Response to the Regulator of Social Housing: Consultation on the consumer standards

The Institute of Customer Service welcomes the opportunity to respond to the Regulator of Social Housing’s consultation on consumer standards. 

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

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

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

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

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

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

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

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

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

Our starting position therefore is that in order for consumers to trust businesses and be satisfied with the services or products being offered by businesses, those businesses must ensure they are focusing on the way in which they serve those consumers and on customer experience with a ‘right first time’ approach – and the social housing sector should be no different. In order to fully understand what positive customer experience and satisfaction is, which in turn builds customer trust, businesses and organisations must invest in training, development and professionalisation of their customer service staff. Such training, development and professionalisation needs to be part of a wider organisational culture that enables, supports and encourages high levels of customer service standards and service excellence.  

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

Overall, do you agree that the proposed Safety and Quality Standard sets the right expectations of landlords, as set out in Chapter 6 of the consultation document? Please state if you agree or disagree. Please provide comments if you wish to explain your response.  

The Institute agrees the proposed Safety and Quality Standard sets the right expectations of landlords. However, we would ensure a focus is put on 2.3 – Repairs, maintenance and planned improvements that timely, consistent and easy to understand communications are sent to customers ahead of such works to ensure that customers are kept aware of works ahead of time. Contact details should also be provided by providers to customers of a customer liaison officer or customer service team, should they have any questions or queries about such works. 

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

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

Overall, do you agree that the proposed Transparency, Influence and Accountability Standard sets the right expectations of landlords, as set out in Chapter 7 of the consultation document? Please state if you agree or disagree. Please provide comments if you wish to explain your response. 

The Institute agrees the proposed Transparency, Influence and Accountability Standard sets the right expectations of landlords. 

However, the Institute would urge a principle is added that encourages social housing providers to build trust with their customers and increase their customers’ satisfaction levels which puts in place the ability of the Regulator of Social Housing to monitor the trust and satisfaction levels of customers for their social housing providers, simultaneously benchmarking this against other public services and regulated sectors. The Institute would be happy to discuss how the Regulator of Social Housing could utilise the UKCSI and other Institute measurements and research in order for social housing providers to fulfil this new principle.   

Overall, do you agree that the proposed Neighbourhood and Community Standard sets the right expectations of landlords, as set out in Chapter 8 of the consultation document? Please state if you agree or disagree. Please provide comments if you wish to explain your response.  

The Institute agrees the proposed Neighbourhood and Community Standard sets the right expectations of landlords.  

However, the Institute would again urge a principle is added that encourages social housing providers to build trust with their customers and increase their customers’ satisfaction levels which puts in place the ability of the Regulator of Social Housing to monitor the trust and satisfaction levels of customers for their social housing providers, simultaneously benchmarking this against other public services and regulated sectors. The Institute would be happy to discuss how the Regulator of Social Housing could utilise the UKCSI and other Institute measurements and research in order for social housing providers to fulfil this new principle.   

The proposed Code of Practice is designed to help landlords understand how they can meet the requirements of the standards. Do you agree that the proposed Code of Practice meets this aim? Please see Chapter 10 of the consultation document for more information on the Code of Practice. Please state if you agree or disagree. Please provide comments if you wish to explain your response.  

The Institute agrees that the proposed Code of Practice meets the aim of helping landlords to understand how they can meet the requirements of the standards proposed.  

However, the Institute would particularly focus on the Transparency, Influence and Accountability Standard paragraph 24 which states, 

All tenants deserve to be treated with fairness and respect and this principle should underpin how registered providers deliver all landlord services. Registered providers should foster a strong culture throughout their organisation of fairness, courtesy and respect, where tenants are listened to and can trust their landlord. In treating tenants fairly, providers should consider how they can adapt their services and communications to meet individual tenants’ needs. 

The Institute strongly agrees with this focus on building a strong culture of fairness, courtesy and respect, where trust is built and where tenants are listened to. However, the Institute would question how landlords will be measured against one another within the sector, and benchmarked on their progress of this focus outside of sector as well. Again, the Institute would urge a principle is put in place that ensures the Regulator of Social Housing can monitor the trust and satisfaction levels of customers for their social housing providers, simultaneously benchmarking this against other public services and regulated sectors. Without such consistent and independent measurement, social housing providers won’t be able to understand how they’re doing in comparison to their counterparts, nor in comparison to the rest of the public service and regulated sector areas of society which their customers will also likely be interacting with on a frequent basis.  

On ‘Engagement with Tenants’, understanding effective engagement must also be prioritised so that social housing providers can consistently improve their engagement with their customers. Again, measuring customer satisfaction here on a consistent and independent basis would help providers to understand the impact and effectiveness of their engagement strategies and tactics, whilst allowing the Regulator to understand which providers may fall down on this point as well – allowing the Regulator to help such providers to improve their engagement with their customers.  

Further, on engagement with customers more generally, social housing providers should be mindful of potential vulnerable customers that they may be providing housing too and also that not all customers will want to receive engagement communications in the same way.  

Some vulnerable customers will be more obvious to identify than others. Some customers will be more open with their communications preference(s) than others too. Ensuring there is detailed and clear guidance for social housing providers across the communications channels providers should be using with customers, learning lessons from past experiences and demonstrating improvements in customer service and dealing sensitively with vulnerable customers is of paramount importance.  

However, on communication channels and the use of appropriate channels for appropriate customers, it should be strongly noted that not all customers will want just one form of communication channel used by their social housing provider to contact them.  

The Institute conducted breakthrough research on technology and customer service. Entitled ‘A Connected World? Ensuring the right blend of people and technology for customer service’, our research notes the following key takeaways: 

• 73% of customers see themselves as confident users of technology. But 15% lack confidence. 
• 41% of customers have used at least 6 different apps in past 6 months to buy something or access services.  
• There is a wide diversity in customers’ preferred channels for contacting organisations, depending on the situation or type of contact. 
• The main reasons for contacting an organisation by phone are the need for reassurance, and for certainty about an issue that could not be resolved online or via an app. 

• Artificial intelligence-enabled chatbots are more likely than experiences in other channels to cause annoyance. 
• Customers welcome practical applications of technology to improve service but views are polarised about use of artificial intelligence and data in the context of highly personal or sensitive experiences. 
• When organisations launch new technologies, the most important factors they should consider from a customer service context are the option to speak to a person, the availability of customer support and the needs of vulnerable customers. 

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

On dealing with vulnerable customers and those in vulnerable circumstances, the Institute would urge the Regulator of Social Housing, and indeed landlords, to consider all types of vulnerability of customer, not just prescribing certain types of vulnerabilities or situations. Digital exclusion should be considered when considering customer vulnerabilities. On vulnerable customers, our breakthrough research also notes: 

• Four main factors contribute to the risk of digital exclusion: a physical or mental disability that makes it difficult to contact organisations through digital channels; lack of skills or confidence in using technology; lack of financial resources; and a relatively small number of customers live in areas with gaps in mobile or broadband coverage. 
• Our research suggests that people who are unemployed or who do not use a computer or smartphone at work are more likely than average to be at risk of digital exclusion.  
• At least 23% of us help others to use digital technologies in dealing with organisations and 32% have done so in the past. The main reasons why some customers need help to deal with organisations online is because they don’t understand the process / interaction or are unable to use digital technology. 
• Customers believe that the most important ways organisations can reduce the risk of digital exclusion is by enabling people to speak to an employee when it is needed, and by sharing best practice. 

This exemplifies the need for landlords’ engagement with tenants to include a wide range of channels for customer contact into the future, not just a reliance on those that are most efficient or innovative for the organisation – a focus on vulnerable customers who could be excluded, particularly in an uncertain and worrying economic climate for many, should also be of paramount importance.