Housing – Anti Social Behaviour and Hate Incidents

1.1 Context

The reported crime figures show that our district remains one of the safest places to live and work in the UK.

As a social landlord we deal with low levels of anti-social behaviour (ASB) compared to other landlords. Where incidents do occur, they are what are is considered low level incidents with the most common reports being noise such as music being played/other household noise, litter or rubbish being left including in gardens and communal areas and incidents relating to pets.

1.2 Aims and Purpose of this Policy.

Housing Services is committed to preventing, tackling and managing ASB and hate incidents in accordance with the Housing Regulator’s Standard.

As a landlord, we have a duty, under the Anti-social Behaviour Act 2003 to respond to ASB affecting the properties we manage. We now have a range of additional powers to take action against those causing ASB under the Anti-social Behaviour, Crime and Policing Act 2014.

Our approach focuses on tackling ASB/hate crimes that either affects or is carried out by people living within our stock and the communities we serve. This includes tenants and leaseholders, their family members (including children) or friends, owner-occupiers, lodgers or private tenants.

This policy is consistent with our Domestic Abuse Policy and where appropriate should be read in conjunction with it.

1.3 What is anti-social behaviour?

The Antisocial Behaviour, Crime and Policing Act 2014 defines anti-social behaviour (ASB) as:

(a) conduct that has caused, or is likely to cause, harassment, alarm or distress to any person,

(b) conduct capable of causing nuisance or annoyance to a person in relation to that person’s occupation of residential premises, or

(c) conduct capable of causing housing-related nuisance or annoyance to any person.

Incidents are usually grouped into one of three categories: environmental, nuisance and personal.

1.4 What does not constitute Antisocial Behaviour?

Individuals have a right to enjoy their homes and are entitled to go about their daily lives without having concerns that complaints will be made against them. Therefore, not all behaviour which impacts on one or more other individuals will constitute ASB.

Examples of situations which do not constitute ASB include:

• Low-level neighbour disputes
• Day to day living noise which is not excessive or unreasonable
• Children playing
• Occasional dog barking
• Banging doors
• Conversation heard through walls or floors
• Neighbours walking around their home
• Normal domestic activity such as vacuuming or using washing machines
• Disagreements about parking
• Personal disputes between tenants/leaseholders and their neighbours (unless tenancy/lease/licence conditions are broken)
• People getting together to socialise
• Normal vehicle noise

If residents are affected by these, they are advised to discuss the situation with the person causing the problem, where it is safe to do so. If this is not possible, they can talk to the relevant officer in housing (see 2.3) for advice. Where appropriate independent mediation service may be advised.

1.5 What constitutes a Hate Incident?

The law recognises five types of hate incidents/crimes on the basis of:

• Race
• Religion 
• Disability
• Sexual orientation 
• Transgender identity

There is no legal definition, but the police and the Crown Prosecution Service have agreed the following definition:

“Any criminal offence which is perceived by the victim or any other person, to be motivated by hostility or prejudice, based on a person’s disability or perceived disability; race or perceived race; or religion or perceived religion; or sexual orientation or perceived sexual orientation or transgender identity or perceived transgender identity.”

1.6 Tenants Responsibilities

Our tenancy agreements contain a section relating to Living in the Community. This makes it clear that tenants must respect other people who live in their neighbourhoods. It clearly states that tenants are also responsible for the behaviour of members of their household (i.e., all persons living at the property) and visitors (his includes visiting relatives / carers), to their property and the locality and must not cause or threaten to cause, a nuisance, annoyance, or disturbance to anyone else in the vicinity. They also must not harass any person including another tenant, visitor, and neighbour, member of staff, council contractor or lawful visitor to the area.

In addition, they must “not to cause, or allow, any noise which might cause a nuisance to neighbours and others in the vicinity.”

If tenants fail to respect the terms and conditions of their tenancy agreement, this can constitute a breach of their tenancy agreement.

1.7 Our Aims

We recognise that both ASB and hate incidents can have a disruptive effect on neighbourhoods, communities and individual lives.

In tackling ASB/hate crimes we will:

• Invest in communities where we have housing stock so that they are areas where people want to work and live.
• Offer different ways to report ASB and hate crimes.
• We will grade cases into priorities to ensure more serious cases are dealt with quicker than non-serious cases (see pages 9-10).
• Be accessible and open to complainants about what we can and cannot do, what will happen and why, and possible outcomes.
• Offer support and advice to both complainants and perpetrators.
• Place emphasis on initial assessment, risk assessment and early intervention with the complainant and alleged perpetrator.
• Work in partnership with other agencies to reduce and tackle incidents and support residents. Including the Safer Wealden Partnership.
• Invest in staff training, ensuring all staff involved have up to date training.
• Invest in IT solutions to manage cases.

We recognise that ASB can have a huge impact on people’s lives, even low-level incidents. It is therefore essential that we support complainants to access support services.

2.1 Sanctuary – property security works

The council runs a sanctuary scheme which is a victim-centred initiative that aims to make it possible for victims of domestic violence, other physical violence or hate crimes to remain in their homes and feel safe, if a risk assessment deems it appropriate to do so and/or the victim so wishes.

It provides an alternative to relocation away from family and friends, vital support networks and key services.

The scheme is able to provide the installation of enhanced security measures in a victim’s property. These can range from additional locks for doors and windows, to window grills and in extreme cases, a safe room (sometimes known as target hardening). It is free of charge for victims and the Housing Services will pay for the works.

The scheme is available to women and men, with or without children.

The relevant officer in housing will make referrals into the service where these works are deemed necessary.

2.2 Agencies and websites which provide advice, information, support:

We understand that ASB/hate incidents can have a detrimental impact on people’s lives. We also understand that people are reluctant to report incidents for many reasons and therefore we aim to support complainants throughout the process. We work with other agencies and in some cases with the complainant’s agreement can make referrals for support.

In addition, there are a number of other organisations that complainant s can contact directly themselves.

• ‘ASB Help’ is an organisation which provides information, advice and signposting to other services of you are you suffering with noisy neighbours? Are people making your life a nightmare thanks to their behaviour? Are you unsure where to turn? Or have you reported it, and no-one seems to be listening?

Visit: www.asbhelp.co.uk or email: admin@asbhelp.co.uk or call: 0800 803 804

• Victim Support’ offer help if you have been affected by crime or ASB. They run a 24/7 support help line and have an ‘online chat’ available on their website.

Visit: www.victimsupport.org.uk or call: 08081 689111

• Information, help and advice on antisocial behaviour is available on the Government Website.

Visit: www.direct.gov.uk/antisocialbehaviour

• ‘The Law Society’ can help you find a solicitor in your area:

Visit: www.lawsociety.org.uk

• ‘Support Line’ offer confidential emotional support for anyone who needs it.

Visit: www.supportline.org.uk or call: 01708 765200

• To report harmful content online and for advice on reporting harassment, threats, impersonation, online bullying, unwanted sexual advances, pornographic content etc. visit the Report Harmful Content web pages.

Visit: www.reportharmfulcontent.com

• Samaritans – 24-hour free helpline, particularly if you are suffering with mental health and/or thoughts of suicide.

Visit: www.samaritans.org or call: 116 123

3.1 When to Make a Report

If it is not possible for a complainant of ASB to resolve an issue for themselves, if the ASB gets worse, or if there is a serious incident, then a report should be made to the Housing Service.

All hate incidents and domestic abuse as well as other personal incidents such as physical attacks are potentially criminal offences and as such should be reported to the police and to us Housing Services.

3.2 How to make a report:

This can be done in writing to: Housing Services, Wealden District Council, Council Offices, Vicarage Lane, Hailsham, East Sussex, BN27 2AX.

By telephoning: 01323 443322.

In person: By visiting the Council offices at the address above.

By emailing: housing@wealden.gov.uk or

By completing the online reporting form: www.wealden.gov.uk/housingforms

If there is an immediate threat call the Police on 999.

3.3 Who manages ASB?

Temporary Accommodation

The Temporary Accommodation Co-Ordinator is responsible for managing and resolving cases of ASB in our temporary accommodation.

Retirement Living

The Retirement Living Court Manager is initially responsible for managing cases of ASB, in conjunction with the Supported Housing Team Leader. If an ASB case becomes more complex the case is referred to the appropriate Housing Officer (general needs) who then becomes the lead officer.

General Needs

The Housing Officers are responsible for managing cases of ASB in conjunction with the Housing Services Team Leader.

Leaseholders

Within our housing stock there are Right to Buy general needs leasehold flats (these may have been subsequently re-sold) and retirement living shared ownership leaseholders.

Where a leaseholder is a complainant or an alleged perpetrator the Housing Officer in conjunction with the Leasehold & Right to Buy Officer takes responsibility for examining the lease and considering what actions are appropriate. This may include taking advice from Legal Services.

4.1 Prioritisation

All complaints received are categorised by the relevant officer into levels of seriousness in terms of impact, frequency and level of risk.

Priority 1

• These are the most serious cases, such as domestic violence, hate incidents or harassment. In such cases the Housing Officer must inform the team leader or in their absence the Housing Services Manager of the case immediately. In many instances the police would have already been contacted. The complainant must be visited within 24 working hours of reporting the incident. A risk assessment will be completed at this time and, if the risk is high, a joint meeting will take place with the police within 48 working The Housing Allocations Team will be included in the meeting if the resident needs to be moved.

In some instances, these cases may have already been reported to the police before being reported to us.

Priority 2

• All other cases of ASB will be classed as priority 2. This means that the relevant Housing Officer must contact the complainant within 5 working days, either in person or by phone.

As appropriate the relevant officer in housing will:

• Work with the complainant to draw up an agreed action plan to investigate the matter, including how any identified support needs will be meet.
• Normally issue nuisance diary sheets in order to collate evidence. The relevant officer in housing will explain how to complete these and how they will be collected, returned and used.
• Provide support and signpost to agencies who can provide complainants with further advice and/or support.

Criminal activities

In all reports of ASB that constitute criminal activities we will expect the complainant to report this to the police (this includes all hate crimes and domestic abuse). Whilst the police may be responsible for investigation and any criminal prosecution, Housing Services will work with them and continue to support complainants and perpetrators.

4.2 The Investigation Stage

Each case will take a different route; however, this sets out a guide as to the steps we will take:

• The relevant officer in housing will begin to gather evidence including interviewing the alleged perpetrator/s and/or any witnesses. This may include anonymous door knocking.

As part of the investigation, the following might be undertaken:

Community Impact Assessment

When investigating a complaint of ASB it may be necessary for the relevant officer in housing to consider its wider impact on other members of the community and whether the ASB is of a discriminatory nature. Particularly, in relation to its impact on people with regards to one or more of the 9 protected characteristics:

• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race
• Religion or belief
• Sex
• Sexual

Community Harm Assessment

When a complaint of ASB is made it is sometime necessary for the relevant officer in housing to visit other members of the community to see if they have experienced any issues of ASB. Any additional complaints/evidence will help to build a case against a alleged perpetrator of ASB. 

• The relevant officer in housing will consider the range of early intervention options available. Examples would include mediation, warning letters, Acceptable Behaviour Contracts and referral to an appropriate agency.
• Subject to the nature of the ASB the relevant officer in housing will speak to the alleged perpetrator to try and get them to rectify their unacceptable behavior. In the most serious cases this will not be an option and legal action in conjunction with the police will be explored.
• In some cases, it will be necessary to involve other agencies, such as Environmental Health, particularly in cases of noise nuisance. For example, they can work with us to use equipment to record noise levels.
• Both the complaint and alleged perpetrator will be sign-posted to relevant support agencies and will receive guidance from the relevant officer in housing.
• It is not unusual to receive counter allegations of ASB. Such allegations will be investigated in the same way.
• Cases will be reviewed on a regular basis, and complainants and perpetrators will be kept informed of developments.

The Council will carefully consider each case individually and will take into account the requirements of the Equalities Act 2010.

We will put the needs of complainants and witnesses first. However, any actions that we take will depend upon:

1. and be appropriate and proportionate to the nature of the ASB.
2. any vulnerabilities that the complainants or perpetrators may have.

A complainant or alleged perpetrator may be vulnerable for many reasons including physical or mental health, use of or dependency on drugs and/or alcohol, financial problems or circumstances such as ASB. Therefore, complainants or perpetrators may be referred to an appropriate support agency or statutory agency (e.g., Adult Social Care or appropriate NHS service) and/or the Housing Services own Tenancy Support Officer. We will work in partnership with other agencies in order to deter or prevent ASB and to rehabilitate those who have engaged in such behaviour. In these cases, a multi-agency approach will be taken. However, we will take enforcement action where perpetrators fail to engage with support services and/or where behaviour does not improve to an acceptable level.

The Council as a landlord will ensure that its approach to dealing with ASB is transparent, consistent and accessible. We value diversity and are committed to promoting equality of opportunity to ensure all residents are treated fairly.

If interpretation is required for face to face meetings, staff will ensure this is provided at appropriate junctures. Letters will also be translated as necessary.

All complainants and perpetrators have the right to have a third party represent them throughout a report of ASB.

6.1 Types of ASB (including hate incidents) and Possible Remedies for tackling them

6.2 Remedies for Tackling ASB and hate incidents

There are a large number of remedies available for tackling ASB, which one/s are appropriate will depend on the type of ASB and severity of the case. Remedies available include:

Talking to the alleged perpetrator:

The first step is usually the relevant officer in housing will speak to the alleged perpetrator as they might not even be aware of the effect of their behavior. If they are aware, sometimes a visit from a Council Officer can end that behavior.

Mediation:

In some cases, particularly neighbourhood disputes, mediation is an effective way of resolving problems. The Council can make a referral or residents can refer themselves. The service is free, informal and confidential. It is a voluntary process but can help resolve issues by reaching a mutually acceptable solution. It aims for a win/win situation and lets residents decide together what happens.

Intensive Support:

In some cases, either the complainant or alleged perpetrator needs support to resolve the situation. The relevant Officer in Housing will identify these cases and make appropriate referrals to relevant support agencies including mental health services. Alternatively, they may refer the case to the Tenancy Support Officer to ensure an intensive and joined up support package is put in place.

Tenancy Conditions enforcement – warning letters and notices:

ASB is a breach of tenancy agreement terms and as such we may take action     to enforce these. Warning letters may initially come from the relevant officer in housing asking that the behavior/situation stop and explaining how it contravenes tenancy conditions. Warning letters will escalate as necessary, until they come to the Council’s solicitors.

If warning letters fail, an Introductory Tenancies tenant/s who commits ASB could be served an extension to their introductory tenancies by 6 months. Secure or Flexible Fixed Term Tenancies could be served a Notice of Seeking Possession and introductory or non-secure tenancies a Notice to Quit. If this has failed to address the situation/behavior, then it is possible to apply to the court for an eviction (possession is mandatory for non-secure and introductory tenants). 

Management Transfers:

In exceptional circumstances it may be agreed that a management transfer is the best option to address the ASB. Wealden’s Allocations Policy allows this to happen, but only where there is agreement between the Housing Services Manager and Housing Options and Strategy Manager. All such transfers will go into Band B and will only be eligible for a property of the same size and type.

Demoted Tenancy:

Demotion is an alternative to possession proceedings where a tenant is causing nuisance through antisocial behaviour. The tenant does not lose her/his home and can regain her/his original tenancy and security of tenure after 12 to 18 months. However, a demoted tenant has less rights than other tenants.

We can apply to court to demote a tenancy where the tenant, or someone living with or visiting the tenant, has:

• engaged or threatened to engage in antisocial behaviour, or
• used or threatened to use the property for an unlawful purpose.

Closure Notices and Order:

Closure Notices and Orders are formal sanctions that allow the police and the council to quickly close premises which are being used or are likely to be used to commit nuisance or disorder.

A Closure Notice can close premises for up to 48 hours whilst arrangements are made for a formal application to a local Magistrates’ Court for a Closure Order. A Closure Order can keep premises closed for up to 3 months. They can apply to any land or any other place including residential businesses premises, business premises non-business premises and licensed premises.

Criminal Behaviour Order (CBO)

A criminal behaviour order is an order made in the criminal courts for ASB. It prohibits the offender from doing anything described in the order. They are only available on conviction of a criminal offence by any criminal court. They are designed for more serious offenders, who engage in criminal activity as well as antisocial behaviour.

Statutory Nuisance

Councils must investigate complaints about issues that could be a ‘statutory nuisance’ (Environmental Protection Act 1990). Within Wealden this is dealt with by the Environmental Health team. If they agree that a statutory nuisance is happening, has happened or will happen in the future, they can serve an abatement notice on people responsible for statutory nuisances, or on a premises owner or occupier if this is not possible. This may require whoever’s responsible to stop the activity or limit it to certain times to avoid causing a nuisance and can include specific actions to reduce the problem.

What can be a statutory nuisance?

Issues that may be a statutory nuisance include:

• noise from premises or from vehicles, equipment or machinery in the street
• smoke from premises
• smells from industry, trade or business premises
• artificial light from premises
• insect infestations from industrial, trade or business premises
• accumulation or deposits on premises.

For the issue to count as a statutory nuisance it must do one of the following:

• unreasonably and substantially interfere with the use or enjoyment of a home or other premises
• injure health or be likely to injure health

Injunctions

Under the Antisocial Behaviour, Crime and Policing Act 2014 Wealden District Council as a local authority can apply for an injunction to prevent nuisance or annoyance which can be granted by the county court against any person aged 10 or over if it is satisfied, on the balance of that:

• a person has engaged, or threatens to engage, in antisocial behaviour, and
• it is just and convenient to grant the injunction for the purpose of preventing that person from engaging in antisocial behaviour.

Civil Action

Anyone affected by nuisance has the right to take private action to resolve the problem independent of the Council.

6.3 Remedies Involving and protecting the community

There are a range of other actions that are available including:

Community Protection Warnings (CPW)

We regularly issue community protection warnings. These can be issued to any individual aged 16 or over, or a body, if we are satisfied on reasonable grounds that:

• the conduct of the individual or body is having a detrimental effect, of a persistent or continuing nature, on the quality of life of those in the locality; and
• the conduct is unreasonable.

The CPW imposes any of the following requirements on the individual or body issued with it:

1. A requirement to stop doing specified things
2. A requirement to do specified things
3. A requirement to take reasonable steps to achieve specified results.

Community Protection Notice (CPN):

If a CPW is not effective we may issue a CPN, if the conduct continues and is:

• having a detrimental effect on the quality of life of those in the locality
• persistent or continuing in nature, and
• unreasonable

There is no restriction on the type of behaviour a CPN can deal with, for example it can deal with noise nuisance, rubbish in gardens, littering etc. Failure to comply with the CPN can lead to:

• Fixed Penalty Notices
• Remedial Works
• Court Orders

Community Trigger

If the incident has been reported three times or more within a six-month period and a satisfactory response is not received, the Community Trigger can be activated. This gives those affected by ASB the right to demand that agencies deal with persistent antisocial behaviour. This will activate a multi-agency case review in an attempt to ultimately fix the problem and stop the ASB.

Community Remedy

The Community Remedy is intended to give those affected by low-level crime and ASB a say in the punishment of perpetrators out of court. Their involvement is entirely voluntary, and all reasonable steps will be undertaken to find out the views of those affected. When this is not possible, or those affected do not wish to be involved; the responsibility will fall to the officer to choose an appropriate action.

Multi Agency Approach.

The Housing Service is an active member of partnerships such as the Joint Action Group set up to tackle issues such as ASB and safety in Wealden. ASB, which impacts on the community will be discussed at JAG so that a joined up multi-agency approach can be agreed and implemented for tackling the problems.

The Housing Service also works closely with other agencies such as the police and Environmental health, as necessary to tackle ASB.

6.4 Legal Action

Not all cases of ASB/hate incidents will require legal action to be taken. Some may proceed to court led by the police as criminal offences; others may proceed to court led by the council as the landlord.

However, should this action be necessary the relevant officer in housing will discuss this with the complainant. There are limited legal remedies available which don’t involve complainants attending court. Therefore, they may be required to attend court as a witness. Where court action arises from Council lead action the structure of the legal system is such that it is a judge who has the final say over whether a tenant is evicted for ASB. For criminal activities it is a magistrate or judge who decides whether to convict and impose a legal sanction depending upon the severity of the offence.

Where legal action is housing led Housing Services will need to ensure that all relevant early intervention options have been used and / or properly considered. Failure to do so may result in legal action being ultimately unsuccessful. This alongside the likely cost of the case and the likelihood of success will influence Housing Services’ decision as to whether legal action is justified.

Proportionality:

Any decision to take formal legal action will be accompanied by a review of the proportionality of the action, taking account recent case law, the Human Rights Act 1998 and the Equalities Act 2010.

During the preparation for a court date, it is important to continue to gather evidence and ensure regular contact with complainant s and witnesses who may feel vulnerable about the prospect of appearing in court. Under the direction of legal services, the relevant officer in housing will be required to prepare their own statement as well as collecting statements from complainants and witnesses.

Following legal action, there will be a range of outcomes. Firstly, the case may be successful e.g., injunction obtained, undertaking obtained, or possession order grated and as a result the ASB is resolved, and the case closed, and publicity considered.

However, if the legal action is not successful and if ASB continues following court action the case may be referred back to legal services for advice. Other options such as a management move may also be considered if legal action is not successful.

We aim to bring all cases to closure as soon as possible. However, some cases can be quickly resolved whilst others that require court action can take a long time, potentially years to reach a conclusion.

A case may be closed at any stage of the process. This could be:

• When the complainant does not want it taken any further
• Where there have been no further reports of ASB within 10 working days
• Where the issue has been resolved
• Where no further action can be taken by the Council

Case closure will usually be carried out with the agreement of the complainant s and witnesses and after a review of the case. However, if the complainant or witnesses do not agree, the case may still be closed with a full explanation being given to the complainant as to why. This does not prevent a case being re-opened or a new case being started should any new instances of ASB be reported or if new relevant evidence is provided after a case has been closed.

8.1 Recording and Monitoring

The Housing Service uses a case management system which has been tailored to our procedure to record and monitor all cases of ASB and hate incidents. Additionally, a secure system is used to obtain and share information on ASB across partners e.g., police.

8.2 Feedback and Complaints

Once a case is closed a survey will be sent to the complainant (except in cases of domestic abuse where the perpetrator is still living with the complainant). This is being done to monitor the service being provided by us.

The housing service also encourages all customers to use the housingfeedback@wealden.gov.uk email address to give any feedback on any service that they have received from the housing service.

Any complaints about how a case of ASB/hate incident has been handled will be dealt with through the Council’s complaints procedure. Complaints Procedure

All feedback and complaints are reviewed and used to inform changes to the service. One relevant example is this guide which incorporates our policy and procedure and complaints remedies into one document.

8.3 Performance

In managing cases of ASB/hate incidents we collect and can report on a number of measures including, but not limited to:

• Cases opened
• Case closures
• Cases by type of complaint
• Case outcomes

In addition, we are required to report back to the Regulator for Social Housing on an annual basis a number of Tenant Satisfaction Measures (TSMs) including: the Number of:

• anti-social behaviour cases, of which
• anti-social behaviour cases that involve hate incidents

opened per 1,000 homes.

We will be publishing a report on the results of all our TSMs on an annual basis and reporting back the results to our tenants and leaseholders via our newsletters and the website.

We report performance data as well as the results of our case closed survey to tenants and leaseholders on our website and via our newsletters. We also report performance data in our annual Tenant and Leaseholders Report. In addition, we have a Complaints, Performance and Customer Feedback panel that meet 3 times a year.

8.4 Publicity and Promotion

We will ensure regulator communication on ASB and hate incidents with our tenants and leaseholders through publications such as Threshold our newsletter, our monthly e-news update and our annual report to:

• ensure that tenants and leaseholders know what ASB/hate incidents is and how to report it
• send a clear message we will not tolerate any form of intimidation, harassment, discrimination or victimisation because of a person’s age, gender, sexual orientation, disability, race, nationality, ethnic origin or religion.
• manage expectations of what we can and can’t do
• be clear on the range of powers that we have and
• publicise any success cases e.g., where we have taken legal action
• feedback performance data

8.5 Confidentiality and Data Sharing

Wealden’s Housing Service treats all reports of ASB and hate incidents confidentially. This means that we will not tell the alleged perpetrator who has made the compliant against them. However, in some cases it will be obvious who has complained.

We may share personal information about cases of ASB with third parties but only for the following purposes:

• prevention and/or detection of a crime/ fraud or we are otherwise legally required to do for example the Crime & Disorder Act 1988 for the purposes of ASB or other behaviour adversely affecting the local community
• where it is in the public interest or the Council’s legitimate interests to do so
• in the interest of safeguarding the complainant/s and/or perpetrators or others

If we wish to use or share your information for any other purposes, we will seek your consent.

8.6 Staff Training

All staff involved in dealing with ASB cases/hate incidents will receive appropriate training. Training will be ongoing to ensure that they are up to date on best practice and legislation and case law. Staff will also receive other relevant training such as trauma informed practice to ensure they have the skills needed to carry out their role effectively.

8.7 Review of this policy & procedure

We will review this policy and procedure at least every three years to ensure that it complies with best practice and/or legislation. In undertaking a review, we will:

• Consult and involve residents.
• Use the results of our case closed survey.

to ensure, as far as possible, that it meets residents and our needs.

8.8 Data Protection 

“Wealden District Council is committed to ensuring that your privacy is protected and will only use and store your personal data in line with the UK General Data Protection Regulation 2021 and Data Protection Act 1998. We will not disclose your personal data to any third parties, unless we need to do so to provide a service to you or we are legally required to do so. We may share your personal data with other Council departments in order to provide the service you have requested.

Our Privacy Policy sets out how we collect, use and securely hold you data as does the privacy notice for public sector landlords