Optivo (now Southern Housing) (202205605)

REPORT

COMPLAINT 202205605

Optivo (now Southern Housing)

12 October 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:
1. Response to the resident’s request for repairs including damp and mould.
2. Response to the related complaint.
3. Knowledge and information management.

Background

Since 2018, the resident has been an assured non-shorthold tenant of a two-bedroom house, owned by the landlord. The landlord has recorded learning difficulties and long-term illness as vulnerabilities for the resident.
The resident was unhappy with the findings of a damp survey at his property in September 2021. The landlord said it would arrange a second surveyor to attend.
The resident raised a complaint in January 2022 about a phone call being dropped, about damp and cold at the property, and the expertise of the surveyor who had attended the property. The landlord responded on 3 February 2022 that the survey found no issues with the building, but that the kitchen fan needed upgrading, and the bathroom fan had been turned off by the resident when it should be on all the time. A second survey was arranged for the same day, 3 February 2022 when windows and doors were also surveyed and the resident was given advice about avoiding condensation.
The resident remained unhappy and chased the landlord for further action in February and March 2022. On 21 March, the landlord acknowledged his complaint escalation. A review panel was convened on 13 May followed by the final complaint response on 20 May. The landlord apologised for a call being dropped but said that the surveyor was experienced, and a second surveyor had supported the findings of the initial report. It said work had been completed to repair windows seals, fit a vent in the larder, upgrade the kitchen fan and repoint and repair the gable end.
On 15 July 2022, the landlord issued a stage one complaint response under a different complaint reference, covering several issues previously included under the above complaint including, damp in the bedroom, issues with the kitchen extractor, and drafty windows and doors. It issued a final response on 15 February 2023, again covering the issues it had previously responded to under the original complaint reference (which had completed the formal complaints process in May 2022). It also reviewed some new concerns and repairs raised after May 2022.
In its second stage two response, the landlord agreed for damp specialists to attend and seal the southwest brick wall, to overhaul the kitchen fan and all windows. The landlord offered the resident £350 to reflect the delays in finishing the work, inconvenience, time and trouble, miscommunication and unsatisfactory handling of the complaint. The landlord acknowledged that further learning was required when multiple items were raised. The resident has recently told this Service that since the new organisation took over (the previous landlord’s organisation was acquired during the complaint events), it had admitted liability for the repairs and although it was too late, it had at least sent a surveyor who for the first time was open and clear to the resident in their communication and findings.

Assessment and findings

Scope of investigation

The original complaint, under landlord’s reference 23400, was brought to this Service on 15 July 2022, after it had exhausted the landlord’s process in May 2022. Following this a second complaint was opened under the landlord’s reference 26051 which included many of the same concerns. However, the second complaint included some additional issues: kitchen flooring, ant infestation, water main issues and cracks suggesting potential subsiding. These additional issues will not be part of this complaint as they have not been brought within the Ombudsman’s formal remit. This investigation considers the following issues, which completed the landlord‘s process on 20 May 2022 and were brought to this Service by the resident in July 2022:
1. The broken windows, front and back door gaps, causing draughts into the property.
2. The reports of damp and cold in the property, and particularly in the bedroom and kitchen.
3. The walls in the bedroom were peeling.
4. Concrete falling from the gable end wall.
Whilst this investigation will primarily concentrate on the period from September 2021 until May 2022 (the end of the landlord’s complaints process), we will also take into consideration the landlord’s further action and response to the resident’s reports concerning these repair issues. It is the landlord’s response during the original complaints process that this investigation is primarily focussed with however as this is the complaint that brought the case within the Ombudsman’s formal remit.
If the resident wishes to raise concerns with the Ombudsman in relation to the additional issues covered in the later complaint process, under the landlord’s reference 26051, he may do so, subject to the usual time constraints for an Ombudsman investigation under the terms of the Housing Ombudsman Scheme.
The resident also contacted this Service in August 2023 in respect of live wiring under the artex; an uneven path; his concern about the chimney and general movement of the property; and an infestation of wasps/hornets. It is not known if this is currently being investigated by the landlord as a formal complaint, but the Ombudsman has made it aware of the resident’s concerns. Again, if the resident wishes to escalate these matters to this Service he may do so, after his complaint exhausts the landlord’s process. As such, those issues will not be part of this investigation.
This is because in accordance with the Housing Ombudsman’s Scheme paragraph 42 (a) the Ombudsman may not consider complaints which, in the Ombudsman’s opinion are made prior to having exhausted a member’s complaints procedure.

Assessment and findings

The resident’s assured tenancy agreement (TA) says at section 39 that the landlord’s responsibilities include to keep the structure and outside of the property in a reasonable state of repair and proper working order. This includes drains gutters outside pipes and the roof, outside walls, outside doors, windowsills and catches and window frames, inside walls, plastering (aside from minor cracking), floors, ceilings, doorframes but not inside painting and decorating.
Section 41 says the landlord is responsible for carrying out any repair work that is its responsibility, within a reasonable time of receiving the tenant’s report and to a reasonable standard.
Section 102 says the resident must ensure all rooms in the property are kept properly ventilated by opening windows and using any other specific ventilation means provided e.g., fans, extractors etc and also ensure that their home is sufficiently heated to prevent mould growth.
The landlord’s Responsive Repairs Policy effective April 2017 says at Section 5.0 that if a repair is not an emergency the landlord will arrange an appointment for as soon as possible and at a time that suits the tenant. The landlord would also aim to complete the repair in one visit. It also confirmed the same the responsibility of the landlord as in section 39 of the TA.
The repairs policy also states that an emergency repair should be completed within six hours and responsive will take as “little time as possible”. An emergency repairs is considered any risk of falling masonry or structural collapse.
Landlords are required to look at the condition of properties using a risk assessment approach called the Housing Health and Safety Rating System (HHSRS). HHSRS does not set out any minimum standards, but it is concerned with avoiding, or minimising potential hazards. Damp and mould are potential hazards that can fall within the scope of HHSRS. Landlords should be aware of their obligations under HHSRS, and they are expected to carry out additional monitoring of a property where potential hazards are identified.
The Ombudsman’s Spotlight Report on Damp and Mould (published October 2021) provides recommendations for landlords, including that they should:
1. “Adopt a zero-tolerance approach to damp and mould interventions. Landlords should review their current strategy and consider whether their approach will achieve this”.
2. “Identify where an independent, mutually agreed and suitably qualified surveyor should be used, share the outcomes of all surveys and inspections with residents to help them understand the findings and be clear on next steps. Landlords should then act on accepted survey recommendations in a timely manner”.
3. “Ensure they treat residents reporting damp and mould with respect and empathy. The distress and inconvenience experienced by residents in this area is some of the most profound we have seen, and this needs to be reflected in the tone and approach of the complaint handling”.
The landlord’s Compensation Policy February 2018 says at section 2.0 that the landlord will pay compensation when it has missed appointments, failed to repair or for poor quality of repair. Section 2.3 says the compensation policy does not include claims which are for ‘stress following any incident of or failure of service’. In some cases, the landlord may offer discretionary payments for distress or inconvenience (i.e., repeated attempts to resolve an issue).
In this instance, a survey was carried out on 8 September 2021 following a report from the resident that all the windows were very draughty. He also said that there was damp throughout the house and mould in his bedroom. However, the landlord assessed that a window upgrade was not due until 2026/2030 but agreed to replace gaskets and seal repairs to the windows. On 18 January 2022, a job was raised to replace the fire escape hinges to a window.
In its second final response of 15 February 2023 (when the issues were for a second time responded to under the landlord’s process), it stated that a job to overhaul the windows due to them being draughty was raised in November 2022 and completed in January 2023, which was over 16 months from the issue raised. However, this service has seen no other evidence of when the job was completed. The landlord failed to demonstrate that it followed up on the report or responded to the repairs required in relation to the draughts in a timely and reasonable manner, and in line with its policy.
The inspection from September 2021 found that there was a bathroom fan in situ, but the resident had turned it off. The surveyor explained to the resident that it was very important that this was left on. The surveyor assumed that this was related to the reported mould building up against the external wall in the bedroom opposite the bathroom. The surveyor advised that turning off fans would affect the humidity throughout the first floor of the property. The fan was left on following the inspection. The surveyor also advised that the kitchen fan was only effective for removing cooking smells etc so would be upgraded to a moisture tracker to help regulate the humidity. The loft was checked where insulation was found to be ‘present and full’.
The surveyor noted no crumbling and no sign of holes or gaps in the cement of the gable end wall. However, the surveyor also noted that it was likely that the cavity wall insulation would get wet and ‘soak up the water like a sponge’, and that would cause a problem with the cold wall showing mould and condensation on the inside. There is no evidence that further action was taken for this to be rectified until a later stage when the landlord reviewed its repairs handling for a second time.
The landlord records indicate that the resident called on 20 October 2021 to raise concerns with the report findings and was advised by the landlord on 3 November 2021 that it was chasing another surveyor for a second opinion.
The resident sent several emails over the next few months which stated he had been in contact with CAB and environmental health and the property was very cold even with the heating on. In January 2022 the landlord said that damp specialists had reported no damp but condensation, so no further action was required. It is not clear whether it referred to the inspection from September 2021 or another inspection was conducted. The resident kept chasing the landlord for an update.
A second survey was arranged for the day the landlord issued its first complaint response, on 3 February 2022. While the landlord said that that the surveyor’s opinion was supported by a specialist damp contractor, it had arranged for another survey and the results would be reviewed and acted upon. It also said that a new combination boiler had been fitted the previous month.
The second surveyor recorded that the temperature in the bathroom was 14 degrees with a relative humidity level of 70%, which meant the property would be prone to condensation issues with these levels. The surveyor said he would discuss the cavity wall with the first surveyor as this was raised by the resident during the visit. This service has seen no evidence of the additional notes as mentioned in the survey report or any further communication about the side wall with between the surveyors.
According to the repairs log, a vent in the larder cupboard, a kitchen fan upgrade, and a job to repoint and fill gaps in the mortar were raised in February 2022. There is no evidence of the completion date of those jobs although some of them were recorded as invoiced in May 2022.
In its initial final response of 20 May 2022, the landlord apologised for difficulties during a phone call that the resident said he had experienced, although it also said it had no record of any such issues. The landlord also said that the works to seal the windows and the airvents to the larder cupboard and the upgrade of the kitchen fan had been completed. The response noted that the resident had raised the issue of the gable end pointing and a week later the concrete came down in the wind. The landlord said that it had done all it could to resolve the repairs, so it did not offer compensation. The gable end wall repairs were then shown as completed in June 2022, but further repairs were logged in respect of damp in the resident’s bedroom, inspection of the external wall and draughty windows.
In its further final response of 15 February 2023 (when the issues were for the second time responded under the landlord’s complaints process under its reference 26051), it stated that the kitchen fan was updated “at some point between February 2022 and May 2022”. This statement will be further discussed in the landlord’s knowledge and information management section. However, it is evident that the landlord failed to assess its repairs handling in its initial stage two response of 20 May 2022, on account of its subsequent acknowledgement of failures when it progressed them through its complaints process a second time. As such, it failed to acknowledge its delays in handling the repairs at the time it progressed them through its complaints process and put things right for the resident. It stated in May 2022 that all the works were completed, but it did not acknowledge the damp and mould and the draughts issues, which had been raised since September 2021. This contributed to further delays in the handling of the repairs and additional distress to the resident having to chase them.
In its second final response of February 2023 (under landlord’s reference 26051), it stated that in January 2023 again inspected the side brick wall, which its surveyor believed to be causing the mould in the bedroom. It committed to “review the quotes and raise the necessary works”. The first reports of issues with this wall which might be the cause of mould and damp were raised during the survey from September 2021. However, the landlord failed to take any action for over 17 months. This was an unreasonable delay and not in line with the landlord’s policy which requires it to deal with repairs in as “little time as possible”. Additionally, there is no evidence that these repairs to the walls were competed up to the date of this investigation.
The landlord failed to demonstrate that it had taken appropriate action in line with the recommendations of the Ombudsman’s Spotlight Report on Damp and Mould or the provision of the HHSRS, which requires assessment and monitoring of any hazard in a property. It identified potential structural issues in the side wall causing internal damp and condensation in September 2021. However, it failed to follow up on it, monitor or take reasonable steps and effectively investigate and resolve this for a considerable period of time, extending to in excess of 24 months.
Additionally, the landlord did not take into account the resident’s vulnerabilities and the distress and inconvenience the situation had caused him. He had to chase repairs despite his condition and difficulties. The landlord’s response was not in any way empathetic and lacked customer focus. It failed to admit failures and provide a proper review of its repairs handling while the repairs were reviewed initially in May 2022. Additionally, it failed to provide clear information as to the outcome of its inspection and copy of its reports, which could have reassured the resident. It did not admit any failures when initially progressing the issues through its complaints process. In its second stage two response, it admitted delays and failures. However, this happened months after the resident’s initial reports. This extended period of time and the uncertainty with regards to the findings and the following works added to the inconvenience and distress caused to resident. Additionally, the landlord could not demonstrate that if had acted in line with the Ombudsman’s guidance to treat residents reporting damp and mould with respect and empathy.
Overall, there were considerable delays in the landlord’s handling of the resident’s repair reports with issues not having been evidenced as completed. The landlord failed to acknowledge its failures during its complaint process, including in relation to, the condition of the windows, draught, damp and mould. The landlord was not transparent about its findings, at times dismissive, and did not show empathy when dealing with the resident’s concerns. Some of the repairs, and particularly the ones related to damp and mould were not completed for over 24 months, and the ones related to the side external wall were not evidenced as completed to date. As such, this service has determined severe maladministration in the landlord’s handling of the resident’s complaint relating to his reports related to the windows and door gaps, damp and mould and issues with the gable wall.
While in its further stage two response, the landlord offered compensation of £350 for its failures, it is not clear which repairs were included because in its second final response, it included the review of some additional repairs’ handling. The compensation offer as stated in its second final response included:
1. Failure to do work by the second appointment.
2. Inconvenience time and trouble.
3. Failure to follow process.
4. Repeat visits to resolve outstanding issues.
5. Delays in carrying out repairs.
6. Miscommunication between contractors.
7. Unsatisfactory handling of complaint.

None of the above referred to any of the repairs and as such it remains unclear which repairs handling the compensation was offered for.

Ultimately, the landlord rejected the resident’s complaint under reference 23400 in May 2022 but by February 2023, under reference 26051 had accepted responsibility and failures in its handling of the repairs. The landlord committed to a damp contractor attending to inspect and quote to seal the southwest facing wall. The landlord provided contact details for the resident’s liaison officer who would oversee the repairs and offered £350 compensation. The landlord said that the lessons learned were that when inspections were raised with multiple items in the future, supervisors needed to ensure that they addressed each point or issue raised during that visit.
Since this second final response, the Ombudsman asked the landlord to explain why this change of stance in relation to the reports of damp had occurred. However, no clear response was provided or any evidence of further inspections.
When there are failings by a landlord, as is the case here, the Ombudsman considers whether the landlord’s offer of redress was in line with the Ombudsman’s Dispute Resolution Principles: Be Fair, Put Things Right and Learn from Outcomes as well as our guidance on remedies.
While the landlord completed some of the repairs, it failed to provide evidence that the main issue related to damp and mould, and particularly the external wall has been resolved. As such, it failed to put things right for the resident.
The final response of February 2023 appears to accept responsibility for the repairs subject of this investigation, but it has not been made clear if all the repairs brought to this Service and discussed in this investigation have been fully completed. As such, the landlord has been ordered to provide a report of its inspections to the resident and a plan for completing any outstanding repairs.
The compensation offered by the landlord in its second stage two response included its consideration of its belated acknowledgement that it had not addressed the resident’s reports about damp and mould appropriately. The sum offered also included consideration for additional areas of service failure identified by the landlord. In calculating a suitable amount of compensation for the landlord’s failures in relation to the damp and mould issues under investigation here, the landlord’s subsequent offer has been considered as it is clear that the failures continued following the end of the complaints process. In all the circumstances, the landlord’s subsequent offer was not proportionate to the detriment experienced.
The landlord was aware of the resident’s vulnerability and should have been mindful of the added challenges this would cause him when raising repairs and interacting with the parties involved. It has been seen in his correspondence with this Service and the landlord, that there have been times when the resident felt that the landlord was colluding with the contractors, and that specific staff were not competent. The landlord did not take sufficient steps to reassure the resident, there is no recorded input from a housing officer or other support staff. The resident lost confidence in the landlord and did not trust it to resolve matters for him. This vulnerability meant that the resident would reasonably suffer additional distress in dealing with outstanding repairs over an extended period.
In deciding an appropriate level of redress in this complaint, this Service has considered the resident’s level of rent, the landlord’s failures and the inconvenience and distress caused. The property is two-bedroom house and the rooms affected were the kitchen, the bathroom and one of the bedrooms. While the rooms were not entirely out of use, 3 of 4 rooms were affected and the resident could not have full enjoyment of them. Given the inordinate delay in the resident’s concerns around the repairs being addressed, if not resolved, the landlord should pay the resident the sum of £3423.40. As per the tenancy agreement from 2018, the resident’s rent is £100.90 per week and the period of time the resident had been reporting and experiencing issues with damp and mould was around 24 months. The rent and the period of time are only indicative and used as a guidance. As such, the compensation does not intend to amount to an exact refund. It comprises of:
1. £2,623.40 which is around 25% of the rent for the period of 24 months
2. and £800 for the distress and inconvenience caused to the resident having to chase the repairs.
In addition, for the recognition of its failures and the impact this had over such a period of time on the resident, the landlord is also ordered to apologise.

Complaint handling

The landlord’s complaint resolution policy effective November 2021 says:
1. That in line with the Ombudsman’s definition a complaint 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.’
2. At section 5.4 that stage one complaints will be answered within 10 working days. Section 6.3 details the options for a further review, (no timescale given for how quickly this must be done) a response will be sent to the tenant within ten days of a panel review.
The Ombudsman’s Complaint Handling Code (The Code) requires landlords to respond at stage two within 20 working days of the escalation request.
In this instance, the first complaint was logged on 20 January 2022 and the reply, under reference 23400, was issued within the timescale of the landlord’s policy, on 3 February 2022. However, there is evidence that the resident was dissatisfied with the landlord’s handling of the repairs prior to that, and from October 2021 after the outcome of the September inspection. The landlord failed to recognise and raise this dissatisfaction as formal complaint and as such it missed an opportunity to resolve the issue at an earlier stage.
It is not clear when the resident escalated his complaint, but the landlord’s acknowledgement was sent on 31 March 2022. The review response was issued on 20 May 2022, with a four-week delay as per the Code.
In additional to those delays the landlord’s response lacked a thorough and full approach. The complaint process is an opportunity for the landlord to review its action and to restore the relationship with the resident. The landlord, however, could not evidence that it made an effort to provide such a response. It failed to acknowledge some of the repairs, and particularly the ones related to window draughts, damp and mould. Additionally, the ones that it acknowledged as completed were not reviewed and assessed against its service standards.
The resident brought his concerns to this Service in June 2022, as directed in the final response. The landlord then reviewed the issues of damp in the property, draughty windows and external side wall again following our intervention, along with other concerns and issued a new complaint response, with a different reference, 26051, was issued on 7 July 2022 and then stage two on 15 February 2022.
While this service appreciates and encourages any action taken by the landlord following the end of the complaints process, this further investigation into the same issues caused confusion. Additionally, the change in its finding supported the resident’s concerns that the initial investigation into those repairs was biased and incorrect. This is a great concerns as of how effective the landlord’s complaints process is and how reliable are its staff.
The Ombudsman is keen that landlords look to findings of early resolution and offering reasonable redress, as part of the dispute resolution principles to ‘be fair’ and ‘put things right’. However, the Ombudsman does not encourage additional layers to the formal complaint process which should be completed before a case is referred to this Service. It would have been reasonable in these circumstances for the landlord to be clear that it had reviewed the old repairs formally and they had exhausted its process. A new complaint should have been raised only for the more recently repairs, and those reported after May 2022. Additionally, the fact that the case was reviewed again after the final response indicates that the landlord missed an opportunity to resolve the matter sooner.
In order for the Ombudsman to find that the landlord had made ‘reasonable redress’ on a case, the compensation offer would need to have been made within the formal process, not later as in this case. It is noted that the landlord had acknowledged its failings in handling of the substantive issues, but it did not explain its complaint process failings in not identifying these during the first investigation. Additionally, it did not provide resolution to the substantive issues and as such did not put things right for the resident event after the second final response.
Overall, there was maladministration in the landlord’s handling of the resident’s complaint. There were avoidable delays and considerable confusion over the complaints process caused by its double assessing of the same repairs under two separate reference numbers, one of which following the Ombudsman’s involvement. As such, a compensation order of £300 is consider fair in the circumstances and in line with the Ombudsman’s remedy guidance.

Knowledge and Information Management

The timeline points to a significant problem with the landlord’s record keeping. It indicates that the landlord’s repair logs were insufficient and inconsistent. No record was provided prior to February 2022. Additionally, the record of the repairs provided in 2022 was lacking any completion dates or description of the works or the action taken. Its inspection reports were not dated, a few pages and notes from the surveyors were missing. It is reasonable to conclude that this hampered the landlord’s and this service complaint investigation. The landlord in its further stage two response pointed to a job done “at some point” between February 2022 and May 2022.
Additionally, there were no telephone logs from the calls with the resident. Considering his vulnerabilities and that he was chasing the repairs and the complaints mainly via telephone calls, it would have been reasonable for the landlord to keep logs and notes of any discussions between it and the resident.
A landlord should have systems in place to maintain accurate records of repair reports, responses, inspections and investigations. Good record keeping is vital to evidence the action a landlord has taken and failure to keep adequate records indicates that the landlord’s complaints processes are not operating effectively, and a fair outcome cannot be achieved.
Staff should be aware of a landlord’s record management policy and procedures and adhere to these, as should contractors or managing agents. Given the above the landlord’s complaint record keeping was inappropriate. The survey reports were not dated and unclear as of the outcomes and next steps. There was no evidence of clear communication to the contractors and complete repair logs in addition to the lack of professionalism as evidenced by the change of position in the landlord’s follow up investigation. It is reasonable to conclude the landlord’s record keeping may have contributed to the overall delays, its lack of coordination and identification of issues.

Determination

In accordance with paragraph 52 of the Housing Ombudsman Scheme there was severe maladministration by the landlord in respect of the landlord’s handling of the repairs.
In accordance with paragraph 52 of the Housing Ombudsman Scheme there was maladministration by the landlord in respect of the landlord’s handling of the complaint.
In accordance with paragraph 52 of the Housing Ombudsman Scheme there was maladministration by the landlord in respect of the landlord’s knowledge and information management.

Orders and recommendations

Orders

The Ombudsman orders the landlord to arrange for a senior member of its staff to apologise to the resident, for the failings identified in this report, in person within four weeks.
The Ombudsman orders the landlord to pay the resident a total of £3,723.40 in compensation within four weeks. Compensation should be paid directly to the resident and not offset against any arrears. The compensation comprises:
1. £2,623.40 for the delays in the landlord’s response to his various disrepair concerns.
2. £800 for any distress and inconvenience the resident was caused by the landlord’s response to the resident’s ongoing damp and mould concerns.
3. £300 for any distress and inconvenience the resident was caused by the landlord’s complaint handling.
The landlord to reinspect the property for damp and mould within four weeks. Particular attention should be paid to the bedroom, side wall, kitchen and bathroom. The landlord should share its inspection report with the resident and the Ombudsman. It should include options for mitigating any damp and mould in line with HHSRS and ensure that the resident is provided with expected timescales for any identified works.
The landlord’s leadership to review the issues highlighted in this report. Within four weeks the landlord should provide the Ombudsman a report summarising identified improvements, which should also be cascaded to its relevant staff. Topics for inclusion include the landlord’s: approach damp and mould, with reference to HHSRS and the Ombudsman’s spotlight report; capacity to promptly complete disrepair works, compliance with the Code and record keeping, with emphasis on inspection records.
The landlord should provide evidence of compliance with the above orders within 8 weeks.

Recommendations

The landlord should provide training to relevant staff of its complaints process, including confirmation that the same complaint issues should not be investigated twice through its formal process. Where there is a change after the final response and the landlord is aware the Ombudsman is investigating, it should advise this Service accordingly.