Accurate and timely data underpins our engagement with providers. We consider failure to manage data integrity to be indicative of a poor internal controls assurance framework.
Failure to provide accurate and timely data that meet regulatory requirements will be reflected in the judgement of a provider’s compliance with regulatory standards.
The quotation above, taken from the most Sector Risk Profile, produced by the Regulator of Social Housing (RSH), emphasises the current focus within the sector on being able to demonstrate effective data management in all areas, including property compliance. Data management has been on the RSH’s radar for some time and continues to play a pivotal role in their assessments of a landlord’s performance. We believe this is not going to change and will grow in importance as the requirements of the Building Safety Bill become law.
First and foremost is ensuring resident safety. It is often the case that the failure to collect and maintain quality data about tenants properties results in ambiguity around what statutory checks are required and at what frequencies; or a breakdown in the process of ensuring any remedial works required to ensure a property is safe are completed. As a result, providers are unable to demonstrate that they are aware of the risks to their tenants and that they are taking appropriate action to mitigate them. Good quality data, which is accurate and periodically reassured, helps providers to proactively address these risks and prevent them from falling foul of their statutory obligations.
Registered providers collect considerable volumes of data on a monthly, weekly and even daily basis – knowing how to leverage the opportunities this presents is pivotal to ensuring both tenants and the organisation benefits. This includes logically structuring data, regularly assuring its reliability and utilising the power of analytics and reporting to: quantify performance, take action when falling short, and predict future obstacles.
Whenever our consultants work with landlords to validate their compliance data, we assess against several of core principles to gauge current performance and then structure an action plan for improvement.
Often providers struggle to quantify exactly how many properties they own or can not verify if the reported number is accurate due to the number of systems they have in place. An example is where a central housing management system is in place and supported by separate compliance systems. Whilst this in itself is not necessarily an issue, it is when these systems are not reconciled which causes discrepancies and misalignments. It is often the case that one system is updated following a stock movement but the changes are not mirrored across the others – all systems must be reconciled regularly to ensure there is clarity on exactly how many properties an organisation owns.
All compliance programmes should be reconciled against the total number of properties. Not only will this assure all properties are captured on the relevant programmes, but it will also allow the opportunity to investigate and explain those which aren’t. Evidencing and explaining why properties aren’t on a particular programme is a key component of fully assured and reliable data.
Once the compliance programmes have been reconciled it is imperative to ensure that the data used to drive them is accurate. An effective means of doing this is to undertake a sample audit of compliance records for each programme to test whether the information on the physical records matches what has been recorded electronically.
Accurate and reliable data can be leveraged to inform decisions made when planning, delivering and reviewing the compliance programmes. Structured and concise reporting ensures the correct information is communicated to the right people. In this way, appropriate action can be taken to address any non-compliance and pre-empt potential tenant safety issues.
Provided the correct information is included, this reporting assures leadership teams and Board that; assets are included on the appropriate compliance programmes, inspection records and inspection data are in place and accurate, and the systems which underpin the management and delivery of each compliance programme are robust and fit for purpose.
The upcoming changes from the Building Safety Bill have been well documented and it is no surprise that the data obligations the ‘golden thread’ will place on providers will be far more onerous than those currently required from a statutory compliance perspective. The Golden Thread of Information will be a live digital register that must contain accurate and up-to-date information on how a building was designed, built and is being maintained. The Building Safety Regulator will be able to access this document to ensure all building safety requirements are being met and identify, and hold the accountable party responsible if they are not.
With these changes on the horizon, organisations should be viewing the assurance of their compliance data as key preparation in ensuring they are prepared for how future data is managed, assured and reported.
Most often, organisations have a lot of the requisite data in place but are not equipped with the tools or resources to leverage its benefits.
At Pennington Choices, working with landlords we guarantee the safety of tenants via assurance of their compliance data and providing the tools to maintain integrity moving forward.
Our diverse and experienced consultancy team is built-up of technical experts that work across fire safety, gas safety, electrical safety, asbestos management and water hygiene, to put in place practical solutions to any shortfalls that they may come across.