Transparency, Influence and Accountability Standard

By Paul O’Callaghan · 16 May 2024

We’re excited to share a series of insightful conversations on the new Regulator of Social Housing Consumer Standards, which came into effect on 1 April 2024. In these discussions, ARK Assistant Director Paul O’Callaghan sat down with Nick Sedgwick and Helen Scurr to delve into the key changes and implications for housing providers within the sector. In this conversation, Paul and Helen focus on the Transparency, Influence and Accountability Standard, discussing the importance of resident engagement, and the challenges and intricacies of maintaining good communication with tenants.

You can watch the video of their conversation below or scroll down to read the full transcript.

Our video on the Safety & Quality Standard can be viewed here.
Our video on the Tenancy Standard can be viewed here.
Our video on the Neighbourhood and Community Standard can be viewed here.

Transcript:

Paul O’Callaghan: Hello, everyone, and welcome to our Bite-Sized conversations, where we discuss the hot topics in the housing sector. My name is Paul O’Callaghan, and I’m one of the Assistant Directors here at ARK. I’m delighted today to be joined by Helen Scurr, who is one of our company directors. Today we will be talking about the new consumer standards, which were launched on the 1st of April this year. We will be talking in this session about the Transparency, Influence and Accountability Standard. So, Helen, Transparency, Influence and Accountability. That’s twice I’ve managed to say it without tripping over my tongue now. So I’m quite pleased with myself. Obviously, this forms part of the four new consumer standards, and for me, this one is quite a complex standard because of everything that it covers. But it’s also made up of areas I think organisations are really, really struggling to get a handle on. What are your thoughts around this standard in particular and just what it means for organisations? What kind of things should they be thinking of?

 

Helen Scurr: I think a new title for the standard would be a good idea, so no one forgets it, because this is going to be one that really does test organisations. To some degree, it does what it says on the tin. For me, it is about how tenants and residents are treated. It is about equality, fairness, and behaviours. It’s about ensuring that tenants are very much engaged in designing services going forward. It’s listening to tenants who may not be happy with the service they’re receiving, tenants who may be making complaints. But it’s also about working with those tenants to come up with a resolution. Understanding tenants, we often talk about property data, don’t we? And, you know, data again is a common thread and a common theme across all of the new consumer standards. However, data and information around tenants, people that live in those households, we know is a real weakness in the sector. We work with clients where they won’t have updated data for years. And actually, you know, you’ve had additions to the family or people exit households and they don’t necessarily know. They also don’t necessarily understand the vulnerability needs and the protected characteristics of those tenants and residents. And all of that is such rich information that this is going to require organisations to really sit up and look at data and what it’s telling them, but more importantly, where the gaps are.

 

Paul: There are a few things within this standard, and I will touch on them through this conversation. The first one I want to draw out, and this really leans into your expertise and your experience as well, is really how we engage with residents as organisations. Where have you seen it work well? How have you seen it work well? And what more can organisations do in terms of making sure that we are hearing our residents through a multitude of channels, because they do talk to us in very, very different ways. But from your experience, how have you seen it work well before?

 

Helen: Well, what it isn’t is inviting 3 or 4 people into a room to have a cup of coffee and a cake because I think, you know, gladly those days are gone. It’s about engaging with tenants through lots of different mechanisms. And where we see it work well is where organisations see tenants as part of the solution to either issues they have or indeed to improve services. So, you know, if I can take one example of a client that we’ve been working with recently that have gone through quite a lot of regulatory challenges, we have worked with their tenants and residents through a whole range of mechanisms, using things like text messages to get responses. We’ve gone out into the communities, so bringing different community groups together, working alongside partners and other stakeholders who are also engaging with people in those communities to actually share information. So, you know, it’s about going out, talking to tenants and residents. It’s about enabling them to be able to contact you through whatever mechanism. What it isn’t about is actually ignoring that feedback and that response. It’s also thinking about how people with protected characteristics can influence and support service design and service improvements, so ensuring that they have a voice, ensuring that actually, you are responding to their very specific needs. So it’s being fleet of foot. It’s around having a whole range of mechanisms to engage and communicate with tenants and residents. It’s about engaging with the stakeholders. And actually more importantly, it’s about listening to what they’re telling you and acting on their feedback and responses is so important.

 

Paul: I think that’s one of the key things that, in conversations that I’ve been having with organisations in the last 12 months, obviously everybody had to carry out their TSM surveys, which was a big change for the sector. You know, primarily people were using transactional methods that moved to perception-based surveys. Now, the conversations that I was having with organisations, it was very much a case of the scores are great, and it will give you an oversight of what your residents think about you. Again, it’s the range of indicators, the question and the thing that the regulator will want to see is, what are you doing with what they’ve told you, particularly if you’ve asked open-ended questions in there as well. And taking in that qualitative feedback in the same way. Okay. Well, how do we utilise that? How do we look at what themes are coming out? And it leans very much back into things like when we were talking about Grenfell, for instance, how do we take the themes and how do we make sure we hear the voice of the customer as a collective? And I think that’s probably a bit of a step change for organisations in terms of changing the way that they work and looking at smarter analytics, but also reporting at the highest level as well to make sure the resident voice comes through. And I think the TSMs will help with that. One of the other things was around triangulation of that data. So looking at whenever you get a call into your contact center, the chances are that that contact goes on to a CRM. Yeah. There’s so much information that’s out there. Yeah. And generally, people will say, ‘I called up to report a repair, I’ve raised a repair’ and the repair’s been completed, brilliant, we’ll close that one down. But what else is in there? What else or what other parts or bits of insight are in there. So I think there’s a really important part there. The next question I wanted to ask you really around residents was the importance of a really robust communication strategy. And this is something that’s within this standard, which really focuses on how do we give them information to our residents, how do we provide that information for their consumption? Now, I would know that most organisations will go, ‘We’ll put it on the website.’ Yeah, yeah. How many people go on to the website to look for things like that? Have you got any advice for organisations that might be looking at how do we engage proactively in terms of an outgoing communication strategy?

 

Helen: Again, I think it’s asking tenants how they want to be communicated with and not making an assumption. We’ve still got an awful lot of digital exclusion, within the communities. Not everybody can afford or has access to digital, internet. It’s just not always there, not everyone’s first language is English. So actually, it’s asking people how they want to be communicated with is an absolute priority. I also think it’s about nuggets of information. There’s lots of colleagues will enter a tenant’s home, whether that be an operative, whether that be a neighbourhood officer, and actually asking questions, making almost part and parcel of that activity to ask the tenant, you know, have your circumstances changed, how would you like us to communicate with you and is there support you require. And what we are told by frontline staff is they don’t feel able or have the time to ask those questions, because often they’re. If they’re repairing, they’re carrying out a repair, they’re on a limited time scale to complete that repair, and they’ve got to move on to the next job. So again, I think it’s back to culture and behaviours. You know, if your frontline staff feel empowered and want to take the time and listen, then they will hear and they will then, you know, gather lots of rich information that can come back, whether that’s through a CRM system or a different database. But actually, it’s capturing that information and bringing that back that will build up and help develop a communication strategy. And it will identify gaps as well, whether that’s digital exclusion, digital inclusion or actually where housing associations need to spend a little bit more time with tenants and residents or invest money. So it’s twofold. There’s no, you know, one size fits all. It’s just not there.

 

Paul: I have two challenges now for you, two questions which have just come to me through, you know, through that conversation. The first one, bearing in mind the strength and the breadth of the challenge that we’re now talking about in terms of hearing that resident voice, in your opinion, do you think that the capacity exists within the sector to meet this standard, particularly around that, hearing the customer voice?

 

Helen: I think they will struggle. I think there’s so many competing priorities at the moment in the sector. We moved away, from, you know, tenant engagement through board structures for lots of different reasons. There used to be quite a framework in place around tenant engagement and tenant activities. Organisations are lacking capacity in that area. We are certainly seeing clients ask for support in this area, whether that’s around helping them to develop new strategies, whether that’s actually around providing some interim support to help develop an approach, or indeed whether that’s working in communities with tenants and residents groups to help build capacity, to help them engage, develop those skills they need to engage and indeed deliver some qualifications in that area as well. So, you know that that there’s a whole plethora there of support that that certainly we are currently providing for our clients that will build capacity in their businesses to enable them to really think about how can I achieve standards, where are are the gaps? and I think this is I think one of the more challenging standards, because it’s people focused. So it’s not necessarily about we need to spend X amount to bring our properties up to standard or you know, or address what are improvements in our stock. It’s much more around people, so thats an investment in people.

It’s about behaviours training. It’s also about culture. It’s enabling frontline staff to feel confident to go into people’s homes and actually ask some what can be quite difficult questions. but also to take that feedback to inform service improvements.

So it is about building capacity in organisations and some organisations are now, developing new roles. They are looking at their target operating model. We now know that, you know, the ombudsman’s spotlight report talks about capacity, and certainly we are seeing, operations now focus on customer numbers. So reduction in certain patch sizes that neighbourhood officers are managing. We’re seeing enhancements around sort of supported housing and actually helping more vulnerable people to become engaged. And a lot of that could be through 1 to 1 conversations. But it is a capacity issue, definitely in the sector, and I think it will continue to be.

 

Paul: Absolutely. It’s one of the things obviously, you know, I started at ARK earlier this year and I think one of the first projects that you told me that you were working on was a huge resident engagement project. So another area of expertise and specialism for ARK I think. Before I get onto the killer question or the killer conversation, one of the things that came to me that was and it’s within the standard is it’s the provision of performance information that anybody who’s worked in a housing association or a local authority will know what a performance management framework looks like. Very, very complex. Used to be an Excel spreadsheet, probably now in a Power BI dashboard made up of lots of jargon, lots of internal jargon in terms of how we refer to things. Obviously, we’ll now have to tweak the way that we talk about things to make sure that, the residents of organisations can understand how we measure ourselves and measure our performance. So I think that’s another thing where we’re talking about sort of, you know, changes in communication, but also changing culture about kind of how we see ourselves and making sure that residents understand things as well. So it was more of an observation than, than a question.

Helen: Yeah. I think, you know, jargon busting is going to be required, you know, we’re all so used to, KPIs, key performance indicators, metrics, measures, analytics. And actually we’re used to that jargon. But if we are and we will need to engage tenants and residents to absolutely question performance and understand the results that are being provided for them, and that is going to take a shift in culture and an explanation. And also, I think, to identify what are those key metrics. be very clear that, they need to align with the feedback that is coming through the tenant satisfaction measures and the perception surveys. And think about what do tenants really want to know about how can we provide evidence around our performance as a business that they can then challenge and question? So it’s not about blinding people with science. It has to be about it’s almost back to basics for me. and measuring some of that, sort of those, those core housing management, requirements and managing them well and effectively and getting feedback from tenants.

 

Paul: So onto the onto the topic. Obviously, the Housing Ombudsman becomes quite prevalent within this standard. and it’s been really, really interesting to see how the dynamic between the Housing Ombudsman and the regulator has kind of taken shape over the last 12 to 18 months. As you know, we’ve gone through kind of green papers, white papers, Social Housing Regulation Act, obviously as part of this. Now, the complaints handling code has become statutory for people to complete and submit to the Housing Ombudsman.

What sort of role do you see them playing in terms of maintaining standards within the sector? Because as it stands at the moment, and I think until the kind of inspection regime and the regulation really kicks in, they’ll probably still remain two quite separate entities. My gut feeling is that actually we’ll start to see them sort of converge on each other as time goes on. But I’d be interested to hear what you think, how you think that relationship will go.

Helen: I think we’re already seeing that happen. We work with, a range of clients who have gone through regulatory downgrades, and help them to improve performance. and we see, I suppose, quite a lot of alignment with what the regulator identifies and what the ombudsman will be identifying. and when you look at the new standards, a lot of what is contained in these standards has come as a direct result from regulatory downgrades from things like Grenfell and Awaab’s Law and also from, obviously, the ombudsman’s observations and challenges within the sector. So, you know, they are going to be aligning, with each other far more and quite rightly arguably should be, because it’s about raising standards.

and it’s about, raising aspirations as well of tenants and residents. So, you know, we have recently been helping clients to review their approach to how they manage complaints. how they learn from complaints, which is always one of those sort of gray areas. Some businesses think they do it really well. But actually when you go and you look for the evidence, there is no evidence of learning or change in service provision, service delivery. So I think we are going to see far more alignment there, so service improvements, from complaints, will definitely be a key challenge around evidence for organisations to be able to provide that evidence. but also how organisations communicate with tenants and make complaints, keeping them in the loop, making sure that they regularly update them, involve them in the outcome and make sure that actually the service has changed or improved as a result of that complaint.

So lots of alignment here with the standards. And you know, I keep coming back to culture. I will probably drive you mad by saying it’s all about culture and behaviours, but fundamentally it is. You know, if you don’t see a complaint as an opportunity to learn, then your culture is very badly wrong in the organisation. You’ve got to empower your staff to be able to deal with customer inquiries. You’ve got to give them accountability and enable them to resolve issues at that front line, not escalation up the seniority within a business. It’s about empowering frontline people to be able to deliver good quality services, and the Ombudsman has, identified an awful lot of issues within their reports that I’m sure we’ve all read, that we see when we work with clients.

 

Paul: Absolutely. So in terms of a summary of some of the services that ARK can offer in terms of supporting organisations to become compliant with the standard, what would you say the top 5 to 6 services are, in your opinion?

Helen: Mock inspections. So, until we’ve had the first round of RDAs it’s going to be difficult to sort of have a very clear understanding what comes through that. We are helping organisations with mock inspections at the moment, a number have already done self-assessment, but a number have also asked us to help them do self-assessment. From that it’s about developing improvement plans.

So understanding those gaps but working towards addressing those gaps. So very clearly service improvement plans and what flows from that is often a review of policies and procedures and operating practices. Interim support. We’ve got a lot of our colleagues out now in the field, helping organisations, and that’s about adding capacity. It’s also about training for staff. So, you know, we do a lot of training for organisations, leadership, management training, behaviours, conduct. And a lot of our people, of course, are fully CIH qualified. And that is now going to be a requirement. It’s also about developing and understanding those performance frameworks. So you touched on, making sure that tenants and residents can understand performance and how to measure it.

So simplifying some of those performance frameworks, we are supporting organisations. Some of that’s through the use of dashboards and other approaches are available, of course. but that is one of the services that we offer. So I’ve probably missed lots of what we can offer, but I think fundamentally those are the key areas and of course recruitment. So where there are capacity gaps, we can and we do carry out recruitment campaigns, for lots of different roles in the sector, as well as board roles. So it’s about adding capacity.

 

Paul: Helen, it’s been wonderful talking to you. Thank you so much for your time and for your input. and for your expertise as well. It’s been really, really, really delightful. thank you to everybody who’s tuned in to watch the video as well. we hope that you enjoyed it.

 

Here at ARK, we can help you to meet or exceed the new RSH Consumer Standards. If you would like more information, simply get in touch.

Paul O’Callaghan, Assistant Director – pocallaghan@arkconsultancy.co.uk