/development of houses a third party all reviews all submissions against all appropriate H&S and Building legislation
• H&S and Resident Impact is a section on the cover report for every Board report, which demonstrates consideration of our commitment to designing services that take resident’s H&S into consideration.
• Safeguarding Policy approved by Board Annually
• Safeguarding practices reported quarterly to A&RC
comply?
Comments and evidence for compliance
2.3 Repairs, maintenance and planned improvements
2.3.1 RPs must enable repairs and maintenance issues to be reported easily.
Yes
• All CCHA tenants are able to report repairs through a range of measures which are published on the CCHA Website and detailed within all tenancy and leasehold handbooks.
Mapping of governance reporting
• Safeguarding audit reported to A&RC
• ASB reported quarterly to A&RC from 2024/25
• ASB audit reported to A&RC
• Satisfaction with repairs is reported in biannual Residents’ Voice Report (RVR) and the Annual Residents’ Report.
2.3.2 RPs must set timescales for the completion of repairs, maintenance and planned improvements, clearly communicate them to tenants and take appropriate steps to deliver to them.
Yes
• CCHA have a set of repair timeframes which are documented in the Reactive Repairs Policy and published as part of CCHA service standards and within tenancy agreements. Systems and processes are in place to deliver and monitor these.
• Delivery of repairs including spend and budget performance tracked by F&IC at end of Q2, Q3 and Q4 including number of repairs completed and timescales and investment programme.
2.3.3 RPs must keep tenants informed about repairs, maintenance and planned improvements to their homes with clear and timely communication.
Yes
• All tenants are informed of proposed timeframes for works at point of reporting. Updates are available through contact with CCHA and delays are communicated with the resident.
• Notification of planned improvements to properties is provided in advance of works commencing, programmes of work are provided along with regular communication on tenant choice.
2.3.4 RPs must understand and fulfil their maintenance responsibilities in respect of communal areas.
Yes • Works to all communal areas follow the same process as works within individual properties.
• There are standards documents for Communal Cleaning and Grounds Maintenance, which are made available to residents.
• Satisfaction with repairs and planned maintenance is reported in biannual RVR and the Annual Residents’ Report.
• Satisfaction with repairs and planned maintenance is reported in biannual RVR and the Annual Residents’ Report
• Resident Scrutiny Panel (RSP) exercise and recommendations on Communal Cleaning and Grounds Maintenance to A&RC.
Do we comply?
Comments and evidence for compliance
Mapping of governance reporting
2.3.5 RPs must ensure that the delivery of repairs, maintenance and planned improvements to homes and communal areas is informed by the needs of tenants and provides value for money, in addition to the requirement at 2.1.2.
Yes
• Tenants are consulted with before all planned works programmes to assess any specialist needs. All repairs both planned and reactive are procured in line with CCHAs financial regulations and are assessed on both cost and quality. Internal contractor (CCS) is subject to annual review reported to Board and over seen by Board working group. All partnerships are subject to an annual review and reported to F&IC.
• During 2023/24, we have carried out a number of workshops with tenants to understand their aspirations and expectations for end-to-end services, including our repairs and maintenance service. The findings of this will be used to inform our IT Board Working Group project.
Further Strengthening: Consideration to the link between the needs of tenants and value for money. During 2024/25.
2.4 Adaptations
• Satisfaction with repairs and planned maintenance is reported in biannual RVR and the Annual Residents’ Report
• RSP exercise and recommendations on Communal Cleaning and Grounds Maintenance to A&RC.
2.4.1 RPs must clearly communicate to tenants and relevant organisations how they will assist tenants seeking housing adaptations services.
2.4.2 RPs must co-operate with tenants, appropriate local authority departments and other relevant organisations so that a housing adaptations service is available to tenants where appropriate
Yes
• CCHA Aids & Adaptations Policy is in place and is subject to regular review. This policy provides the basis for CCHA to develop and implement procedures for considering requests for aids and adaptations from tenants.
• CCHA has an aids and adaptations budget that is reviewed annually and is made available to all requests for adaptations. CCHA seek to combine our funding with Disabled Facilities Grants (DFG) from Local Authorities (LAs) to maximise the number of residents we can support.
Further Strengthening: Increase visibility.
Adaptations reporting to F&IC, to include numbers and budget spend from May 24/25 onwards.
• Number of adaptations completed and budget spend in Planned Maintenance Budget.
• RSP Exercise looking at Aids & Adaptations, including recommendations was reported to A&RC.
Do we comply? Comments and evidence for compliance Governance Reporting Mapping
Transparency, Influence and Accountability Standard - Responsible officer: Housing Services Director
2.1 Diverse Needs
2.1.1 RPs must use relevant information and data to:
a) understand the diverse needs of tenants, including those arising from protected characteristics, language barriers, and additional support needs; and b) assess whether their housing and landlord services deliver fair and equitable outcomes for tenants.
Partial compliance, with strengthening required to fully comply
• Equality, Diversity & Inclusion Strategy (ED&IS) 2022-27, supported by 5-year Delivery Plan (DP), approved by Board in May 2022
• Dedicated senior ED&I Lead, with responsibility for ensuring aims and objectives from ED&IS are being met – Head of Customer Service & Engagement
• ED&I Working Group in place to oversee delivery of the actions within the DP
• Staff ED&I Champions in place across CCHA departments. Specific ED&I Champion training undertaken by specialist external provide
• ED&I Board Champion (BC), with specific role profile
• ED&I Charter and Handbook for staff and contractors, co-developed with RSP
• All staff and Board Members undertake ED&I training on an annual basis
• Equality Impact Assessments undertaken for any new services, and refreshed policies and procedures, to understand any barriers different groups of residents might face in accessing services and how we can remove them
• ED&I internal audit carried out Sept 23, with Substantial Assurance rating
• ED&I culture survey carried out during Q3 2023/24
• Severe Diary Entries & Specific Needs Policy, setting out how specific requirements and needs of residents are captured, recorded and used
• Contact preferences and specific needs of residents captured on housing management systems and used to adapt and deliver services in accordance with individual needs and preferences
• Language Line in place to offer a translating service and ReachDeck accessibility tool in place on CCHA’s website, offering enlarging, read out loud and translating of the website
• RSP carried out exercise to ensure information on CCHA website is accessible, helpful and easy to use/find during 2022
• External accessibility and inclusivity assessment of CCHA’s website carried out by specialist ED&I consultants in 2022/23, with all recommendations adopted
Further Strengthening:
• KPI measuring progress against DP reported to Board quarterly
• Annual report to Board, showing progress against ED&IS
• BC participated in staff ED&I Champion training
• BC provides regular assurance updates to Board
• BC invited to ED&I Working Group meetings, to review progress against the DP
• ED&I internal audit, reported to A&RC
• Results of ED&I culture survey, reported to Board
• RSP review of CCHA website, reported to A&RC.
Additional ED&I session for Board will be arranged for 2024/25
Additional ED&I training for front line staff will be arranged for 2024/25, with a specific focus on adapting services to meet specific needs.
Development of a standalone Vulnerabilities Policy. By end Q2 2024/25.
Business improvement project during 2024/25, to ensure all resident contact preferences, protected characteristics and specific communication requests are captured through an initial census, system upgrades, and cyclical process, to ensure information is stored/used/ kept up to date. By end 2024/25
2.1.2 RPs must ensure that communication with and information for tenants is clear, accessible, relevant, timely and appropriate to the diverse needs of tenants.
Yes
• The RSP independently assess resident communications, to ensure they are clear, accessible, relevant, timely and appropriate to the diverse needs of tenants. Most recently an assessment of communication relating to grounds maintenance and rent & service charge statements has been carried out. In addition, we have established a dedicated inhouse Communications Team, with responsibility for ensuring communications to residents are appropriate, timely and accessible, with a consistent tone and style of messaging.
Further Strengthening: Communications Team carrying out a review of all standard communications to residents across CCHA teams, to ensure consistency of tone of voice, and ensure communications are clear and accessible for residents. By end Q2 2024/25
• RSP review of rent & service charge statements, reported to A&RC.
• RSP review of grounds maintenance, reported to A&RC.
2.1.3 RPs must ensure that landlord services are accessible, and that the accessibility is publicised to tenants. This includes supporting tenants and prospective tenants to use online landlord services if required.
• CCHA’s services can be accessed in a range of ways to meet resident individual needs and preferences, including face to face, telephone, website, email, webchat, web call back and via the residents’ portal. The ways residents can contact CCHA are published in schemes, receptions, on CCHA’s website, social media and published literature.
• Reception areas have dedicated space and equipment to support existing and prospective tenants as required i.e., with online systems such as Choice Based Lettings.
• CCHA’s service commitments are outlined in our Residents’ Charter (RC), which was codeveloped with residents. RSP carried out an exercise to measure CCHA’s compliance against the commitments in the RC.
• RSP Review of RC reported to A&RC and Board
• Digital Service Improvement Strategy approved by Board
• RSP Review of CCHA’s website, reported to A&RC.
2.1.4 RPs must allow tenants and prospective tenants to be supported by a representative or advocate in interactions about landlord services.
Yes
• Residents can request third party advocacy in a way to meet their needs. They can also ask for advocacy for all aspects, specific/ partial aspects i.e. repairs reporting only, or for a oneoff requirement i.e. a local councillor about a complaint. Housing management system has the capability of registering a third-party/advocate, and specific instructions relating to this.
2.2 Engagement with Tenants
• Through the Board Complaint Champion carrying out spot checks, evidence of third-party advocacy will be evident.
2.2.1 RPs must give tenants a wide range of meaningful opportunities to influence and scrutinise their landlord’s strategies, policies and services. This includes in relation to the neighbourhood where applicable.
Yes
• Resident Engagement is a key Strategic Risk (SR1), monitored by Board, with detailed monitoring responsibility delegated to A&RC
• Five-year Customer Service & Engagement Strategy (CS&ES) and Delivery Plan (DP) approved by Board in 2022, setting out our key aims and objectives for resident engagement
• Dedicated Head of Customer Service & Engagement, with responsibility for delivering CS&ES
• Dedicated Customer Experience Team, who support and deliver all resident engagement and feedback activity
• Flexible resident engagement framework in place, to encourage feedback from a range of residents, including:
• RSP, who report findings and recommendations of scrutiny exercises directly to A&RC, recommendations are then tracked to completion.
• Resident service co-design groups, most recently workshops held across CCHA to help co-design digital services
• Resident Feedback Groups, to provide feedback on a specific service
• Ad-hoc surveys, to provide specific feedback on a service affecting a particular group of residents. For example, local playpark surveys
• Residents can provide real-time feedback about the services they receive through satisfaction surveys, these are carried out at the point of residents receiving a service
• Service Satisfaction feedback is collated and analysed by the Customer Experience Team and used to hold quarterly service improvement workshops with managers
• RC, co-designed with residents sets out CCHA’s service commitments.
• Risk & Assurance Map reported to A&RC and Board – Quarterly
• A&RC monitors detailed progress against CS&ES DP biannually
• Progress also reported to Board through quarterly KPI
• RSP report findings of exercises to A&RC and progress against recommendations is tracked at every meeting.
• RSP Chair and Vice Chair meet with A&RC Chair and Board Chair without officers present annually
• Resident engagement activity published to Board and residents biannually through the RVR
• Resident feedback is published to Board and residents biannually through the RVR and quarterly through Board KPIs
• RSP report on scrutiny exercise against RC, reported to A&RC and Board
2.2.2 RPs must assist tenants who wish to implement tenant-led activities to influence and scrutinise their landlord’s strategies, policies and services. This includes in relation to the neighbourhood where applicable
Yes
• The RSP are fully assisted and supported to carry out their role by the Customer Experience Team. If CCHA received requests from any other resident groups to support resident-led activities, we would consider these requests and how we can best support these.
• Engagement opportunities are publicised on CCHA’s website, within the RVR, on social media and by frontline staff.
• RSP report to each A&RC meeting
• Biannual RVR
2.2.3 RPs must provide accessible support that meets the diverse needs of tenants so they can engage with the opportunities in 2.2.1 and 2.2.2
Yes
• CCHA’s resident involvement framework has been developed to allow residents to be involved in a way that meets their personal needs and preferences. For example, RSP meetings are held in person, remotely and hybrid. Meeting venues are selected to ensure they are accessible. RSP members are given support and training and electronic devices to support their work, and communication is in their preferred method of contact. Resident involvement opportunities are open and advertised to all residents.
• RSP report to each A&RC meeting
• Biannual RVR
2.2.4 RPs must support tenants to exercise their Right to Manage, Right to Transfer or otherwise exercise housing management functions, where appropriate.
Yes
• CCHA has not received any requests from residents to exercise their Right to Manage, Right to Transfer or exercise housing management functions. If requests were received, support would be provided by officers, and if necessary, suitable external assistance would be sought to support residents.
• If any requests were made, these be reported to Board.
2.2.5 RPs, working with tenants, must regularly consider ways to improve and tailor their approach to delivering landlord services including tenant engagement. They must implement changes as appropriate to ensure services deliver the intended aims.
Yes • Ways to improve services are captured and implemented in the following ways:
• RSP exercises, recommendations are turned into actions, which are reported to, and tracked by A&RC to completion
• Complaint handling learning
• Satisfaction feedback learning
• Resident Feedback Groups, which capture feedback on a specific service
• Resident co-design workshops, i.e., digital service improvement
• RSP exercises reported to A&RC. Actions tracked at every A&RC meeting.
• Annual self-assessment against Housing Ombudsman Complaint Handling Code (CHC)
• Biannual RVR published to residents and Board
• Resident satisfaction reported to Board quarterly
• Complaints reported to Board quarterly
• Board Complaints Champion, carried out assurance exercises, reporting
Do we comply? Comments and evidence for compliance
Reporting Mapping findings and recommendations to the full Board
2.2.6 Where a registered provider is considering a change in landlord for one or more tenants, or a significant change in management arrangements, it must consult affected tenants on its proposals at a formative stage and take those views into account in reaching a decision. The consultation must:
a) be fair and accessible
b) provide tenants with adequate time, information and opportunities to consider and respond
c) set out actual or potential advantages and disadvantages (including costs) to tenants in the immediate and longer term
d) demonstrate to affected tenants how the consultation responses have been taken into account in reaching a decision.
Yes
• Although CCHA has never implemented a change to landlord or a significant change in management, the approach we would take in these instances can be demonstrated and evidenced through that taken when CCHA was formed in 2017. This included significant resident consultation, in line with requirements a-d.
2.3 Information about Landlord Services
2.3.1 RPs must provide tenants with information about the:
Yes
• If CCHA were considering a change in landlord, or a significant change in management arrangements, this communication and consultation with residents would be overseen by Board
a) available landlord services, how to access those services, and the standards of service tenants can expect
b) standards of safety and quality tenants can expect homes and communal areas to meet
c) rents and service charges that are payable by tenants
d) responsibilities of the registered provider and the tenant for maintaining homes, communal areas, shared spaces and neighbourhoods.
• The information set out within sections a-d is published in a range of ways to residents, including:
• CCHA’s website
• CCHA’s social media
• Within schemes, i.e. Independent Living Schemes
• In reception areas
• Within the RVR
• RC
• Annual Residents’ Report
• Resident Handbook
• Leaseholder Handbook
• Rent & Service charge statements (specifically for c)
• RSP RC exercise, reported to A&RC and Board
• RSP exercise, rent and service charge
• statements
• RSP exercise looking at CCHA’s website, reported to A&RC
• RVR reported to residents and Board biannually
2.3.2: RPs must provide tenants with accessible information about tenants’ rights in respect of RPs’ legal obligations and relevant regulatory requirements that RPs must meet in connection with the homes, facilities or landlord services they provide to tenants. This must include information about:
a) the requirement to provide a home that meets the government’s Decent Homes Standard;
b) the registered provider’s obligation to comply with H&S legislation;
c) the rights conferred on tenants by their tenancy agreements including rights implied by statute and/or common law, in particular
(i) the right to a home that is fit for human habitation; and
(ii) the right to receive notice of a proposed visit to carry out repairs or maintenance or to view the condition and state of repair of the premises; and
d) the rights of disabled tenants to reasonable adjustments.
Partial compliance, with strengthening required to fully comply
• Although the majority of information required at 2.3.2 is featured on CCHA’s website, within the RC, the Tenancy Agreement, Resident Handbook and Leaseholder Handbook, this is an area which needs to be strengthened, to ensure this is explicit and easy to access for residents. This is a new section added since the consultation within the final Consumer Standards.
Further Strengthening: Communications Team to carry out a full review of the requirements set out within Sections 2.3.2 to ensure the information available to residents through our various contact channels and publications is as robust in these areas as it can be and is clear to residents. Working with the RSP to review these. By end Q2 2024/25.
• RSP exercise to review CCHA’s website to A&RC
2.3.3: RPs must communicate with affected tenants on progress, next steps and outcomes when delivering landlord services.
Partial compliance, with strengthening required to fully comply
• Progress, next steps and outcomes are provided to residents for services. Where possible communication is through the resident’s preferred choice which may include email, text, call, WhatsApp or letter and often with a dedicated person of contact (For example, lettings and ASB). Repairs updates are provided to residents, particularly where an amendment to a repairs appointment is required. However, this is an area of focus for CCHA, as we recognise our current systems limit our aspiration to deliver proactive, automated, resident led progress updates. For example, the ability for residents (who wish to access services digitally), to receive automated updates and control their own appointments.
Further Strengthening: Board IT Working Group project will focus on improving end to end processes and systems, to enable proactive resident communication updates. Business Case to March 2024 Board, which will initiate project timeframes.
• RSP exercise to review RC to A&RC
• Board shadowing of frontline teams, for example the Customer Services Team
• Resident Satisfaction and Complaints KPIs are reported to Board quarterly
• Biannual RVR reported to Board
2.3.4 RPs’ housing and neighbourhood policies must be fair, reasonable, accessible and transparent. Where relevant, policies should set out decision-making criteria and appeals processes.
Yes
• All housing policies in place are fair, reasonable, accessible, and transparent. An Equality Impact Assessment is carried out on every policy renewal and update. Key policies are published, and residents can request alternate language/ reading formats to meet their needs. The appeals process is outlined within key housing policies, for example allocations policies
• Housing policies are assessed independently by specialist housing solicitors, to ensure they are fair and meet the required regulatory and legislative requirements
• The RSP have helped to look at some policies, to ensure they are clear and accessible for residents. For example, the Aids & Adaptations Policy
• The RSP carried out an exercise to ensure they could find key housing and policy information on CCHA’s website, and that the information was accessible and relevant/ helpful.
Further Strengthening: Development of a standalone Neighbourhood Management Strategy, which will be published to residents. By end Q2 2024/25.
• Key housing and customer policies are approved by Board in line with the Board Workplan
• RSP scrutiny exercise, Aids & Adaptations, reported to A&RC
• RSP scrutiny exercise, CCHA website, reported to A&RC
2.3.5. RPs must make information available to tenants about the relevant roles and responsibilities of senior level employees or officers, including who has responsibility for compliance with the consumer standards.
Partial compliance, with strengthening required to fully comply
• Roles and responsibilities of senior staff (Exec and non-Exec) are published on CCHA’s website. Having reviewed this, we think their responsibilities could be more detailed.
Further Strengthening: Update the information on the website to ensure the roles and responsibilities are clear. End Q2 2024/25.
• Compliance will be reported in the Consumer Standards Self-Assessment updates to Board.
2.4 Performance Information
2.4.1 RPs must meet the regulator’s requirements in relation to the tenant satisfaction measures (TSMs) set by the regulator as set out in TSMs: Technical requirements and TSMs: Tenant survey requirements.
Yes
• CCHA are fully compliant with the TSMs Technical requirements and TSMs Tenant survey requirements. A report was submitted to Board in January 2023, ahead of the TSMs becoming effective from 1st Apr 2023, outlining the actions we have in place to meet the requirements.
• An annual self-assessment against the TSMs Standard will be submitted to Board in May each year from 2024.
Further Strengthening: Publish TSMs to Board and residents, Q1 2024/25, publish in the RVR, CCHA’s website, social media and in reception areas/ schemes.
• TSMs internal audit will be reported to A&RC May 2024
• Report to Board Jan 2023 – TSMsReadiness Report
• Annual self-assessment against Regulatory Standards, reported to Board
• RVR reported to Board biannually and published to residents
2.4.2 RPs must:
a) collect and process information specified by the regulator relating to their performance against the TSMs. The information must be collected within a timeframe set by the regulator and must meet the regulator’s requirements in TSMs: Technical requirements and TSMs: Tenant survey requirements
Yes
• Internal audit carried out during February 2024, to assess CCHA’s compliance again the TSMs Standard and requirements. Substantial Assurance received, with no recommendations.
• All regulatory requirements in relation to the collation and processing of TSMs are being met by CCHA, this has been supported by the internal audit findings.
Further Strengthening: Publish TSMs data to the RSH, by 30th June 2024.
• TSMs internal audit will be reported to A&RC May 2024
• Regulatory & Statutory Returns compliance reported to A&RC quarterly.
b) annually publish their performance against the TSMs. This should include information about how they have met the regulator’s requirements set out in TSMs: Technical requirements and TSMs: Tenant survey requirements. This information must be published in a manner that is timely, clear, and easily accessed by tenants; and
Yes
• TSMs will be published to residents and Board in line with the requirements set out in Section b, during Q1 2024/25, and annually thereafter.
• Biannual RVR
• Quarterly Resident Satisfaction KPIs to Board
c) annually submit to the regulator information specified by the regulator relating to their performance against those measures. The information must be submitted within a timeframe and in a form determined by the regulator.
Yes
• Data will be submitted to the RSH by 30th June 2024 and annually thereafter, in line with the submission requirements set out by the RSH. A plan is in place to collate, validate and submit the data to the RSH. This Plan was verified by the internal auditor as part of the TSMs internal audit in Feb 2024.
Further Strengthening: Submission of TSMs data to the RSH by 30th June 2024 via NROSH system.
• Regulatory & Statutory Returns compliance reported to A&RC quarterly.
• TSMs Audit reported to A&RC
2.4.3 In meeting 2.4.1 and 2.4.2 above, RPs must ensure that the information is an accurate, reliable, valid, and transparent reflection of their performance against the TSMs
Yes
• All survey data is collected through an independent survey tool, CX Feedback, ensuring complete transparency and accuracy of data. This was tested and verified by the internal auditor. In addition, there is a Plan in place to verify and sign off the data prior to submission to the RSH. The process includes data being verified by Heads of Service and the Housing and Property Services Director. All in both questions and methodology followed are exactly as directed by the regulator.
2.4.4: RPs must provide tenants with information about:
• TSMs Audit reported to A&RC
• Quarterly Resident Satisfaction KPIs to Board
Do we comply? Comments and evidence for compliance
Yes
Governance Reporting Mapping
a) how they are performing in delivering landlord services and what actions they will take to improve performance where required
b) how they have taken tenants’ views into account to improve landlord services, information and communication
c) how income is being spent
d) their directors’ remuneration and management costs.
• Information about how we are performing, the actions we are taking to improve services and how we have taken residents views into account is published within our biannual RVR.
• Information about how income is being spent is published within the Annual Residents’ Report.
• Directors renumeration and management costs will be published in the Annual Report & Financial Statements, available on CCHA’s website
2.5 Complaints
2.5.1 RPs must ensure their approach to handling complaints is simple and accessible and publicised.
Yes
• CCHA’s Complaint Policy and process is fully aligned to the Housing Ombudsman CHC
2.5.2 RPs must provide accessible information to tenants about:
a) how tenants can make a complaint about their registered provider
b) the registered provider’s complaints policy and complaints handling process
Yes
• Regulatory & Statutory Returns compliance reported to A&RC quarterly.
• Biannual RVR reported to Board and residents.
• RSP exercises reported to A&RC
• Annual Report & Financial Statements, reported to Board
• Annual compliance against the CHC selfassessment reported to Board
c) what tenants can do if they are dissatisfied with the outcome of a complaint or how a complaint was handled, and
d) the type of complaints received and how they have learnt from complaints to continuously improve services.
• Dedicated Customer Experience Team, with responsibility for ensuring complaints are tracked and meet the requirements in the CHC
• Complaints Policy and compliance against the CHC are published to residents on CCHA’s website, Annual Report, RVR and Complaints Correspondence
• Dedicated Board Complaints Champion (BCC), with specific role profile, showing our commitment to complaints at all levels of CCHA
• Residents can raise a complaint in a range of ways accordance with their needs and preference, including e-mail, telephone, letter, webchat, social media, via CCHA’s website, in person at one of our offices or schemes, or through a 3rd party/advocate
• Residents are kept updated on the progress of their complaint through their chosen contact medium
• Any updates to the CHC reported to Board, with compliance reported
• BCC carries out assurance exercises, reporting findings and recommendations to Board
• Complaints KPI reported to Board quarterly
• Complaints data reported to Board and residents in the biannual RVR
• Satisfaction with handling of complaints will be reported within TSMs from Q1 2024/25
• The Housing Ombudsman Service is publicised to residents on CCHA’s website, within the RVR and within all complaint correspondence. Residents are informed of their right to escalate a complaint throughout the complaints process
• Data and learning from complaints is shared with residents and Board, in the RVR
Further Strengthening: BCC continues to review complaint handling practices, reporting findings and recommendations to Board.
2.6 Self-referral
2.6.1 RPs must communicate in a timely manner with the regulator on all material issues that relate to non-compliance or potential non-compliance with the consumer standards.
Yes
• Although there have been no material issues that relate to non-compliance or potential noncompliance with the Consumer Standards, CCHA would ensure that we informed the RSH at the earliest opportunity if we believed there was a material issue.
• CCHA has previously self-referred at an early stage to the RSH in relation to another Standard.
• Any self-referral and remedial actions would be reported to Board
2.1.1 RPs, having taken account of their strategic objectives, the views of tenants and their presence within the areas where they provide social housing, must:
a) identify and communicate to tenants the roles RPs play in promoting social, environmental and economic wellbeing and how they will achieve them; and
b) co-operate with local partnership arrangements and the strategic housing function of local authorities where they are able to assist them in achieving their objectives.
Yes
• CCHA has a Community Fund (CF), with specific outcomes focussed on promoting social, environmental and economic wellbeing. The fund is available to support projects across all CCHA communities and is promoted via CCHA’s website, social media, within schemes and offices and within the biannual RVR.
• CCHA has excellent relationships with key strategic local partnerships. We deliver a range of joint community initiatives which meet the objectives of CCHA and partner agencies. Examples include: Local Lettings Policy to tackle serious crime in a particular area, community ASB events, clean up events and supporting local food banks.
• Outcomes of CF reported quarterly to Board.
• CF reported within biannual RVR to Board and residents
• Strategic partnership working with LAs and other partner agencies promoted in biannual RVR
comply?
2.2 Anti-social behaviour and hate incidents
2.2.1 RPs must have a policy on how they work with relevant organisations to deter and tackle ASB in the neighbourhoods where they provide social housing.
Yes • CCHA has a robust ASB Policy, which is updated every 3 years in line with regulatory requirements, legislation and best practice. A full legal review is also undertaken when the policy is updated, by a senior housing solicitor.
• ASB KPI reported to A&RC from 2024/25
• ASB internal audit reported to A&RC
2.2.2. RPs must clearly set out their approach for how they tackle and deter hate incidents in neighbourhoods where they provide social housing.
Yes • Hate crime is included within the ASB Policy. CCHA are active members of Community Safety Partnerships and MASH in our areas of operation to ensure effective multi-agency working.
2.2.3: RPs must enable ASB to be reported easily and keep tenants informed about the progress of their case.
Yes
• Each case is assigned to a named officer and regular updates are a core part of case management. This is carried out by a combination of email, telephone, visits and WhatsApp in relation to residents’ preference.
• ASB internal audit reported to A&RC
• ASB internal audit reported to A&RC
2.2.4 RPs must provide prompt and appropriate action in response to ASB and hate incidents, having regard to the full range of tools and legal powers available to them.
Yes
• CCHA has clear timescales within the ASB Policy for response and has two dedicated ASB Case Managers, as well as an ASB Assistant within the Lettings & Neighbourhoods (L&N) Team. CCHA is a member of Resolve ASB to ensure we remain up to date with and are utilising best practice and the full range of tools and powers available to us from informal letters and mediation through to Section 21, Injunctions and Possession applications in the most serious of cases.
• Satisfaction with handling of ASB complaints will be reported within TSMs from Q1 2024/25
• ASB internal audit reported to A&RC
2.2.5: RPs must support tenants who are affected by ASB and hate incidents, including by signposting them to agencies who can give them appropriate support and assistance.
Yes • Each ASB Case is risk assessed at the point of reporting to ensure signposting and support referrals at the earliest possible stage where required. CCHA also has two Tenancy Sustainment and Safeguarding Partners who are dedicated the most complex cases to ensure effective and sustained support. We are part of local Community Safety Partnerships and MASH within our areas of operation.
2.3 Domestic Abuse
2.3.1 RPs must have a policy for how they recognise and effectively respond to cases of domestic abuse
• ASB internal audit reported to A&RC
Do we comply?
Comments and evidence for compliance
Yes • CCHA has a Safeguarding Policy in place and a specific Safeguarding Residents Against Domestic Abuse Policy. We are working towards Domestic Abuse Housing Alliance (DAHA) Accreditation.
Further Strengthening: Achieve DAHA Accreditation in the next three years.
Governance Reporting
• Safeguarding Policy approved by Board annually
• Safeguarding reported to every A&RC
• Safeguarding audit reported to A&RC
2.3.2 RPs must co-operate with appropriate local authority departments to support the local authority in meeting its duty to develop a strategy and commission services for victims of domestic abuse and their children within safe accommodation.
Yes
• CCHA has strong working relationships within the key LA areas of operation, with trained MARAC representatives / DA Champions as part of the wider Safeguarding Team who attend MARAC and ensure all relevant actions in relation to their accommodation are carried out.
• Domestic abuse cases reported to A&RC quarterly
• Safeguarding audit reported to A&RC
Do we comply?
Comments and evidence for compliance
The Tenancy Standard: Responsible officer – Housing Services Director
2.1 Allocations and lettings
Governance Reporting
2.1.1 RPs must co-operate with local authorities’ strategic housing functions and assist local authorities to fulfil their duties to meet identified local housing need. This includes assistance with local authorities’ homelessness duties, and through meeting obligations in nominations agreements.
Yes
• CCHA has strong working partnerships within our LA areas of operation with nomination agreements and Local Lettings Policies in place. We are also building new relationships in areas of new build development and working closely with the LA on S106 / Nominations agreements
• CCHA is a member of several Choice Based Lettings Partnerships within our areas of operation, the largest being Cumbria CBL. As part of this we will always seek to allocate homes in this way
Further Strengthening: Ensuring LA partnerships are built in new areas of operation including partnership working on Nominations Agreements at an early stage of development (e.g. South Tyneside).
• Allocations Internal Audit findings and recommendations reported to A&RC
• Development Strategy approved by Board
• Development schemes, including needs assessments, reported to F&IC
2.1.2 RPs must seek to allocate homes that are designated, designed, or adapted to meet specific needs in a way that is compatible with the purpose of the housing.
Yes
• CCHA has an Adaptations Policy for residents living within our homes, which was part of a scrutiny exercise carried out by the RSP
• RSP Aids & Adaptations scrutiny exercise reported to A&RC
Do we comply?
Comments and evidence for compliance
• Priority is given to residents on a needs basis, to make the best use of social housing assets, including adapted properties
Governance Reporting
• Aids & Adaptations reported to F&IC from 2024/25
• Allocations Internal Audit findings and recommendations reported to A&RC
2.1.3 RPs must develop and deliver services that seek to address under occupation and overcrowding in their homes. These services should be focused on the needs of tenants.
Yes
• Where under or overcrowding is identified CCHA will seek to address this. Termination reasons are also monitored at the earliest possible stage and mutual exchanges encouraged to address this issue. This is covered within the Lettings Policy and Procedures: Sections: overcrowding / under-occupation.
• Discretionary management moves are permitted where family housing can be made available, by allowing an under-occupying resident to downsize.
2.1.4 RPs must take action to prevent and tackle tenancy fraud.
Yes
• CCHA has robust pre tenancy checks in place, including right to rent and we undertake new resident visits at 1 and 9 months. Any reports of tenancy fraud are investigated and responded to, with the relevant policies/ procedures followed as required
2.1.5 RPs must have a fair, reasonable, simple and accessible appeals process for allocation decisions
Yes
• Allocations Internal Audit findings and recommendations reported to A&RC
• Allocations Internal Audit findings and recommendations reported to A&RC
• The appeals process is clearly set out with specific allocations policies covering each area of operation
• Allocations Internal Audit findings and recommendations reported to A&RC
2.1.6 RPs must record all lettings and sales as required by the Continuous Recording of Lettings (CORE) system.
Yes
• All CORE Returns are submitted in accordance with timeframes and requirements. This is monitored regularly by CCHA’s Head of Housing and Housing Services Director. It is also reported to A&RC.
2.2 Tenancy sustainment and evictions
• Regulatory & Statutory Returns compliance reported to A&RC quarterly
2.2.1 RPs must provide services that support tenants to maintain their tenancy or licence and prevent unnecessary evictions.
Yes
• Dedicated Financial Inclusion Team in place, with referral procedures in place and all frontline teams trained in referral procedures
• Network of third-party partner agencies in place, to refer residents into, should additional support be identified
• Financial Inclusion service promoted on CCHA’s website, social media through rental related mailings and through front-line teams during visits to residents
• Tenancy sustainment case studies published in the biannual RVR
• Rent Arrears Policy approved by F&IC
• Income Report (Including rent arrears and financial inclusion), reported to F&IC biannually
Do we comply?
Comments and evidence for compliance
• Rent Arrears Policy and associated procedures
• Dedicated Tenancy Sustainment Budget
• CCHA’s L&N Team works closely with residents to ensure early identification of issues and appropriate responses, referrals and signposting.
• CCHA also has two dedicated Tenancy Sustainment and Safeguarding Partners for complex tenancy cases.
Governance Reporting
2.2.2 RPs must provide tenants required to move with timely advice and assistance about housing options before the tenancy or licence ends
Yes
• CCHA is part of the commitment to refer and the L&N Team will provide clear information to any resident who is required to leave their home including contact details for the local homeless services team.
2.3 Tenure
2.3.1 RPs shall publish clear and accessible policies which outline their approach to tenancy management, including interventions to sustain tenancies and prevent unnecessary evictions, and tackling tenancy fraud, and set out:
a) The type of tenancies they will grant
b) Where they grant tenancies for a fixed term, the length of those terms
c) The circumstances in which they will grant tenancies of a particular type
d) Any exceptional circumstances in which they will grant fixed term tenancies for a term of less than five years in general needs housing following any probationary period
e) The circumstances in which they may or may not grant another tenancy on the expiry of the fixed term, in the same property or in a different property
f) The way in which a tenant or prospective tenant may appeal against or complain about the length of fixed term tenancy offered and the type of tenancy offered, and against a decision not to grant another tenancy on the expiry of the fixed term
g) Their policy on taking into account the needs of those households who are vulnerable by reason of age, disability or illness, and households with children, including through the provision of tenancies which provide a reasonable degree of stability
h) The advice and assistance they will give to tenants on finding alternative accommodation in the event that they decide not to grant another tenancy
i) Their policy on granting discretionary succession rights, taking account of the needs of vulnerable household members.
Yes
• CCHA has the following policies in place which are reviewed regularly in line with regulatory requirements, legislation and best practice:
• Allocations Policy
• Tenancy Policy (Tenure)
• Tenancy Policy, last approved by Board July 2021
• Allocations internal audit reported to A&RC
Do we comply?
Comments and evidence for compliance
• Every policy update is subject to a full review by a senior housing solicitor, to ensure the policies meet all legal and statutory regulations
• The requirements within Sections 2.3.1 (a-i) are covered within CCHA’s Tenancy Policy and the associated procedures
• Residents on the Rent to Buy Model are granted two 2-year fixed term tenancies following the starter period, in line with the Capital Funding Guide
Governance Reporting
2.3.2: RPs must grant general needs tenants a periodic secure or assured (excluding periodic assured shorthold) tenancy, or a tenancy for a minimum fixed term of five years, or exceptionally, a tenancy for a minimum fixed term of no less than two years, in addition to any probationary tenancy period
Yes • In line with CCHA’s Tenancy Policy, residents are granted an assured tenancy following successful completion of a starter tenancy where applicable. As above, residents on the Rent to Buy Model are granted two 2-year fixed term tenancies following the starter period in line with the Capital Funding Guide.
• Allocations internal audit reported to A&RC
2.3.3: Before a fixed term tenancy ends, RPs shall provide notice in writing to the tenant stating either that they propose to grant another tenancy on the expiry of the existing fixed term or that they propose to end the tenancy.
Yes • Residents on Startertenancies are advised of the outcomeof this in advance of the tenancy transferring to an assured tenancy. These tenancies would only be ended otherwise through the S21 Court process.
• Residents on the Rent to Buy model receive regular reviews throughout the rental period so are aware of the end period of their fixed term tenancies.
• Allocations internal audit reported to A&RC
2.3.4: Where RPs use probationary tenancies, these must be for a maximum of 12 months, or a maximum of 18 months where reasons for extending the probationary period have been given and where the tenant has the opportunity to request a review.
Yes • CCHA Starter tenancies are for a period of 12 months which may be extended to 18 months through the S21 process.
• Allocations internal audit reported to A&RC
2.3.5 : RPs shall grant those who were social housing tenants on the day on which section 154 of the Localism Act 2011 comes into force, and have remained social housing tenants since that date, a tenancy with no less security where they choose to move to another social rented home, whether with the same or another landlord. (This requirement does not apply where tenants choose to move to
Yes
• CCHA complies with this and grants tenancies in line with the Localism Act 2011.
• Allocations internal audit reported to A&RC
2.3.6 RPs shall grant tenants who have been moved into alternative accommodation during any redevelopment or other works a tenancy with no less security of tenure on their return to settled accommodation.
Yes
• CCHA complies with this and this is covered within CCHA’s Decant Policy
2.4 Mutual Exchange
2.4.1 RPs must offer a mutual exchange service which allows relevant tenants potentially eligible for mutual exchange, whether pursuant to a statutory right or a policy of the registered provider, to easily access details of all (or the greatest practicable number of) available matches without payment of a fee.
Yes
• CCHA pays an annual subscription to Homeswapper and promotes this to residents through the CCHA website, Social Media and front-line teams. Residents seeking housing in Cumbria can also use the Mutual Exchange process through Cumbria CBL. Residents do not have to pay a fee for either of these services. The housing teams provide support to residents who may need it, for example, helping to advertise their current property for mutual exchange
2.4.2 RPs must publicise the availability of any mutual exchange service(s) it offers to its relevant tenants.
Yes
• CCHA publicises this on the website, Social Media and through front line housing teams
• Allocations internal audit reported to A&RC
2.4.3 RPs must provide support for accessing mutual exchange services to relevant tenants who might otherwise be unable to use them.
Yes
• CCHA’s L&N Team provides this support, as required.
2.4.4 RPs must offer tenants seeking to mutually exchange information about the implications for tenure, rent and service charges
Yes • Information, including an affordability assessment is carried out at the point of application for a Mutual Exchange and reviewed by CCHA’s dedicated Income Team.
•