Complaints Policy (Excluding Enterprise)

Policy Control:

Policy Level - Operational
Policy Reference - CS/CE/001/2019 (Corp)
Link to Strategy - Trusted Customer Service

Version Control:
V1 – Dec 2012: updated Group policy
V2 – Feb 2016: Policy Review
V3 - Feb 2022: Policy Review
V4 – Oct 2022: Policy Review
V5 – Dec 2022: Change in 6.1 (20-10 days)
V6 – Oct 2023: Change in 4.6 (policy
complaints) and in 7 (Associated documents)
V7 – Apr 2024 : Policy Review
V8 – Jul 2024: Removed 4.6 and amended
5.4 (policy complaints)

Approved by - Chief Customer Officer

Consultation - Customer Services Leadership Team, Resident Engagement Panel
Equality analysis - October 2022
Next review date - October 2025

1. Policy Statement and Aims

1.1 We try to make sure things don’t go wrong, but occasionally they do.
When that happens, the way we manage, resolve, and learn from our
mistakes is critical to our objective of providing great customer
service.
1.2 At Curo we welcome complaints. We encourage customers to give
feedback and when they do, we’ll listen, we’ll try to resolve things
quickly, and if we can’t we’ll explain why.
1.3 Customers have the option to request representation for their
complaint, should they prefer it. They may also choose to have their
representative accompany them during any meetings with the
landlord.

1.4 One of our strategic priorities is really listen to customers, value their
feedback and support, and act on what we hear. Curo looks to drive
a complaint obsessed culture, encouraging and enabling all our
colleagues to respond quickly and positively to complaints as soon as
we know about them.
1.5 This policy supports those aims by setting out principles for the way
we manage complaints. Our procedures put those principles into
practice.
1.6 Curo publicises their complaints policy along with their selfassessment against the Housing Ombudsman Code on their
webpage, providing clear guidance on how customers can directly
contact the Housing Ombudsman.
https://www.curo-group.co.uk/contact-us/feedback/complaints/
1.7 At any time, customers have the option to reach out to the Housing
Ombudsman. https://www.housing-ombudsman.org.uk/

2. Definitions

2.1 Curo means any or all organisations in the Curo Group, with the
exception of Curo Enterprise Ltd, who maintain their own separate
complaints policy.
2.2 A complaint is any expression of dissatisfaction; however, it is made,
about the standard of service we have provided, actions or lack of
action on Curo’s part, our colleagues, or those acting on Curo’s
behalf, affecting an individual or group of residents.
A resident does not have to use the word ‘complaint’ for it to be
treated as such. Whenever a resident expresses dissatisfaction
landlords must give them the choice to make complaint. A complaint
that is submitted via a third party or representative must be handled
in line with the landlord’s complaints policy. Third party permission
is still needed to discuss the details of the complaint after it has been
logged.
Initiating a report for the first time, such as for a repair or noise
disturbance, typically doesn't constitute a complaint. However, the
subsequent handling of the issue might evolve into one. For instance,
if a resident expresses dissatisfaction with the response to their initial
service request (e.g., suggested repair date), even while the request
is still being addressed, it necessitates raising a formal complaint.
2.3 An unreasonable complainant is someone who makes repeated
complaints, often on similar issues that have previously been
investigated, and may do so with the intention of causing
inconvenience, harassment, or expense.
2.4 Unacceptable behaviour means being aggressive, making demands
in a threatening way, not explaining what has gone wrong, and
refusing to listen. This may be an isolated incident or persistent; it
makes it difficult for us to consider a complaint and in extreme cases
may mean that we cannot do so. We do not consider a customer to
be behaving unacceptably just because they are assertive or
determined.

3. Scope

3.1 This policy applies to complaints made by anyone about Curo or
anyone working on its behalf.
3.2 The policy applies to all Curo organisations, with the exception of
Curo Enterprise Ltd. Sometimes there will be variations between
organisations; where this is the case, our procedures make it clear.
3.3 The policy also applies to services provided by others on our behalf.
We’ll deal with the customer’s complaint and work with the contractor
concerned to resolve the matter.

4. Roles and responsibilities

4.1 The Board and Executive, through the Policy Owner, make sure that
the policy delivers Curo’s strategic objectives and reflects corporate
values.
4.2 The Accountable Lead is accountable to the Executive for the
effective implementation of the policy in Curo, so that
• The principles are achieved through appropriate team plans and
objectives, and
• procedures translate the policy objectives into practice.
4.3 The Customer Resolution Manager reviews the policy and
recommends changes. They lead the Customer Resolution Team by
providing support and guidance as well as by monitoring the
standards of the service we provide.
4.4 Any colleague receiving the complaint will look to resolve this at
Stage 1.
4.5 If the complaint remains unresolved or the complainant requests
formal escalation, a Customer Resolution Adviser (CRA) will manage
the next stage of the complaint at Stage 2. This is the final stage of
Curo’s internal complaints process. If the complainant remains
unhappy with the outcome of the Stage 2 investigation, they will be
referred directly to the Housing Ombudsman, should they wish to
request an independent review of their complaint.
4.6 Managers support the resolution of complaints throughout each
stage. They also have a responsibility to make sure that their teams
take complaint resolution seriously:
• Ensuring complaints are dealt with by the team in a timely and
effective manner.
• Working with colleagues in other teams where that will help
resolve complaints.
• Setting objectives for relevant colleagues.
• Understanding the root causes of complaints about their services.
• Learning from complaints and making changes to the way we do
things.
• Prioritising the resolution of the complaint above other tasks.
4.7 If a complaint is about the behaviour of an individual colleague, this
will be managed as a one stage process by the colleague’s line
manager.
4.8 Contract Leads work directly with contractors to resolve complaints
about services provided by others. Complaints about the behaviour
of a contractor will be managed as a one stage process by the
Contract Lead.
4.9 All colleagues are responsible for responding to complaints in a way
that is consistent with this policy:
• Taking the complaint seriously.
• Recording it.
• Understanding what resolution, the customer is looking for.
• Trying to resolve it quickly, at Stage 1 of our process, to the
satisfaction of the customer.
• Working with other colleagues to deal with any concerns, queries,
or questions.
• Learning from complaints received to make changes which will
improve our service.

5. Principles

5.1 We welcome complaints. When things go wrong, we want to know,
and we won’t be defensive. We also learn from them to improve the
way we do things. We want to resolve complaints and we treat them
as a priority.
5.2 We know that every complaint, and the circumstances of the
individual who makes the complaint, are different and that we need
to be flexible in how we respond. We encourage colleagues to use
their discretion, whilst recognising that some overall guidelines are
necessary so that we can provide a consistent service. When handling
complaints, colleagues should consider the customer’s individual
needs and/or protected characteristics and this should be reflected
in the offer of resolution, where applicable.
5.3 We make it easy for customers to make a complaint.
• A complaint can be made to any colleague, and they will deal with
it, even if they work in a different part of Curo.
• Complaints can be made by telephone, email, social media, letter,
webchat, WhatsApp, SMS, webform, MyCuro online portal or face
to face.
• We accept complaints from a third party or representative,
however we need explicit consent from the customer to discuss
the complaint after it’s logged.
• When we contact a customer about a complaint, we use plain
language and, where necessary, provide large print, Braille,
translation services or a verbal reply.
5.4 We record all complaints and use the information to improve our
services.
• We’ll review every individual complaint to see whether there are
things we can change immediately.
• We carry out “root cause analysis” of complaints to identify
underlying reasons for things going wrong.
• We will survey customers who have made a complaint to ask how
we dealt with it.
5.5 The way we manage complaints reflects our values.
• Caring: we support customers who make a complaint, making the
process easy for them.
• Respectful: we listen to our customers and act on what they tell
us.
• Open: we keep customers informed and where we can’t resolve a
complaint in a way that satisfies the customer we’ll explain why.
• Fair: we review the outcomes of complaints with customers and
colleagues to make sure we’re consistent in the way we approach
and resolve complaints.
• Trusting: when we agree a resolution, we’ll do what we say we’ll
do.
5.6 We will not generally identify individual members of staff or
contractors when communicating with customers, except where this
information is pertinent to the resolution of a complaint.
5.7 We may offer resolution (which may include compensation) without
admission of liability.
5.8 Any resolution offered to a customer will be reflective of the extent
of the service failings and the impact on the customer. Factors taken
into consideration (length and frequency of situation; severity;
impact on the customer; customer circumstances etc.) will apply to
all cases.

6. Application

6.1 Our Complaints procedure sets out detailed guidance for colleagues
on how to manage complaints. This uses a two-step process:
• Stage 1: wherever possible, agreeing a quick resolution.
• We will acknowledge a complaint within 5 workings days of
receiving it.
• We will offer a Stage 1 resolution within 10 working days, if
possible.

• When we have offered a Stage 1 resolution, complainants will be
given 10 working days to respond or provide evidence to support
their claim, where required.
• If additional complaints are raised during the investigation, these
must be incorporated into the stage 1 response if they are related,
and the stage 1 response has not been issued.
• Where the stage 1 response has been issued, the new issues are
unrelated to the issues already being investigated or it would
unreasonably delay the response, the new issues must be logged
as a new complaint.
• It is possible for the complaint case manager to ask to extend this
timeframe, but they must notify and agree this with the
complainant. Any extension must be no more than 10 working
days without good reason, and the reason(s) must be clearly
explained to the resident. If an extension is agreed the customer
must be provided with the details of the Housing Ombudsman.
• If a request for escalation to stage 2 is received, residents are not
obligated to provide an explanation for their decision.
• Stage 2: where we need to investigate further and propose a
resolution.
• The person considering the complaint at stage 2 must not be the
same person that considered the complaint at stage 1.
• Requests for stage 2 must be acknowledged, defined, and logged
at stage 2 of the complaint’s procedure within five working days
of the escalation request being received.
• We will offer a Stage 2 resolution within 20 working days of the
complaint escalation date, if possible.
• When we have offered a Stage 2 resolution, complainants will be
given 10 working days to respond or provide evidence to support
their claim, where required.
• The timeframes set out above are in line with the Housing
Ombudsman’s Complaint Handling Code.
• It is possible for the complaint case manager to ask to extend this
timeframe, but they must notify and agree this with the
complainant. Any extension must be no more than 20 working
days without good reason, and the reason(s) must be clearly
explained to the resident. If an extension is agreed the customer
must be provided with the details of the Housing Ombudsman.
• Where a complainant fails to engage with Curo to progress the
complaint management and subsequent resolution within the
timeframe set by the case owner, their complaint will be closed
due to no contact.
We know that for most complainants having their problem heard and
acted on as quickly as possible is important. This is why we use a
two-stage process so that the majority of cases can be resolved at
Stage 1, and Stage 2 provides a more formal process for complaints
whereby the customer remains unhappy with the first stage
resolution.
6.2 We ensure consistency in complaint handling during both stages of
the complaint process by delivering regular training, monitoring and
sharing best practice from the Housing Ombudsman and completing
quality assurance checks on a fair sample of cases investigated. Our
complaints review forum advise on our compliance with this policy
and review anonymised complaints. They also advise if we are
making fair and right decisions when it comes to resolution, including
compensation.
6.3 We encourage everyone to complain as soon as possible after the
event; this increases the likelihood that we can resolve the matter.
We won’t consider complaints about things that happened more than
12 months ago, unless the issue is still ongoing; however, we will
consider extenuating circumstances when applying this principle. We
don’t hold personal information for longer than we need to, so any
complaint about things that happened twelve months or more ago
may be more difficult to resolve.
6.4 Our approach is different for:
• Complaints to Curo Enterprise. A separate complaints procedure
manages more effectively the more commercial nature of the
organisation and the different nature of the service.
• Complaints about termination of starter tenancies. Our starter
tenancy policy and procedure outline an appeal process that in
these circumstances will be followed. The appeal process replaces
our procedure.
• Complainants whose behaviours are unacceptable; we will decide
on a case-by-case basis how to manage these complaints. We will
write and explain why we are using a different procedure and how
we are going to do this. We will ensure we take into account the
Equality Act 2010 when considering managing these complaints.
6.5 It’s important that colleagues are seen to be impartial when dealing
with a complaint. Colleagues who:
• Have a family or other close connection to the customer.
• Were directly involved in the event that gave rise to a complaint.
• Feel otherwise unable to act impartially are not involved in trying
to resolve the complaint.
Can declare this to their line manager and identify and agree
handover of the complaint to a new complaint case manager. The
customer is advised who the new case manager is.
6.6 We will not always accept a complaint and on those occasions, we
will advise the customer why we have taken that decision. In these
instances, we will provide the customer with details for the Housing
Ombudsman should they wish to escalate this to them to review.
6.7 We would not raise a complaint if it directly relates to matters being
pursued via legal channels, however, this doesn’t include those being
investigated under disrepair. In these instances, the customer will
have the option to seek compensation via the complaint or the
disrepair case, payments will not be awarded by both.
6.8 We see complaints as an opportunity to leave customers satisfied
with our services after something has previously gone wrong. Our
complaints procedure has that aim. Where that doesn’t happen,
customers will have a further opportunity to take the complaint to
external arbitration. This means one of:
• A local MP or Councillor
• The Housing Ombudsman
• The National House Builders Federation
• The New Homes Ombudsman
• A support service commissioner
• The Information Commissioner’s Office
We’ll always write and explain which service is best suited to the
customer and how to take a complaint further.
6.9 We provide training on complaints and how to manage them for all
colleagues.
6.10 We publish information about complaints annually and this is
available online and in a printable leaflet on request. This includes:
• The number, type and outcome of complaints.
• What we’ve learnt from complaints.
• What we’ve done as a result.

7. Associated documents

• Curo Strategic Plan
• Customer Resolution Equality Analysis
• Curo Complaint Procedure
• Enterprise Complaint Procedure
• Starter Tenancy policy and procedure
• Relevant care & support procedures which may be required by
commissioning bodies and regulators.
• Compensation Policy & Procedure
• Curo Acceptable Behaviour Policy

8. Measures of success

We will measure success of this policy by:
• Reviewing customer feedback about our complaints process.
• Checking colleague conformance through a Quality Assurance
process.
• Monitoring the time taken from receipt of a complaint to a
resolution being agreed with the customer.
• Monitoring the percentage of complaints that are resolved at
Stage 1.
• Using the Complaints Review Forum to check anonymised cases
and collate feedback on how we handle complaints.

9. Equality

We’ve carried out an Equalities Impact Assessment (October 2022)
which identified the potential for inequalities in the impact of this
policy on different sections of the community. Monitoring of the effect
of the policy is therefore in place.