Consultation on a review of the Scottish Social Housing Charter: an analysis of responses

5. Current Outcomes and Standards: Communication (Charter outcome 2)

COMMUNICATION (Charter outcome 2)

Social landlords manage their businesses so that tenants and other customers find it easy to communicate with their landlord and get the information they need about their landlord, how and why it makes decisions and the services it provides.

Supporting Narrative

This outcome covers all aspects of landlords' communication with tenants and other customers. It is not just about how clearly and effectively a landlord gives information to those who want it. It also covers making it easy for tenants and other customers to make complaints and provide feedback on services, using that information to improve services and performance, and letting people know what they have done in response to complaints and feedback. It does not require landlords to provide legally protected, personal or commercial information.

Question 4a): Would you keep this outcome exactly as it is or change it? Please explain your answer.

5.1 Of the 92 respondents who answered this question 63% considered that the outcome should remain exactly as it is; 33% thought it should change; and 4% did not know. There were differences in views between categories of respondent. The vast majority of RSLs (83%) and local authorities (77%) who provided a view were in favour of keeping the outcome as it is. TRGs had mixed views however, with around half favouring the status quo and half suggesting change. Table 5.1 in Annex 2 presents a breakdown of views by respondent category.

5.2 A few respondents referred to the wider context around the outcome. One individual argued for a broader culture of openness and honesty amongst social landlords which they considered would support this outcome.

5.3 The Scottish Information Commissioner outlined how the Charter focuses on tenants and customers, whereas Freedom of Information ( FOI) legislation is concerned with universal rights and duties, making it important for social landlords to think about wider stakeholder groups over and above their own tenants. This, they suggested, may necessitate publishing information to a wider stakeholder group including third sector organisations which support and promote social housing to communities. The Commissioner suggested replacing "other customers" in the outcome wording to "other stakeholders", and "their landlord" to "a landlord" to address this.

Views of those in favour of keeping the outcome as it is

5.4 Those in favour of retaining the outcome reported it as being easy to understand, working well and central to effective social housing management. One statutory body commented that the outcome reflected the statutory duties around tenant participation.

5.5 One RSL welcomed what they considered was the lack of over prescription, which enabled landlords to shape their communication strategy according to their particular circumstances and customers.

Views of those in favour of changing the outcome

5.6 A recurring view was that the outcome as framed is too open and enables too much lee-way in interpretation. Calls were made for more specificity in the type of information to be made available.

5.7 Four TRGs shared the view that the outcome does not portray sufficiently the need for a higher standard of communication than previously existed. An individual respondent perceived the outcome to sustain the current situation in which the landlord controls what information they communicate and how they frame that information. A rights-based approach to the outcome was recommended by the Scottish Human Rights Commissioner to address any power imbalance in participative processes.

5.8 Two respondents, one TRG and one voluntary body, argued for the outcome to be re-drafted to reflect the tenants' perspective. It was observed that every outcome begins currently with "social landlords…", and they considered that rephrasing this to focus on the point of view of the tenant would meet requirements of people with communication difficulties (perhaps following brain injury for example, or those whose first language is not English).

5.9 One local authority perceived the wording "how and why it makes decisions and the services it provides" to be overly prescriptive and suggested its removal, particularly as the supportive narrative does not refer to this.

5.10 Six respondents recommended that in line with the Housing (Scotland) Act 2001, the text of the Charter should include here and elsewhere, reference to RTOs. This point was also made by others in response to other questions.

Question 4b): Please provide any suggestions on how we could improve the supporting narrative

5.11 A few respondents suggested that the supporting narrative gives more emphasis to this outcome on account of its perceived importance. One individual recommended that the narrative clarifies that both positive and negative information should be provided by the landlord.

5.12 Suggestions were made that the narrative should emphasise that information should be provided in plain English and in a variety of formats to meet the needs of people with communication difficulties such as sight impairment, poor literacy or lack of access to the internet.

5.13 Two individual respondents recommended that the supporting narrative should include reference to timescales for giving information and dealing with complaints. It was argued that this will be important in the context of tenant scrutiny.

5.14 Whilst a few respondents (including one from a remote island community) called for the narrative to include greater encouragement for landlords to use information technology including social media for communication purposes, in contrast, one individual remarked that the landlords should not lose sight of the need of most people for hard copy information.

5.15 A local authority considered that the narrative should make it clearer that feedback could come in many forms including surveys, tenant participation and focus groups. One RSL suggested that examples could be provided of ways to provide feedback and examples of how a social landlord could provide evidence that they have taken the results of the feedback into account.

5.16 Other comments included those of two respondents who recommended that some mention is made of tenant scrutiny in this supporting narrative; calls were made for Registered Tenants' Organisations to be included along with tenants and other customers; the Scottish Information Commissioner once again requested that "stakeholders" be inserted along with tenants in the context of FOI; and an individual respondent suggested the insertion of "..to understand, make complaints…" in the third sentence of the supporting narrative.