TSMs: How Your Data Management Approach Can Impact Compliance

With the Tenant Satisfaction Measures (TSMs) officially in force, landlords must now start collecting their data and preparing to report a wide range of related performance information. The TSMs are measures introduced by the Regulator of Social Housing (RSH) to assess the quality of housing and services that social housing landlords are providing to their tenants. They aim to enhance the wellbeing of tenants by ensuring their voices are heard, their complaints are handled effectively, and they live in safe, good quality homes. There are 22 TSMs in total, covering complaints, neighbourhoods, anti-social behaviour, repairs and safety- click here to view official government guidance outlining each measure in detail.

What does the TSM timeline look like moving forward?

What do the TSMs mean for compliance?

Amongst the various TSM elements, building safety is a hot topic. The TSMs change the way that landlords have to report on compliance now that the focus is on the number of dwellings at risk, a significant shift when looking at how most organisations have been reporting in previous years.

When reporting your performance to meet with the TSM requirements, your data needs to be accurate and reliable. Having worked with over 300 housing organisations, we have developed detailed knowledge and insight into the most common data pitfalls and how best to address them.

1. Define your data structure

Starting strong, data structure is the key to being able to demonstrate effective data management and is pivotal to understanding exactly how many assets your organisation owns and where your compliance obligations lie – an important requirement under the TSMs. Toidentify the dwellings at risk within each block you will need a clear division between yourdomestic properties (e.g., houses, flats, maisonettes etc.) and non-domestic properties in your structure. Most often, landlords can readily extract a domestic asset list, but the challenges typically come from non-domestic property lists, particularly communal blocks. It is essential to have a clearly defined structure that identifies your blocks, the domestic dwellings which sit within them and your communal areas. Without this structure in place, it becomes difficult to evidence that all your potential compliance obligations have been assessed and addressed.

2. Reduce manual entry

The risks of manual data entry speak for themselves, yet it remains common practice for data to be recorded in this way, whether on spreadsheets or within a system. This method of recording data leaves the accuracy of your information entirely reliant on the person inputting it. Even if they are a meticulous and vigilant employee, mistakes are inevitable, and whilst preventing manual data entry entirely may be challenging, reducing its frequency through automation and effective reconciliation between systems is crucial.

3. Get serious about quality assurance and data reconciliation

All data should be periodically reconciled to ensure that asset numbers align across systemsand in turn, reconcile with each compliance programme. Whilst we appreciate the frequency of this reconciliation is dependent on the systems your organisation has in place and the interface between them, it is an essential mechanism, which will continue to pay dividends. There should be clearly defined processes in place that firstly ensure that asset numbers match across each system (to capture any stock movements) and secondly that the asset list you hold aligns with each compliance programme. Any properties which are on the asset list but not on a compliance programme should have a valid reason which can be backed up with evidence.

4. Silos are for farms, not your compliance data!

This is often a symptom of ineffective data reconciliation. When programmes are managed in silos (in other words, managed within a bubble that does not share information with others), there is no assurance that the right data is moving into the right places. Do you have assurance that all stock movements have been captured on each programme? Are changes to a particular programme being reflected into your core system and across other programmes? For example, if a contractor goes out on-site and identifies an asset or location which has been previously missed, is this then integrated into each of your other compliance programmes, and do you investigate why it was omitted?

5. Be clear on what you are reporting

Clearly structured and concise reporting ensures the right information is relayed to the right people. The TSMs represent a new way of reporting which will likely require a rethink of how you present your performance data, given they focus on the number of dwellings at risk as a result of a non-compliant record. As an example, if a block had an outstanding Fire Risk Assessment (FRA), then you must report against the number of dwellings within that block which are at risk because of the FRA not being completed. To achieve this, you must have absolute clarity on the assets you are responsible for and the compliance requirements of eachone. This information should then be presented in a way which demonstrates compliance with the TSMs but also provides assurance to leaders and Board that any non-compliance is understood and is being addressed.

6. Be clear on what data must be recorded

One of the most difficult challenges for organisations is recording the right information to provide the required levels of assurance. Often, the focus is primarily on the programmes themselves and ensuring current certifications remain in date. This is important, and organisations should never lose sight of this. However, it is the properties that are not on programmes that are most often overlooked. If a property is not on a programme, it is imperative to know and be able to prove, why. For example, if a building is not on your FRA programme because there are no communal areas, what assurance do you have that this is correct – has a competent person been to the site to confirm and document it? If so, great! If not, make sure this is rectified as a priority and the information is stored safely and reviewed regularly so that you can rest assured.

7. Record keeping

As the Housing Ombudsman calls for evidence from landlords on their record keeping and data management, practicing good record keeping is imperative. From negatively impacting on tenant experiences, mishandling complaints, data reporting errors and even risking tenant safety, poor record keeping is, simply put, a recipe for disaster. The Ombudsman’s recent findings shed light on the consequences of getting things wrong with landlords being held accountable for poor record keeping and handling of complaints, receiving orders to stringently review and change their policies, alongside being ordered to pay compensation to tenants who have been treated unjustly.

The same principles apply to compliance and the importance of good record keeping is not to be underestimated. To avoid future errors and ensure you hold the records to verify the compliance position you are reporting, your records must be well-managed, accurate and up-to-date.  

How we can help

It is clear that proper data management is crucial to comply with the new Tenant Satisfaction Measures. The TSMs allow tenant needs to be put first, ensuring their living standards are improved and voices are heard, though this will be difficult to achieve without accurate and reliable data. Through first-hand experience, we understand that dealing with data can be daunting and time-consuming for even the most resolute Boards and Senior Leadership Teams. Identifying areas for improvement can also be challenging as it’s not always clear where to start, which is where we come in.

The Pennington Choices team work closely with landlords to ensure they not only understand the TSMs, but they are able to accurately report on them too, to ultimately make the process of reviewing your data as simple as possible.

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 landlords may come across throughout navigating the TSM process.

In the meantime, you can watch our free on-demand webinar ‘Managing and using data – How to achieve excellence in Property Management’ here. Our team of industry experts explain how your organisation can achieve excellence in managing and using data to help keep people safe. Learn why data is so important and how you can use it to effectively manage your services operationally and drive strategic decision making, all whilst achieving positive customer safety and value for money outcomes.