Welcome from our Chair & Chief Executive
As we move into 2023/24 tenants and social landlords continue to face enormous challenges. Many tenants are facing genuine financial hardship. We are seeing acute issues around homelessness, and temporary accommodation in particular. Social landlords are faced with cost inflation that is running well above the headline rate of CPI, higher interest rates, and increasing requirements on quality of homes, while responding to pressure to keep rents as low as possible.
It looks like the year ahead will remain unpredictable, volatile and difficult. It will challenge the resilience, capacity and confidence of social landlords as they continue to strive to serve their tenants and service users. The ability of social landlords to adapt and evolve, to be resilient in the face of change and challenges, has never been more important, not least to protect the contribution that social landlords have made over the decades to many of our communities.
We recognise that the current context means that social landlords are likely to have to prioritise their attention and resources on the most critical and immediate issues, including tackling the acute problems in homelessness, alleviating fuel poverty and maintaining tenant safety. We will work with our stakeholders to understand what achievable priorities at a sustainable pace look like for social housing for the next year.
Our Regulatory Framework introduced in 2019 has delivered effectively during challenging times. We review our Framework every five years and it is now time to ensure that it remains up to date. We will work to review it in consultation with our stakeholders during 2023/24, with the introduction of a new Framework in April 2024. For this reason this strategy covers a one year period and in April 2024 we will introduce a longer term strategy.
We will also continue working closely with all our stakeholders to protect the interest of tenants and others by supporting social housing and delivering shared goals. And we look forward to working with all of our people in SHR to deliver this strategy.
Our objective, priorities & vision
2.1 Our Statutory Objective:
To safeguard and promote the interests of current and future tenants of social landlords, people who are or may become homeless, and people who use housing services provided by registered social landlords (RSLs) and local authorities
2.2 Our Vision:
Well-run social landlords delivering what tenants, people who are homeless, Gypsy/Travellers and others who use social housing services need and want, and at a price they can afford to pay.
2.3 Our priorities for 2023/24:
- Listening to tenants and service users and working closely with all our stakeholders.
- Regulating to support social landlords to meet their obligations and duties for tenants and those who use their housing service, with a focus on:
- landlords’ discharge of their duties to people who are or have experienced homelessness, with a particular focus on duties to provide appropriate temporary and permanent accommodation;
- the quality of the homes social landlords provide to their tenants and the standards of Gypsy/Traveller sites, particularly around energy efficiency and the safety of tenants and residents; and
- landlords being able to achieve the standards and outcomes in the Social Housing Charter and meet their wider obligations, while keeping rents affordable and providing value for money.
- Reviewing our Regulatory Framework to ensure it remains effective and sustainable, enabling us to do the right things in the right way at the right time.
- Being an effective public body.
- Responding to the Scottish Government’s public sector reform agenda, including helping to shape future private sector regulation.
What we will do
We will develop the plans set out below into a detailed operating plan aligned to our priorities and we will publish a summary of this.
Our priorities for 2023/24
3.1 Empowering tenants & others
We will help to empower tenants, people who are or have experienced homelessness, Gypsy/Travellers and others by:
- publishing the landlord performance data we gather in open, useful and accessible ways;
- providing them with tools to use the data we publish to help them better understand, compare and challenge their landlord’s performance;
- continuing to provide an effective way for tenants to raise concerns about significant performance failures by landlords; and
- further promoting to landlords the importance of involving tenants and others who use their services in the scrutiny of their performance to inform their self-assurance.
We will keep a strong focus on people who are or have experienced homelessness by:
- engaging and working with groups that represent and support people who are homeless;
- using our National Panel of tenants and service users to gain insight; and
- talking openly about the things that people who are or have experienced homelessness tell us are important.
We will promote a strong tenant voice by:
- engaging with our National Panel of Tenants & Service Users to better understand their priorities and experiences;
- working with our new cohort of tenant advisors to bring the tenant perspective to our work;
- engaging with the Regional Network SHR Liaison Group;
- engaging and working with tenant advocacy groups; and
- talking openly about the things that tenants tell us are important.
We will keep a strong focus on Gypsy/Travellers by:
- monitoring landlords’ achievement of the minimum standards for sites;
- engaging and working with groups that represent and support Gypsy/Travellers; and
- talking openly about the things that Gypsy/Travellers tell us are important.
3.2 Supporting social housing landlords to continue to deliver for tenants and meet their obligations and duties
We will continue to align our approach to the challenges that tenants, other service users and social landlords tenants, face. We will:
- work with the Scottish Government and representative groups to identify emerging issues and to develop effective responses to those issues; and
- continue to provide relevant advice and guidance to social landlords.
3.3 Getting assurance from landlords
We will get assurance by:
- using Annual Assurance Statements from all social landlords to inform our assessment of risk in each landlord and focus on priorities for tenants;
- monitoring, assessing and reporting on social landlords’ performance on:
- the Scottish Social Housing Charter
- discharging their statutory duties to provide timely access to temporary and permanent accommodation to people who are experiencing homelessness
- standards relating to quality and safety of homes and Gypsy/Traveller sites;
- monitoring, assessing and reporting on RSL financial health and governance;
- delivering a programme of assurance visits to RSLs and local authorities; and
- maintaining a focus on our priorities through our risk assessment, including on quality and safety of tenants’ homes, rent affordability and value for money.
We will promote and support effective landlord self-assurance by:
- publishing statutory & advisory guidance as required to assist RSLs and local authorities to build capacity and drive improvement;
- working with others, including Fire & Rescue Scotland, HSE, OSCR, Audit Scotland, SPSO, Care Inspectorate and the Scottish Government.
We will be transparent by:
- publishing proportionate engagement plans for every RSL and local authority;
- publishing our regulatory judgement in engagement plans for all RSLs; and
- engaging with current and potential investors in social housing and, if required, making it clear if we consider that an RSL is not a suitable partner for investors.
3.4 Taking action when we need to
We will act effectively and proportionately by:
- engaging with landlords where we see risks to the interests of tenants, homeless people, Gypsy/Travellers and others who use landlords’ services;
- using our statutory powers to protect those interests when we judge that to be appropriate and necessary;
- responding effectively when tenants raise concerns about significant performance failures;
- being open to, and responding to, people who bring concerns about landlords to us, including whistleblowers; and
- engaging with investors and our other stakeholders to protect the interests of tenants.
We will encourage landlords to:
- promote a culture in which tenants, governing body members and staff can constructively challenge the performance of their organisation;
- engage with us early when they face challenges; and
- work constructively with us when we need to engage with them.
Our powers include:
- requesting information;
- making inquiries;
- setting a performance improvement target (for one or more landlords);
- requiring a performance improvement plan;
- serving an enforcement notice;
- appointing a manager;
- appointing a governing body member to an RSL;
- removing or suspending a member of a governing body of an RSL;
- restricting dealings in an RSL; and
- directing an RSL to transfer some or all of its assets to another RSL.
We won’t normally need to use our statutory powers where a social landlord is able and willing to investigate and resolve any issues, and it engages with us effectively.
3.5 Carrying out thematic work
We use thematic work to look in depth at specific areas of social landlords’ work and respond to emerging issues and challenges. This helps us raise awareness of our priorities, emerging issues, lessons from serious casework and other things that tenants and service users tell us matter most. Thematic work also informs our advisory guidance and risk assessments and lets us share positive practice.
3.6 Promoting equality & human rights
We will continue to :
- work with stakeholders to develop a framework for equality and human rights in social housing to support landlords to effectively embed equality and human rights in how they run their organisations and deliver services;
- require social landlords to confirm through their Annual Assurance Statement that they meet the requirements around equality and human rights, or what they are doing to improve;
- seek assurance that landlords are giving due regard to equality and human rights in their decision-making through our engagements with individual landlords; and
- focus on landlords’ work to achieve the equalities outcome in the Scottish Social Housing Charter and to meet their legal duties in relation to equality and human rights.
3.7 Reviewing our Regulatory Framework
We will complete a review of the Regulatory Framework by April 2024. We will:
- publish a discussion paper early in summer 2023 setting out our ideas for change to the Framework;
- engage with our stakeholders around these ideas and seek their views on other potential changes;
- use the feedback on the discussion paper to propose changes to the Framework and associated guidance;
- consult formally on the changes we propose to make to the Framework and associated guidance in autumn 2023;
- publish an independent review of responses to the consultation; and
- publish the new Framework and associated guidance in February 2024.
3.8 Responding to the Scottish Government’s public service reform agenda
We will respond to the Scottish Government’s public service reform agenda as this takes shape by engaging with Scottish Government, partner public bodies and stakeholders. For us, this will include helping to shape future private sector regulation.
How we will work
Our core values, principles & how we will communicate:
- Open and transparent
- Risk based
- Evidence based judgements
- Effective and efficient
- Effective governance and financial stewardship
We are committed to the better regulation principles enshrined in the Scottish Regulators’ Strategic Code of Practice
- support our people to work in new ways, while helping them to maintain a good work / life balance;
- be visible & accessible, including using virtual platforms;
- be clear on what we require of social landlords;
- use our website and use social media platforms effectively;
- look for opportunities to work collaboratively with others;
- share and promote positive practice;
- provide a secure way for landlords to submit information to us;
- make the data we collect as freely accessible to others as possible;
- continue to publish annual summaries of our work plans;
- continue to learn lessons from all our work;
- maintain and continually develop effective and compliant IT systems to support our work; and
- maintain our cyber resilience, with appropriate preventative measures, retaining Cyber Essentials Plus accreditation, and having effective incident management arrangements.
We will relocate to an interim office and then move to a new permanent base.
Our public body duties
We will be an effective public body, and we will model good governance and financial stewardship.
Our duties and responsibilities as a Scottish public body include:
- SPSO complaints handling and reporting
- Records Management & Information Security
- Digital & Cyber Resilience
- Climate Change and biodiversity
- Public Service Reform
- Freedom of Information
- Data Protection
- Business Continuity
- Health & Safety
- Corporate Parenting
- Best value
We will use our resource effectively and efficiently to deliver our regulatory priorities and public body duties. Our revenue budget for 2023/24 is £5.3 million, of which around 82% is staff costs, and a capital budget of £0.4 million.
Our people includes:
- our Chair supported by our Non-Executive Directors;
- our 50.4 FTE employees;
- our Tenant Advisors; and
- the independent members of our Advisory Appeals Panel.
We will also look to our:
- National Panel of tenants and service users;
- Regional Network SHR Liaison Group and
- selection list of potential statutory managers.
We continue to be grateful and seek the input of volunteer statutory governing body members (mostly drawn from the social housing sector) who work to strengthen governance in social landlords and protect the interests of tenants.
Through risk-based regulation, we prioritise our resources and plan how to engage with RSLs & local authorities through further scrutiny, engagement or use of our powers.
How we will know we have been effective
We will monitor progress against our priorities throughout the year. We will report on our work in the performance section of our annual report and accounts 2023/24. This will be framed to report against the priorities we have set out in this strategy.
In our annual report we will demonstrate that we are doing the right things and that we do them well, and so we safeguard and promote the interests of tenants, people who are homeless, Gypsy/Travellers and factored owners. We will report on how we have:
- responded effectively when the interests of tenants, people who are or have experienced homelessness, Gypsy/Travellers and factored owners are at risk;
- managed any landlord failures to ensure tenants and service users do not suffer serious detriment, for example, losing their status as social housing tenants;
- worked with our stakeholders to give them confidence in how we regulate;
- strived to be open, transparent and accountable on our approach and performance; and
- sought to influence others to focus on our priorities.
We will lay and present out annual report and accounts to the Scottish Parliament, and we will engage with and respond to scrutiny by the Local Government, Housing and Planning Committee.