Summary: Miss X complained about the Council’s failure to appropriately respond to her reports of domestic violence, the priority awarded to her Housing Register application and poor conditions in her temporary accommodation. We do not find fault in the way the Council assessed Miss X’s priority on the Housing Register. We find the Council has taken satisfactory steps to improve procedures around reports of domestic violence and staff training. But, we find the Council’s fault in handling her reports of domestic violence meant Miss X was without suitable temporary accommodation. We find there was fault in the way the Council responded to several reports of pest infestation in her temporary accommodation. To remedy the injustice caused, the Council has agreed to apologise to Miss X and make her a payment for the unsuitable temporary accommodation.

The complaint

1. The complainant, who I shall refer to here as Miss X, complains about the Council’s handling of:
1. her housing register application. She says the Council incorrectly assessed her housing register application following a medical assessment in July 2019 and suitability review of her temporary accommodation in September 2019;
2. her reports of disrepair and infestations in two temporary accommodations. She complains the Council failed to address and resolve these in a timely manner;
3. her reports of domestic abuse in November 2019; and,
4. her complaints. She says the Council failed to fully respond to the complaints made and brought them altogether in one complaint response.
2. Miss X says the disrepair issues have significantly affected her health conditions and ability to work. She says she and her family were living in poor living conditions.
3. Miss X says the Council’s failure to provide sufficient assistance following reports of domestic abuse caused her significant stress and distress.
4. Miss X says she does not feel listened to by the Council when she has complained about the dangers caused to her by a regeneration scheme.

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What I have investigated

5. I have investigated the time period between July 2018 and June 2020.
6. The last section of this decision explains the reasons why I have decided not to investigate matters complained of dating back to 2012.

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The Ombudsman’s role and powers

7. We investigate complaints about ‘maladministration’ and ‘service failure’. In this statement, I have used the word fault to refer to these. We must also consider whether any fault has had an adverse impact on the person making the complaint. I refer to this as ‘injustice’. If there has been fault which has caused an injustice, we may suggest a remedy. (Local Government Act 1974, sections 26(1) and 26A(1), as amended)
8. We cannot question whether an organisation’s decision is right or wrong simply because the complainant disagrees with it. We must consider whether there was fault in the way the decision was reached. (Local Government Act 1974, section 34(3), as amended)
9. If we are satisfied with an organisation’s actions or proposed actions, we can complete our investigation and issue a decision statement. (Local Government Act 1974, section 30(1B) and 34H(i), as amended)

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How I considered this complaint

10. I spoke with Miss X about her complaint. I considered the information and documents that Miss X and the Council sent me.
11. Miss X and the Council had an opportunity to comment on my draft decision. I considered all comments before making a final decision.

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What I found

Background

12. Miss X and her children became homeless in 2012. The Council decided it owed Miss X the main housing duty because she was homeless, in priority need and not intentionally homeless. The family have been in temporary accommodation since 2012.
13. During the time period that I have investigated, Miss X lived in two temporary accommodations:

• Accommodation A between July 2018 and May 2019
• Accommodation B between May 2019 and June 2020.

14. Miss X previously experienced domestic abuse. She lives with her two children and her grandchild.

Priority on the Housing Register

The relevant law

15. Every local housing authority must publish an allocations scheme that sets out how it prioritises applicants, and its procedures for allocating housing. All allocations must be made in strict accordance with the published scheme. (Housing Act 1996, section 166A(1) & (14)
16. An allocations scheme must give reasonable preference to applicants in the following categories:

• homeless people;
• people in insanitary, overcrowded or unsatisfactory housing;
• people who need to move on medical or welfare grounds;
• people who need to move to avoid hardship to themselves or others;

(Housing Act 1996, section 166A(3))

17. Housing authorities do not have to design their scheme to give more priority to applicants with more than one reasonable preference need (sometimes called cumulative preference).
18. The courts have decided that reasonable preference means giving the applicant a “head start” over other applicants who do not have reasonable preference. It does not mean they are given absolute priority for an allocation of social housing.
19. Housing authorities may choose to adopt a scheme which gives additional preference to certain categories of people who are entitled to reasonable preference and have urgent housing needs.

The Council’s housing allocations scheme

20. The Council has a points-based housing allocations scheme to assess the relative priority of applicants who qualify to join its Housing Register. For the purpose of this complaint, I have considered the Council’s 2015 housing allocations scheme as this applied at the time of the matters complained of.
21. Under the 2015 scheme, for pre-November 2012 homelessness applicants like Miss X, the Council awards 600 points to homeless applicants in temporary accommodation who are owed the main housing duty. For those homelessness applicants after November 2012, the Council awards 200 points.
22. The scheme says, for pre-November 2012 applications, the Council can end its main housing duty if it makes a suitable offer of social housing to such applicants.
23. For pre-November 2012 homelessness applicants where the Council has accepted the main housing duty, the Council cannot end this duty through an offer of private rented accommodation unless that offer meets the requirements of ‘a qualifying offer’ and the applicant accepts the offer. The Council cannot bring the duty to an end if such an applicant refuses this type of offer.
24. The scheme does not allow for cumulative points if an applicant qualifies under different reasonable preference categories (for example, homelessness and medical needs).
25. Additional preference points can be awarded to applicants who have an accepted health and wellbeing need to move. However the scheme does not permit homeless applicants owed the main housing duty to be awarded these points. The Council says if a homeless applicant in temporary accommodation has an accepted medical or wellbeing need to move, it will offer alternative suitable accommodation to resolve that need.
26. The scheme also provides for applicants who have an urgent need to move, and an emergency and exceptional priority, to be awarded 1000 points. The Council will make a direct offer to applicants awarded this by its Exceptions and Special Applications Housing Panel. The scheme says homeless applicants owed the main housing duty are not eligible for points for emergency or exceptional needs.

Miss X’s priority

27. Miss X has been on the Housing Register since January 2012. She has 600 points because the Council owes her the main housing duty as a homeless person and she is in temporary accommodation. The Council has decided she has a need for a three-bedroom property.
28. Miss X has not been successful in bidding for social housing advertised on the Home Connections choice-based lettings scheme. She has not received a direct offer of social housing from the Council.
29. Miss X says the Council incorrectly assessed her housing register application following a medical assessment in July 2019 and suitability review of her temporary accommodation in September 2019.
30. As a homeless person in temporary accommodation, Miss X does not qualify for extra health or wellbeing points under the Council’s housing allocations scheme. A Medical Assessment Officer can only make recommendations about the type of property that would be suitable if she were to be offered social housing in future.
31. The Council sent me records of the medical assessment from July 2019 and its suitability review from September 2019. These show:

• the Council’s medical assessment officer had considered Miss X’s medical conditions and the evidence she provided. The Officer recommended Miss X bid on any type of property. She considered whether Miss X’s conditions meant she needed an unlifted or lifted floor level property, an extra bedroom or specific heating requirements. The Officer decided Miss X’s medical conditions should not lead to any restrictions on properties she could bid on; and
• the Council reviewed the suitability of Miss X’s temporary accommodation, but decided the property was suitable.

Disrepair and pests in the temporary accommodation

Suitability reviews of temporary accommodation

32. The law says councils must ensure all accommodation provided to homeless applicants is suitable for the needs of the applicant and members of his or her household. This is a continuing duty and applies to interim accommodation and accommodation provided under the main housing duty. (Housing Act 1996, section 206 and (from 3 April 2018) Homelessness Code of Guidance 17.2)
33. Homeless applicants have the right to challenge certain decisions councils make by using a statutory review procedure. The review decision then carries a right of appeal to court on a point of law. Homeless applicants have the right to request a review of the suitability of temporary accommodation provided under the main housing duty. (Housing Act 1996, s202)
34. Homeless applicants must request a review within 21 days of the decision. However, applicants can ask a council to reconsider its decision about the suitability of temporary accommodation at any time. This might be necessary, for example, if their circumstances change. This new decision carries a right of review, with a new 21-day timescale. R(B) v Redbridge LBC [2019] EWHC 250 (Admin)

Miss X’s concerns about conditions in the temporary accommodation

35. During the time period that I have investigated, Miss X lived in two temporary accommodations:

• Accommodation A between July 2018 and May 2019 and
• Accommodation B between May 2019 and June 2020.

36. Miss X complains the Council failed to address her reports of disrepair and infestations in Accommodation A. Based on the evidence I have seen, Miss X did not report any disrepair or infestation issues with Accommodation A between July 2018 and May 2019.
37. Miss X complains the Council failed to address her reports of disrepair and infestations in Accommodation B.
38. Miss X moved to Accommodation B at the beginning of May 2019.
39. Towards the end of May, Miss X contacted the Council to say that she could not stay at the property. She reported the following issues to the Council:

• mould in the bathroom and kitchen
• leaks in the bathroom and kitchen, including water coming through the tiles in the bathroom
• possible flea infestation
• a severe rat infestation
• slugs coming through the shower plughole
• possible faults with the stability of the shower, certain stairs and a ceiling fan.

40. The Council contacted its property management agency, which manages properties on its behalf. The property agency confirmed it had organised a pest control visit. The agency had also arranged for a plumber to address the leaks the next day.
41. Two days later, a Council officer carried out an inspection of the property. The officer sent the property agency a detailed list of repairs and possible mice issues.
42. At the beginning of June, Miss X complained the Council about the disrepair and pest issues with Accommodation B.
43. The Council followed up with its property agency. The agency confirmed all disrepair issues had been resolved and provided photos as evidence of the completed works. The management agency said it had spoken with Miss X to confirm the repairs had been completed.
44. The day after Miss X’s complaint, the Council rescheduled a pest control visit with an alternative pest control team. This was to meet Miss X’s request as she was not happy with the first team.
45. In mid-June, a Council officer carried out a further inspection of Miss X’s property. This was because Miss X said rats were still in the property. The officer checked under the sink and the traps that were still primed and trays of poison laid. Miss X told the officer she last saw mice in the property a week ago when the pest control team last attended the property. The officer decided there were no longer any signs of any rats or mice at the property.
46. Towards the end of June, Miss X asked for a suitability review of her accommodation. She said there were fleas or bed bugs as well as rats at the property. She said the leak coming through the bathroom floor tiles had not been resolved.
47. The property management agency confirmed the leak was resolved as was the rodent issue. It confirmed three treatments had been carried out for rodents. On the fourth visit, the pest control team inspected the property, but found no evidence of rodents, including in the traps that had been put down in the property. The pest control team removed all bait and traps.
48. In early September, the Council reviewed the suitability of Miss X’s accommodation and considered the reasons why Miss X said it was not reasonable for her to occupy the property, including disrepair and pest issues. However, the Council decided the property was suitable.
49. At the end of September, Miss X reported a leak in the roof to the Council.
50. The next day, the property agency told the Council that the leak in the roof had been fixed.
51. Over the next few days, the property agency and the Council were in contact with Miss X to arrange a time to visit the property and carry out further repairs. Miss X said the leak from the roof was unresolved and water was still coming into the property.
52. A few days later, the property agency confirmed the further roof repairs had been successfully completed and it had checked no leaks were present at the property.
53. In early April 2020, Miss X reported issues with rats in Accommodation B. This was during the national lockdown because of COVID-19.
54. At the beginning of June, Miss X chased the Council for a response. She said the disrepair and rat issues were causing her and her family distress and stress.
55. A Council officer called Miss X twice on the same day to arrange a visit with Miss X so that it could inspect the property with the property management agency. Council records of the call show Miss X ended both calls as she was taking legal action.
56. A few days later, Miss X moved to a different temporary accommodation, which the Council had offered her.

Reports of domestic abuse

57. In January 2019, the Council became aware Miss X was living at a women’s refuge. It is my understanding that the perpetrator of previous abuse had located Accommodation A and Miss X fled to the refuge due to an incident of domestic abuse.
58. The Council added Miss X to its temporary accommodation transfer list. 
59. A few weeks later, the Council offered to transfer Miss X to a different temporary accommodation. However, Miss X refused this offer. She was concerned that her identity could become known to the perpetrator of the abuse as he knew the landlord of the property. It is my understanding that Miss X remained on the transfer list after this.
60. In April, Miss X chased the Council for an update. She said that she was still at the refuge.
61. In May, the Council offered to transfer Miss X to Accommodation B. Miss X accepted this offer.
62. In November 2019, Miss X contacted the Council to report a further incident of domestic violence. She said that the original perpetrator had located her again and it was no longer safe for her and her family to stay at Accommodation B. Miss X said that she was struggling to find a refuge to stay in because of the age of her son.
63. Council records show a senior officer in its housing options team replied to Miss X. The senior officer told Miss X that the Council was only able to provide long term accommodation. She said this meant Miss X’s options in these circumstances were:

• Miss X could find suitable accommodation of her choice in the private rented sector in her preferred area. The senior officer said the Council would pay the deposit and rent in advance to secure it; or
• Miss X could approach any council of her choice and the Council would provide information to support her application. This was because it seemed the Council’s area had become a high risk area for her.

64. In January 2020, Miss X contacted the senior officer again. She said that she had been unsuccessful in getting accommodation through other councils.
65. The senior officer replied and restated her previous advice on Miss X’s options. She said the other councils had a duty to accept her application.
66. In March, Miss X contacted the Council again due to fears for her safety at Accommodation B.
67. The Council added Miss X to its temporary accommodation transfer list. 
68. In June, Miss X asked the Council again to assist her. She said she was fleeing domestic violence.
69. A week later, the Council transferred Miss X to different temporary accommodation.

Analysis – was there fault by the Council causing injustice?

Priority on the Housing Register

70. Our role is to decide if there was fault in the way the Council assessed Miss X’s priority under its published scheme.
71. There is a legal duty for the Council to give homeless households, like Miss X, reasonable preference in the scheme. But that does not mean there is a duty to make an offer of social housing. The Council’s 2015 scheme gave homeless households in temporary accommodation reasonable preference by awarding 600 points if they had applied to join the register before November 2012. Some other groups who qualify to join the Register have less than 600 points. So homeless households in temporary accommodation had a head start over them. For this reason, I am likely to find the 2015 scheme complied with the duty to give reasonable preference to homeless households in temporary accommodation.
72. I have considered the Council’s decision by its medical assessment officer from July 2019. I find the Officer considered Miss X’s medical conditions and the evidence she provided. However, she decided to make no medical recommendations about the type of property that would be suitable if Miss X were offered social housing. I do not find the Council at fault here. This is a decision it was entitled to make in line with its housing allocations scheme. Without fault in how the Council reached this decision, I cannot question its content.
73. There is no legal requirement for a scheme to give cumulative preference to a homeless household with more than one reasonable preference housing need, such as homelessness and medical or welfare needs. It is not fault for the Council to adopt a scheme which does not give cumulative points for multiple needs. The Council has discretion to frame its housing allocations scheme in this way.
74. I have considered the Council’s suitability review of Miss X’s temporary accommodation from September 2019. The duty to provide suitable accommodation is an ongoing duty. The Council has a duty to review this where it has reasons to believe that accommodation may no longer be suitable, for example, if an applicant’s circumstances change.
75. I find the Council fully considered the reasons why Miss X had requested a review, which were:

• disrepair issues in the property;
• pest issues in the property;
• carpet on the stairs has pet hair;
• repairs carried out by the landlord’s agent are not satisfactory; and,
• Miss X had not received a direct offer of permanent accommodation.

76. However, the Council decided the temporary accommodation was suitable for Miss X and her family. It provided detailed reasons for this decision. I am satisfied the Council looked at the key matters to consider set out in the Homelessness Code of Guidance for Local Authorities when reaching this decision, including any medical and/or physical needs of the family. I do not find the Council at fault here. I understand Miss X disagrees with decision, but this is not evidence of fault in its decision-making.
77. The Council told me Miss X made no further suitability review requests after this.
78. Miss X told me she was concerned that the Council had reduced her priority due to rent arrears or outstanding charges for her temporary accommodation. She said she was worried this had affected her ability to successfully bid on properties. The Council told me that this was not the case and Miss X’s bidding has not been affected by any such issues. Rather, unfortunately, the reason Miss X has not yet received an offer is because the demand for three-bedroom properties greatly outstrips the housing stock available to the Council. In a call note with Miss X from March 2019, a Council officer told her that the wait time to be offered permanent three-bedroom housing was usually between 12 and 15 years.
79. I understand Miss X’s frustration that she has been on the Council’s housing register since January 2012. However, the Council has limited properties available. The delay in offering Miss X a property during the period investigated is not due to any fault by the Council, it is because of a lack of available properties.

Disrepair and pests in the temporary accommodation

80. The Council has a duty to secure suitable accommodation for homeless households to whom it owes a housing duty. To be suitable, the accommodation must be in a decent state of repair and free from hazards.
81. Miss X complains the Council failed to address her reports of disrepair and infestations in Accommodation A. Based on the evidence I have seen, Miss X did not report any disrepair or infestation issues with Accommodation A between July 2018 and May 2019. I do not the Council at fault during this period. The Council’s last report from Miss X of an issue with the property dated from October 2017. For the reasons explained below, I have not investigated matters dating this far back.
82. The evidence shows there were disrepair and rodent infestation issues in Accommodation B, particularly when Miss X moved into the property. The Council’s property managers responded to these reports by inspecting the property and arranging repairs. From the records I have seen, the Council appears to have taken action each time Miss X reported a defect. In September 2019, it decided Miss X’s accommodation was suitable and provided a detailed response regarding the disrepair and rodent issues.
83. The only exceptions to this are:

• Miss X reported possible bed bugs or fleas in Accommodation B. It is not clear from the Council’s records what action it or the property managers took to investigate this issue. This is fault. This caused Miss X stress and distress about what action, if any, the Council could take here; and
• when Miss X called the Council in April 2020 to report rodent issues, there was a delay of two months before the Council told her it wanted to carry out a joint inspection with its property agency. This delay in communication is fault, which caused Miss X further uncertainty. When the Council attempted to arrange the inspection, Miss X ended the calls as she said she was pursuing legal action. I do not find the Council at fault for not arranging the inspection. It made suitable efforts to arrange this. I have taken this into consideration when assessing the injustice from the original delay.

84. Based on the previous paragraph, I, therefore, uphold part b of Miss X’s complaint.

Reports of domestic abuse

85. In January 2019, when the Council became aware Miss X was living at a women’s refuge, it added Miss X to its temporary accommodation transfer list. The transfer request form completed by Council officers shows that the reason for the transfer was due to domestic violence. It stated that Miss X should be moved as soon as possible.
86. Councils have a duty to keep the suitability of accommodation under review. The Council did not make a clear decision on the suitability of Accommodation A and communicate this to Miss X. However, in my view, the Council accepted the accommodation was unsuitable by placing Miss X on the transfer list due to the risk of violence or domestic abuse there.
87. The Council offered Miss X alternative temporary accommodation a few weeks later. When Miss X refused this accommodation, it is my view that the Council exercised its discretion to withdraw the offer rather than end its duty to Ms X. I do not find the Council at fault here.
88. The Council transferred Miss X to Accommodation B in May 2019. This delay is fault. The law is clear that the Council has a duty to provide accommodation to homeless applicants which is suitable. The courts have said the duty to provide suitable temporary accommodation is “immediate, unqualified and non-deferrable”. Miss X was left without suitable temporary accommodation for a period of three months due to the fault identified. By finding a refuge to stay in, Miss X mitigated some of the injustice that would otherwise have been caused by the Council’s failure to provide suitable temporary accommodation.
89. In the Council’s stage two complaint response, it accepted that, in November 2019 and January 2020, the senior officer in its housing options team failed to fully consider Miss X’s reports of domestic violence and offer other temporary accommodation. This fault caused Miss X distress and uncertainty. She went to time and trouble asking the Council to transfer her to a different property.
90. The officer told Miss X to approach other councils for help with accommodation. Miss X has a local connection to the Council area and it has accepted a main housing duty to her. This means it is the Council which has responsibility for securing suitable accommodation for Miss X. Therefore, this advice was wrong, and Miss X went to avoidable time and trouble approaching other councils as a result. This is an injustice to Miss X.
91. Miss X was later placed on the Council’s transfer list in March 2020. The Council’s records of its decision show the reason for the transfer was due to domestic violence. The records stated that Miss X should be moved as soon as possible. The records say it was not safe for Miss X to remain in Accommodation B and she had no alternative accommodation to stay in. Again, I find the Council accepted the accommodation was unsuitable as a result.
92. If the Council’s senior officer had properly handled Miss X’s reports of domestic violence, Miss X would have been placed on the transfer list much sooner. On balance, it is likely Miss X would have been offered suitable accommodation much sooner than June 2020. I find this fault meant Miss X missed out on suitable accommodation for a period of six and a half months.
93. Based on the above, I have decided to uphold part c of Miss X’s complaint.
94. Given the Council had accepted fault in its handing of Miss X’s initial reports of domestic violence at Accommodation B, I asked the Council for more information about the changes it had made to improve practices. It has taken the following actions:

• launched its Housing Advisory Service (HAS) in October 2020, which brings together for the first time all aspect of the Council’s prevention, assessment, procurement and property management functions into a single service;
• appointed a Safeguarding Lead Officer in the restructured HAS. This Officer is based in the Council’s new Resilience Team;
• the Resilience Team works with service users who have fled home due to domestic abuse and supports them into safe accommodation. The team are trained in completing Domestic Abuse, Stalking and Honour based violence risk assessments and safety planning;
• HAS arranged Domestic Abuse training between September 2020 and March 2021 for around 400 staff across homelessness, housing management, repairs and call centre teams; and,
• all new staff complete mandatory safeguarding children and safeguarding adults awareness training.

95. I am satisfied the Council has made sufficient service improvements since Miss X’s complaint regarding its handling of reports of domestic violence.

Complaint handling

96. Miss X complains the Council failed to fully respond to the complaints made and brought them altogether in one complaint response.
97. For parts a to c of Miss X’s complaint, I have considered the Council’s complaint response, particularly its stage two complaint response. I find the Council fully responded to Miss X’s complaints. I do not find it at fault for bringing these previously separate complaints into one, clear response.
98. In its stage two complaint response, the Council incorrectly referred Miss X to the Housing Ombudsman. This was fault. Miss X was put to unnecessary time and trouble referring her complaint to the wrong Ombudsman scheme.
99. Miss X complains the Council failed to respond to other parts of her complaint. These complaints, made between August and September 2019, concerned:

• the Council sending Miss X a notice to quit warning in August 2018. I find the Council fully responded to this complaint in October 2019. I do not find the Council at fault here;
• a phone call with an officer who was working from home. I find the Council fully responded to this complaint in September 2019. I do not find the Council failed to respond to Miss X’s complaint. A different Council officer apologised for any distress caused by the call and said that she would raise the matter with the relevant officer when she was back from leave;
• advice given by a Council officer to Miss X about an offer of temporary accommodation. She said the officer had told her to pack her belongings and vacate Accommodation A as Miss X was able to stay in the women’s refuge until March 2019. Based on the evidence provided, I have not seen a clear response from the Council on this part of Miss X’s complaint. This is fault, which caused Miss distress and uncertainty.
• a regeneration scheme and the behaviour of several Council contractors, including potentially racist acts. Based on the evidence provided, I have not seen a clear response from the Council on this part of Miss X’s complaint. This is fault, which caused Miss distress and uncertainty.

100. Based on the above identified fault, I have decided to uphold part d of Miss X’s complaint.

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Agreed action

101. Within four weeks of my final decision, the Council has agreed to:
1. apologise in writing to Miss X for the fault causing injustice;
2. pay Miss X £100 for each month for the three months that she remained in unsuitable accommodation between February and end of April 2019. This comes to £300 in total;
3. pay Miss X £200 for each month for the six and a half months that she was in unsuitable accommodation between end of November 2019 and early June 2020. This comes to £1300 in total; and,
4. make Miss X a payment of £300 for the distress and uncertainty caused by the injustice.
102. The Ombudsman will need to see evidence that these actions have been completed.

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Final decision

103. I have completed my investigation.
104. I do not uphold part a of Miss X’s complaint. This is because I have seen no evidence of fault by the Council causing injustice.
105. I have decided to uphold parts b to d of Miss X’s complaint. This is because there is evidence of fault by the Council causing injustice. The above recommendations are suitable ways for the Council to remedy this, which it has agreed to.

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Parts of the complaint that I did not investigate

106. The law says we cannot investigate late complaints unless we decide there are good reasons. Late complaints are when someone takes more than 12 months to complain to us about something a council has done. (Local Government Act 1974, sections 26B and 34D, as amended)
107. Miss X complained about matters dating back to 2012. She explained to me the reasons why she did not complain to the Ombudsman sooner and I have considered her reasons.
108. In Miss X’s case, I think that she could have complained sooner if she had wished to pursue matters from 2012 to June 2018. Given the amount of time that has passed and the likely difficulties with obtaining records from so long ago, I do not think I could confidently reach a clear enough view on the issues Miss X has raised. I have, therefore, decided not to investigate any earlier than July 2018.

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Investigator's decision on behalf of the Ombudsman