Policies and Procedures
Rudd Housing Feedback and Complaints Procedure
Policy Statement
Rudd Housing Nottingham CIC (Rudd Housing) recruits and supplies experienced personnel to deliver people the support they need and what commissioners, and regulators expect.
It is our aim to give the best possible service in all areas of our work. To enable us to do this, we need to know how you feel about how we do our work. We welcome your comments on any aspect of Rudd Housing’s service whether these are positive, negative or suggestions for improvement.
Rudd Housing is committed to delivering a high-quality service and being responsive to the needs of its service users. It does, however, recognise that there will be occasions when people will be dissatisfied with the service received and may wish to make a complaint. Rudd Housing places great emphasis on resolving complaints as quickly as possible in an open and transparent manner which is seen as vital to improve services and service users’ experience of Rudd Housing
To ensure consistency in dealing with feedback across Rudd Housing, procedures are in place for collecting, recording, responding to and reporting on feedback received.
We encourage everyone to put their name to all feedback sent to Rudd Housing. We recognise that sometimes there are circumstances in which someone may prefer to remain anonymous, but this can make it difficult for us to investigate fully and we will not be able to provide a response. Due to these difficulties, we investigate anonymous complaints at our discretion.
Are you content with what Rudd Housing does?
We are always delighted to hear about the things you like. This helps us identify those areas where we are really performing well and learn from that. It also means we can pass this on to the staff concerned.
Got an idea about how we can do things better?
You might think we do a good job but could do it even better or that we could be doing something we haven’t thought of. We welcome all your suggestions for improvements to current services.
Concerned about anything Rudd Housing does?
When we get something wrong, we need to know so that we can put it right. If you are unhappy about any aspects of the service we provide, we want to know about your concerns. We view concerns as valuable feedback about our work and will use the feedback to review how we do things, to learn from our mistakes and to improve the service you receive from Rudd Housing.
How to give us feedback
We welcome all positive feedback, but also welcome feedback that tells us when we may have got something wrong. Our aim is to resolve concerns quickly and at an early stage.
There are two ways to submit your feedback directly to us:
Talk to us – to start with you might like to talk to a member of Rudd Housing staff who will try to help with your concerns. This often works and we can improve our service as a result. They will also tell you whether your concern falls within our control and if not, where you can direct your concern.
Email, or write to us – you can send us feedback by:
By email: info@ruddhousing.co.uk
By post: Feedback Manager, Rudd Housing, 37 Radcliffe Road, West Bridgford, Nottingham, England, NG2 5FF
Please note that all our staff our currently working virtually during the Covid-19 pandemic so it may take longer to reply to letters sent in the post.
Whatever method you choose to use, please make sure you tell us about:
What it is that you are complimenting us on;
You don’t want to complain, but want to give us a suggestion on how we could do something better in future;
Complaints Procedure
If you do wish to lodge a formal complaint, then please tell us:
the issue, including what has happened, when it happened, and the background if you think it’s relevant
what you’ve done to try and resolve it
what you want us to do to put things right
What we will do
Let you know within five working days of its arrival that we’ve received your correspondence
Investigate your concern straight away.
Inform you of the result of our investigation as quickly as possible, and within 20 working days (four weeks) of your complaint.
Give you a full explanation for our response.
Carry out any actions we have promised
We recognise that a complaint which is not resolved quickly and fairly can soon become a cause of resentment, damaging to relationships and to our internal culture.
Therefore, we try to resolve all matters at an informal level if possible. If either party are not satisfied with the outcome of the investigation the case should be referred to the Managing Director, Emmad Kayani through the appeals process.
If you are unhappy with Rudd Housing or the way in which your complaint has been handled you can contact the Housing Ombudsman Service for advice.
The Housing Ombudsman Service introduced the Complaint Handling Code to help set clear guidelines for landlords to follow. This ensures that complaints are responded to quickly and fairly with a focus on learning from these complaints to drive service improvements. It also helps create a positive complaint handling culture amongst colleagues and residents. In April 2024, The Complaint Handling Code became statutory, meaning that landlords are obliged by law to follow its requirements.
Data Protection Policy
1. Purpose
This Data Protection Policy outlines Rudd Housing’s commitment to protecting the privacy and confidentiality of personal data in compliance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). We are dedicated to ensuring the lawful and responsible handling of personal data, maintaining the rights and freedoms of individuals whose data we process, including supported housing tenants, service users, employees, and families of residents.
2. Scope
This policy applies to all personal data processed by Rudd Housing in the course of our activities. It encompasses all employees, contractors, and third parties who handle personal data on behalf of Rudd Housing.
3. Principle of Data Protection
We adhere to the following principles when processing personal data:
Lawfulness, Fairness, and Transparency: We process personal data in a lawful, fair, and transparent manner, ensuring individuals are aware of the purpose and legal basis for processing their data.
Purpose Limitation: We only collect and process personal data for specific, explicit, and legitimate purposes stated at the time of collection.
Data Minimisation: We collect and process only the minimum amount of personal data necessary to fulfil the stated purpose.
Accuracy: We take reasonable steps to ensure the accuracy and currency of personal data, keeping it up to date and relevant.
Storage Limitation: We retain personal data for no longer than necessary for the purposes for which it was collected, with defined retention periods based on legal requirements and business needs.
Integrity and Confidentiality: We implement appropriate technical and organisational measures to ensure the security and confidentiality of personal data, protecting it against unauthorised access, loss, or disclosure.
Accountability: We take responsibility for our data protection practices and demonstrate compliance with applicable data protection laws.
4. Lawful Basis for Processing
We process personal data based on lawful bases as defined by the Data Protection Act 2018 and UK GDPR. These may include the necessity of processing for the performance of a contract, compliance with a legal obligation, protection of vital interests, consent, or legitimate interests pursued by Rudd Housing or a third party.
5. Data Subject Rights
We respect the rights of individuals regarding their personal data and provide mechanisms to exercise these rights, including:
Right to Access: Individuals can request access to their personal data held by Rudd Housing.
Right to Rectification: Individuals can request correction of inaccurate or incomplete personal data.
Right to Erasure: Individuals can request deletion of their personal data under certain conditions.
Right to Restrict Processing: Individuals can request a restriction on the processing of their personal data.
Right to Object: Individuals can object to the processing of their personal data based on legitimate interests or for direct marketing purposes.
Right to Data Portability: Individuals can request the transfer of their personal data to another organisation.
We have procedures in place to address data subject requests promptly and in accordance with legal requirements.
6. Data Security
To ensure the protection of personal data from unauthorized access, alteration, disclosure, or destruction, Rudd Housing implements a comprehensive set of technical and organizational measures, including:
1. Secure Systems
Network Security: Deployment of firewalls and intrusion detection systems to monitor and control incoming and outgoing network traffic, safeguarding against unauthorized access and threats.
Regular Software Updates: Ensuring all systems and applications are up-to-date with the latest security patches to mitigate vulnerabilities.
2. Data Encryption
In-Transit Encryption: Utilization of secure data transfer protocols (e.g., TLS, SSL) to encrypt personal data during transmission, preventing interception by unauthorized parties.
At-Rest Encryption: Encryption of stored personal data to protect it from unauthorized access, even if storage media are compromised.
3. Access Controls
Role-Based Access: Implementation of access controls to ensure that only authorized personnel can access personal data necessary for their roles.
Authentication Protocols: Use of strong password policies and, where appropriate, multi-factor authentication to verify user identities.
4. Staff Training
Data Protection Training: Regular training sessions for employees and contractors to ensure they understand data protection principles and their responsibilities in safeguarding personal data.
Awareness Programs: Ongoing initiatives to keep staff informed about emerging security threats and best practices.
5. Regular Security Assessments
Vulnerability Scanning: Periodic scanning of systems to identify and address security weaknesses.
Penetration Testing: Engaging in simulated attacks to evaluate the effectiveness of security measures and identify areas for improvement.
Compliance Audits: Regular audits to ensure adherence to data protection policies and regulatory requirements.
6. Physical Security
Secure Facilities: Implementation of physical security measures such as locked facilities, security lighting, and alarms to prevent unauthorized physical access to data storage locations.
Visitor Management: Maintenance of visitor logs and issuance of ID badges to monitor and control access to premises.
7. Data Minimization and Pseudonymization
Data Minimization: Collecting and processing only the minimum amount of personal data necessary for the specified purpose.
Pseudonymization: Implementing techniques to process personal data in a way that it cannot be attributed to a specific individual without additional information, enhancing privacy protection.
By integrating these measures, Rudd Housing ensures a robust framework for the protection of personal data, aligning with the requirements set forth in Article 32 of the UK GDPR.
7. Data Breach Management
In the event of a personal data breach, Rudd Housing has established comprehensive procedures to ensure prompt detection, assessment, reporting, and mitigation, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Detection and Reporting
Immediate Reporting: All employees, contractors, and third-party processors are required to report any suspected or confirmed personal data breaches to the Data Protection Officer (DPO) without delay.
Incident Logging: Upon notification, the DPO records the breach in the incident management system, noting the date, time, and nature of the breach, as well as the individuals involved.
2. Containment and Recovery
Initial Assessment: The DPO, in collaboration with relevant departments, promptly assesses the breach to determine its scope and impact.
Containment Measures: Immediate steps are taken to contain the breach, such as isolating affected systems, securing physical areas, or suspending compromised accounts.
Data Recovery: Efforts are made to recover any lost data and to verify the integrity of compromised data.
3. Risk Assessment
Evaluation of Risks: The DPO evaluates the potential adverse effects on individuals’ rights and freedoms, considering factors such as the sensitivity of the data, the volume of data affected, and the potential consequences for individuals.
Risk Classification: Based on the assessment, the breach is classified according to its severity, guiding subsequent actions.
4. Notification
Supervisory Authority Notification: If the breach is likely to result in a risk to individuals’ rights and freedoms, the DPO notifies the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach, providing:
A description of the nature of the breach, including, where possible, the categories and approximate number of individuals and records concerned.
The name and contact details of the DPO or other contact point.
A description of the likely consequences of the breach.
A description of the measures taken or proposed to address the breach and mitigate its effects.
Individual Notification: When the breach is likely to result in a high risk to the rights and freedoms of individuals, Rudd Housing promptly informs the affected individuals, detailing:
The nature of the breach.
The likely consequences.
The measures taken or proposed to mitigate the breach.
Advice on steps individuals can take to protect themselves.
5. Documentation and Evaluation
Breach Documentation: All breaches, regardless of severity, are documented, including the facts relating to the breach, its effects, and the remedial actions taken. This documentation enables Rudd Housing to demonstrate compliance and to provide evidence during potential audits or investigations.
Post-Incident Review: After managing the breach, a thorough review is conducted to assess the effectiveness of the response and to identify areas for improvement.
Policy and Procedure Updates: Lessons learned from the breach are used to update data protection policies and procedures, and to enhance staff training programs, thereby reducing the likelihood of future incidents.
By adhering to these procedures, Rudd Housing ensures a structured and effective response to personal data breaches, prioritizing the protection of individuals’ personal data and maintaining compliance with applicable data protection laws.
8. International Data Transfers
When transferring personal data outside the United Kingdom, we ensure adequate safeguards are in place to protect the data and comply with applicable data protection laws. This may include using standard contractual clauses, obtaining individual consent, or relying on recognised adequacy decisions.
9. Third-Party Data Processors
When engaging third-party processors to handle personal data on our behalf, we conduct due diligence to ensure their compliance with data protection laws and contractual obligations. We have written agreements that outline the responsibilities and safeguards for such processing activities.
10. Staff Training and Awareness
We are committed to ensuring a culture of privacy and data protection through comprehensive training and awareness programs for our employees and contractors. Our initiatives include:
1. Regular Training Programs
Mandatory Onboarding Training: All new employees and contractors are required to complete data protection training during their induction process.
Annual Refresher Courses: We conduct yearly refresher courses to keep staff updated on data protection regulations, organizational policies, and emerging threats.
2. Specialised Workshops
Role-Specific Training: Tailored sessions are provided for departments handling sensitive personal data, such as tenant services and human resources, to address specific data protection challenges pertinent to their functions.
3. Continuous Awareness Initiatives
Regular Updates: We disseminate newsletters and bulletins highlighting recent developments in data protection laws and best practices.
Interactive Learning: Engaging activities, such as quizzes and scenario-based discussions, are utilized to reinforce key concepts and encourage proactive data protection behaviours.
11. Compliance and Review
To ensure the ongoing effectiveness and compliance of our data protection practices, Rudd Housing commits to the following review schedule:
Regular Reviews: We will review this Data Protection Policy at least once every three years to ensure it remains aligned with current data protection laws and our operational practices.
Ad-Hoc Reviews: In addition to the regular triennial reviews, we will conduct immediate policy reviews in response to significant events, such as:
Legislative Changes: If there are amendments to data protection laws or regulations that affect our obligations.
Organisational Changes: If there are significant changes in our operations, services, or data processing activities.
Data Breaches or Security Incidents: Following any data breach or security incident, to assess and improve our data protection measures.
Safeguarding Adults Policy
Introduction
Rudd Housing Nottingham CIC takes all concerns and allegations of abuse, neglect, and harm seriously. Safeguarding means protecting a person’s right to live in safety, free from abuse and neglect. It is about people and organisations working together to prevent and stop both the risks and experiences of abuse or neglect, while ensuring the person’s wellbeing is promoted.
We recognise that abuse can occur in all communities, and adults at risk living in our homes and across our communities may be particularly vulnerable. Abuse may happen through neglect, inflicting harm, or failing to act to prevent harm. It is any behaviour that deliberately or unknowingly causes harm, endangers life, or infringes on a person’s rights.
A key principle in safeguarding is ‘making safeguarding personal’, meaning we work with individuals to determine outcomes, actions, and timescales, keeping the focus on the person rather than the process.
1.1 Scope of this Policy
This policy applies to:
Residents
Household members
People receiving a service from Rudd Housing who are not residents
Rudd Housing employees
Board members and Committee members
Agency staff, volunteers, and apprentices working with or on behalf of Rudd Housing
Overview
In accordance with the Care Act 2014, Rudd Housing is committed to:
Maintaining robust safeguarding policies and procedures, implemented by trained and knowledgeable staff.
Acting as ‘alerters’, ensuring safeguarding concerns are reported to the local authority and/or multi-agency partners.
The Six Key Principles of Safeguarding
Empowerment – People should make their own decisions and give informed consent.
Protection – Victims must be supported and have a say in their care.
Prevention – It is better to act before harm occurs.
Proportionality – Responses must be appropriate to the risk presented.
Partnership – Local services, including housing providers, must work together to safeguard people.
Accountability – Safeguarding arrangements should be transparent and have clear responsibilities.
Rudd Housing operates a zero-tolerance policy towards abuse, neglect, and exploitation.
3. Definitions
3.1 Adults at Risk
An adult is anyone aged 18 or over. Under the Care Act 2014, safeguarding duties apply to adults who:
Have needs for care or support (whether or not they receive local authority support)
Are experiencing, or at risk of, abuse or neglect
Are unable to protect themselves due to their care and support needs
3.2 Abuse
Abuse is defined as ‘the violation of an individual’s human and civil rights’ by another person. It includes:
A single or repeated act
Deliberate neglect or a lack of appropriate action
Persuading a person to do something they have not consented to or cannot consent to
3.3 Types of Abuse
Abuse can take many forms, including:
Physical (e.g., assault, restraint, misuse of medication)
Emotional or Psychological (e.g., threats, intimidation, coercion)
Sexual (e.g., inappropriate touching, harassment, exploitation)
Financial or Material (e.g., theft, fraud, misuse of property or benefits)
Neglect or Acts of Omission (e.g., withholding food, medication, medical care)
Domestic Abuse (e.g., coercion, violence, control within relationships)
Discriminatory Abuse (e.g., based on age, gender, disability, race)
Self-neglect (e.g., hoarding, refusal of essential services)
Abuse cannot be excused for any cultural, religious, or personal reason and must always be reported.
4. Aims of this Policy
4.1 This Policy Ensures Rudd Housing:
Complies with all statutory and regulatory requirements, including:
Care Act 2014
Mental Capacity Act 2005
Deprivation of Liberty Safeguards (LPS)
Health and Social Care Act 2008 (CQC)
Public Interest Disclosure Act 1998
Protects staff, volunteers, and contractors with a duty towards adults at risk.
Makes safeguarding personal, ensuring individuals have choice and control.
Raises awareness of abuse and signs to watch for.
Provides clear reporting procedures for concerns or suspected abuse.
Works in partnership with multi-agency safeguarding networks.
4.2 We Will Achieve Our Aims By:
Protecting the rights of individuals at risk, and treating them with respect and dignity at all times
Ensuring when in contact with people at risk, appropriately trained staff carry out all necessary health and safety risk assessments
Ensuring our safeguarding lead provides clear lines of accountability for reporting abuse
Having a safeguarding team in place to oversee strategic objectives for safeguarding
Working within, and keeping up to date with, government legislation, guidance, and regulation.
5. Roles and Responsibilities
While safeguarding responsibility sits with all staff, there are clear individual and team responsibilities too.
All staff, Board members, volunteers, agents, and contractors are responsible for understanding the different types of abuse and reporting concerns or suspected abuse.
All departmental managers are responsible for ensuring safeguarding matters are reported and safeguarding is effectively managed within their areas of responsibility.
We have a designated strategic lead on safeguarding, supported by a Safeguarding Team.
We are committed to identifying, recording and responding to the needs of our residents and people who receive a care and support service from us who are not our residents, wherever possible.
We will do this by:
Making referrals to, and working with, local authorities
Signposting and working with relevant support agencies
Facilitating or carrying out aids and adaptations where required
Keeping the person updated and involved
Monitoring and reviewing support action plans as necessary.
The Safeguarding Team, via the Senior Leadership Team (SLT), is responsible for making sure lessons learnt are communicated to all relevant staff. Where necessary, supporting policies, procedures, and guidance will be amended.
Safeguarding reports will be provided on a quarterly basis to senior managers across the organisation. As a minimum, six-monthly reports will be provided to the SLT, together with an annual report to the Board.
6.Reporting Concerns
All safeguarding reports are centrally recorded and reported to the local authority, which is responsible for Section 42 safeguarding inquiries.
Confidentiality is maintained, but concerns may be shared where there is a risk to an individual’s safety.
Residents, relatives, or members of the public can report concerns directly to Rudd Housing for support and guidance.
Concerns related to Rudd Housing staff, board members, contractors, or volunteers will be investigated under formal safeguarding and disciplinary procedures.
If a staff member suspects abuse within the community, they must report it to the relevant local authority.
Any allegation against a contractor may result in immediate suspension pending investigation.
Anonymous reporting is supported, but disclosures related to serious harm or criminal acts may need to be shared with professionals.
All safeguarding reports should be directed to:
📧 info@ruddhousing.co.uk
All safeguarding reports are centrally recorded.
Concerns must be reported to the relevant local authority (which has the decision-making responsibility under Section 42 of the Care Act 2014).
Reports should be confidential but shared if there is a significant risk to the individual or others.
Residents or their family members can report concerns directly to Rudd Housing for support and guidance.
7.Information Sharing & Policy Review
All information shared must comply with the Data Protection Act 2018.
Confidentiality must be maintained unless a significant safeguarding risk is identified.
This policy will be reviewed every three years or sooner if legislation or best practice guidance changes.
For further safeguarding concerns or advice, contact:
📧 info@ruddhousing.co.uk
Disclosure and Barring (DBS) Policy and Procedure – Employees and Contractors
1. Purpose
To ensure the safety and well-being of our residents, Rudd Housing mandates comprehensive Disclosure and Barring Service (DBS) checks for all employees and contractors. This policy outlines the procedures for conducting these checks in compliance with relevant legislation and safeguarding best practices.
2. Scope
This policy applies to all individuals working with Rudd Housing, including:
Permanent and temporary employees
Contractors and subcontractors
Volunteers
Agency workers
3. Definitions
DBS Check: A background check processed by the Disclosure and Barring Service to help employers make safer recruitment decisions.
Regulated Activity: Roles that involve working closely with vulnerable groups, including children and adults, which require a higher level of DBS check.
4. Policy Statement
Rudd Housing is committed to safeguarding vulnerable individuals by ensuring that all personnel undergo appropriate DBS checks prior to commencing work. The level of check will be determined based on the role’s responsibilities and the nature of contact with residents.
5. Procedure
5.1. Determining the Level of DBS Check
Enhanced DBS Check with Adults’ Barred List Check: Required for roles involving personal care, supervision, or direct engagement with vulnerable adults.
Enhanced DBS Check: Applicable for roles involving regular contact with vulnerable adults but not directly providing personal care.
Standard DBS Check: For roles with access to sensitive information or areas but limited direct contact with residents.
Basic DBS Check: For roles with minimal or incidental contact with residents.
5.2. Application Process
Initiation:
The hiring manager identifies the appropriate level of DBS check based on the role’s responsibilities.
Candidate Notification:
Inform the candidate that a DBS check is required and obtain their consent to proceed.
Form Completion:
Provide the candidate with the DBS application form and guidance on completion.
Identity Verification:
Verify the applicant’s identity using approved documents, following DBS guidelines.
Submission:
Submit the completed application to the DBS for processing.
Result Handling:
Upon receipt, review the DBS certificate to assess the candidate’s suitability for the role.
5.3. Contractors and Subcontractors
Assessment:
Evaluate the nature of the contractor’s work and their level of interaction with residents.
DBS Requirement:
Ensure contractors undergo the appropriate level of DBS check as determined by their role.
Verification:
Obtain and record evidence of the contractor’s DBS clearance before they commence work.
6. Record Keeping
Maintain secure and confidential records of all DBS checks conducted, including:
Date of check
Level of check
Unique reference number
Outcome
7. Renewal and Monitoring
Renewal:
DBS checks will be renewed every three years for existing staff and contractors.
DBS Update Service:
Encourage staff to subscribe to the DBS Update Service for ongoing monitoring.
8. Handling Positive Disclosures
Risk Assessment:
Conduct a thorough risk assessment if a DBS check reveals a criminal record or other concerns.
Decision Making:
Decisions regarding employment or engagement will be made on a case-by-case basis, considering the nature of the offense, its relevance to the role, and the time elapsed since the offence.
9. Confidentiality
All information obtained through DBS checks will be handled in strict confidence and in accordance with data protection regulations.
10. Compliance and Review
This policy will be reviewed annually to ensure compliance with current legislation and best practices.
11. Related Policies
Safeguarding Policy – Adults
Safeguarding Policy – Children
Data Protection Policy
12. References
Disclosure and Barring Service (DBS) Guidance
Safeguarding Vulnerable Groups Act 2006
Care Act 2014
13. Contact Information
For further information or clarification regarding this procedure, please contact the Health and Safety Department at info@ruddhousing.co.uk.