Agenda Document Pack - Communities and Housing Policy Board - 11/03/2025
Renfrewshire Council · 11 March 2025
Back to Communities and Housing Policy Board — 11 March 2025 and its agenda
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05/03/2025 Notice of Meeting and Agenda Communities and Housing Policy Board Date Time Venue Tuesday, 11 March 2025 13:00 Council Chambers (Renfrewshire), Council Headquarters, Renfrewshire House, Cotton Street, Paisley, PA1 1AN Membership Councillor Marie McGurk (Convener): Councillor Robert Innes (Vice Convener): Councillor Jacqueline Cameron: Councillor Carolann Davidson: Councillor Gillian Graham: Councillor John Hood: Councillor Kenny MacLaren: Councillor Mags MacLaren: Councillor Colin McCulloch: Councillor Janis McDonald: Councillor Cathy McEwan: Councillor Jamie McGuire: Councillor Iain McMillan: Councillor John McNaughtan: Councillor Iain Nicolson: Councillor Emma Rodden: Members of the Press and Public Members of the press and public wishing to attend the meeting should report to the customer service centre where they will be met and directed to the meeting. Further Information This is a meeting which is open to members of the public. A copy of the agenda and reports for this meeting will be available for inspection prior to the meeting at the Customer Service Centre, Renfrewshire House, Cotton Street, Paisley and online at http://renfrewshire.cmis.uk.com/renfrewshire/CouncilandBoards.aspx For further information, please email democratic-services@renfrewshire.gov.uk Hybrid Meeting Please note that this meeting is scheduled to be held in the Council Chambers. However, it is a hybrid meeting and arrangements have been made for members to join the meeting remotely should they wish. MARK CONAGHAN Head of Corporate Governance
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05/03/2025 Webcasting of Meeting This meeting will be filmed for live or subsequent broadcast via the Council’s internet site – at the start of the meeting the Convener will confirm if all or part of the meeting is being filmed. To find the webcast please navigate to https://renfrewshire.public-i.tv/core/portal/home
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05/03/2025 Items of business Apologies Apologies from members. Declarations of Interest and Transparency Statements Members are asked to declare an interest or make a transparency statement in any item(s) on the agenda and to provide a brief explanation of the nature of the interest or the transparency statement. 1 Police and Fire and Rescue Services Scrutiny Sub- committee Minute of meeting of the Police and Fire and Rescue Services Scrutiny Sub-committee held on 14 January 2025. 1 - 4 2 General Services Revenue, Housing Revenue Account (HRA) and Capital Budget Monitoring as at 7 January 2025 Joint report by the Directors of Finance & Resources and Environment, Housing & Infrastructure. 5 - 16 3 Service Update Report Report by the Director of Environment, Housing & Infrastructure. 17 - 28 4 Renfrewshire Common Housing Allocation Policy Review 2024 Report by Director of Environment, Housing & Infrastructure. 29 - 120 5 Renfrewshire Common Housing Allocation Policy – Council Allocation Targets for 2025/26 Report by Director of Environment, Housing and Infrastructure. 121 - 126 6 Renfrewshire Council Tenant Participation Strategy – Update Report by Director of Environment, Housing & Infrastructure. 127 - 146 7 Housing Landlord Compliance Report by Director of Environment, Housing and Infrastructure. 147 - 188
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05/03/2025 8 Creating a smokefree generation and tackling youth vaping – Enforcement of the Environmental Protection (Single-Use Vapes) (Scotland) Regulations 2024 Report by Director of Environment, Housing & Infrastructure. 189 - 194 9 Consultation on the Regulation of non-surgical cosmetic procedures Report by Director of Environment, Housing & Infrastructure. 195 - 204 EXCLUSION OF PRESS AND PUBLIC The Board may by resolution exclude the press and public from the meeting during consideration of the following items of business as it is likely, in view of the nature of the business to be transacted, that if members of the press and public are present, there could be disclosure to them of exempt information as defined in paragraph 9 of Part I of Schedule 7A of the Local Government (Scotland) Act, 1973. Exempt Item Exempt documents are no longer available in print format. You will require to log in to Communities & Housing Exempt Items to access documents. Please note that access to exempt documents is restricted. 10 Disposal of Land - Stirling Drive, Linwood • Information relating to the financial or business affairs of any particular person (including the authority holding that information);
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Minute of Meeting Police and Fire and Rescue Scrutiny Sub-Committee Date Time Venue Tuesday, 14 January 2025 15:00 Council Chambers (Renfrewshire), Council Headquarters, Renfrewshire House, Cotton Street, Paisley, PA1 1AN Present: Councillor Alec Leishman, Councillor Mags MacLaren, Councillor Marie McGurk, Councillor Iain McMillan, Councillor Iain Nicolson Chair Councillor McGurk, Convener, presided. In Attendance G Hannah, Head of Climate, Public Protection & Roads (Environment, Housing and Infrastructure); and E Gray, Senior Committee Services Officer and Donna Cunningham, Committee Services & Licensing Officer (both Finance & Resources). Also in Attendance Chief Superintendent R Fraser and Chief Inspector A Marshall (both Police Scotland); and K Murphy, Area Commander and P Storrie, Group Manager (both Scottish Fire and Rescue Service). Webcasting of Meeting Prior to the commencement of the meeting the Convener intimated that this meeting of the Sub-committee would be filmed for live or subsequent broadcast on the Council’s internet site. Item 1 CHPB110325 Page 1 of 204
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Declarations of Interest and Transparency Statements There were no declarations of interest or transparency statements intimated prior to the commencement of the meeting. Membership Update The Convener welcomed Chief Superintendent R Fraser, Police Scotland, to the membership of the Police and Fire and Rescue Scrutiny Sub-committee. 1 Police Scotland - Performance Report There was submitted a report by the Chief Superintendent, Police Scotland, relative to service performance and activities in the Renfrewshire area for the reporting period 1 April to 31 October 2024. The report summarised the key performance indicators and provided statistics and updates in terms of Renfrewshire’s Policing Priorities 2023/26 and Police Scotland’s Policing Priorities 2023/26. It was highlighted that forthcoming initiatives would include sextortion awareness in schools and a targeted social media awareness campaign. The Chief Superintendent advised that 10 new recruits had recently joined the force and that a further 20 recruits would imminently commence their initial training. Councillor Leishman requested a working definition and more information on non- crime hate incidents. Police Scotland advised this would be provided to all members of the Sub-committee. DECIDED: That the contents of the report and verbal updates be noted. 2 Scottish Fire and Rescue Service - Performance Report There was submitted a report by the Area Commander, Scottish Fire and Rescue Service (SFRS) relative to SFRS performance and local fire and rescue service plan priorities in the Renfrewshire area during the period 1 October to 31 December 2024. The report provided updates in relation to Local Fire and Rescue Service Plan Priorities; Renfrewshire activity; accidental dwelling fires and casualties; unintentional injury and harm; deliberate fire setting; non-domestic fire safety and unwanted fire alarm signals. The Area Commander outlined changes to the Fire Safety Programme. DECIDED: That the contents of the report and verbal updates be noted. Page 2 of 204
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3 Local Issues Councillor McMillan raised concerns that areas of Renfrewshire were becoming problematic in terms of drugs and anti-social behaviour. The Chief Superintendent requested that incidents be reported to enable these issues to be addressed and advised that they would liaise with the local problem-solving team, housing officers and other relevant partners. Councillor M MacLaren expressed safety concerns regarding the number and speed of motorised scooters in the Paisley town centre area. The Chief Superintendent encouraged the reporting of such incidents and advised that officers located in the town centre area would be made aware of this concern. DECIDED: That the verbal updates be noted. Page 3 of 204
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 ___________________________________________________________________ Report by: Director of Finance and Resources & Director of Environment, Housing and Infrastructure ___________________________________________________________________ Heading: General Services Revenue, Housing Revenue Account (HRA) and Capital Budget Monitoring as at 7 January 2025 ___________________________________________________________________ 1. Summary 1.1 At the close of reporting Period 10 on 7 January 2025, the projected revenue outturn at 31 March 2025 for those services reporting to the Communities and Housing Policy Board, including the Housing Revenue Account, is break-even against the revised budget for the year in General Services and a break-even position in the HRA. 1.2 The projected capital outturn at 31 March 2025 for projects reporting to the Communities and Housing Policy Board, is a break-even position. 1.3 This is summarised over the relevant services in the table below and further analysis is provided in the report and appendices. Revised Annual Budget £000 Projected Outturn £000 Budget Variance (Adv)/Fav £000 Budget Variance % Revenue Housing Revenue Account (HRA) 0 0 0 0.0% Housing – General Services (Non-HRA) 4,987 4,987 0 0.0% Communities and Public Protection 6,106 6,106 0 0.0% Criminal Justice 4,198 4,198 0 0.0% Total 15,291 15,291 0 0.0% Item 2 CHPB110325 Page 5 of 204
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Revised Annual Budget £000 Projected Outturn £000 Budget Variance (Adv)/Fav £000 Budget Variance % Capital Housing Revenue Account (HRA) 31,380 31,380 0 0.0% Other Housing PSHG 1,186 1,186 0 0.0% Total 32,566 32,566 0 0.0% 2. Recommendations 2.1 It is recommended that the Board note the projected Revenue outturn break- even position. 2.2 It is recommended that the Board note the projected Capital outturn break-even position. 2.3 It is recommended that the Board agree to homologate the budget adjustments detailed at section 7.2. 3. Revenue Budget Projection – break-even by 31 March 2025 3.1 The tables in Appendix 1 present the projected year-end position for all services reporting to this board, by both subjective analysis (what the budget is spent on) and objective analysis (which division is spending the budget). Significant variances affecting the projected position are analysed further below. 3.2 It should be noted that the projected outturn position reported here is based on the latest information available, which is subject to change during the financial year. Budget holders are obliged to seek mitigating action to minimise significant budget variances. 4. Objective Analysis – Significant Variances 4.1 Housing Revenue Account (HRA) - break-even by 31 March 2025 The HRA is projected to break-even overall in 2024/25. Demand for repairs to HRA premises, including void properties, is still currently expected to be managed within the revised budget levels. 4.2 Housing – General Services (Non-HRA) – break-even by 31 March 2025 The projected outturn for Homelessness within Housing – General Services (Non-HRA), continues to be a challenge over the remainder of the financial year. Demand on services is currently being managed within existing resources, including additional staffing, being supported through migration and asylum funding streams allocated to the Council by the UK and Scottish Government. Page 6 of 204
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The potential increase in homeless presentations linked to the asylum population in Renfrewshire and more widely across the West of Scotland, continues to create additional, potentially long-term, financial pressures for Council services. Projections of these pressures will continue to be reviewed and reported to future Communities and Housing Policy Boards as required. 4.3 Communities and Public Protection - break-even by 31 March 2025 Employee costs are projected to underspend due to vacancies within the service, this area is under review by management. The underspend has been allocated against spend across other budget lines and overall, the service is projected to break-even at year end. 5. Subjective Analysis – Significant Variances GENERAL SERVICES (excluding HRA) 5.1 Employee costs - £0.234m underspend by 31 March 2025 This is a combination of underspends across services, for example, in Public Protection underspends are due to vacancies, which are currently under review. Underspends in Community Learning & Development and Homelessness are offset by minor overspends across their service areas. 5.2 Transport Related – (£0.058m) overspend by 31 March 2025 Overspends in Community Learning & Development, Criminal Justice and Homelessness are offset by minor underspends across their service areas. 5.3 Supplies and Services - (£0.066m) overspend by 31 March 2025 This includes (£0.070m) for prior year water sampling costs within the Public Protection Service, funded by underspends in employee costs as noted above. Furniture costs within the Homelessness Service are projected to overspend, which is consistent with the overall demand on Homelessness services. 5.4 Transfer Payments – (£0.170m) overspend by 31 March 2025 Underspends in revenue costs within the Private Sector Housing Grant programme has led to a reduction in the projected drawdown from Reserves. Overspends in Public Protection are offset by underspends within employee costs, as reported above. HOUSING REVENUE ACCOUNT (HRA) 5.5 Premises Related costs – (£0.121m) overspend by 31 March 2025 The level of demand for Repairs and Maintenance of HRA Properties remains high, especially within Void properties. Page 7 of 204
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In-year temporary budget transfers from areas of underspend have been realigned to manage this within the overall service. Additional focus will continue on this area to understand ongoing demand levels. All premises related costs, including utilities and estate management, are subject to fluctuations, and will continue to be closely monitored throughout the year. 5.6 Transfer Payments – £0.073m underspend by 31 March 2025 The implementation of the Single Voids Team has overseen an improvement in both operational and management void rent loss, and this underspend is reflective of the progress achieved in this area. 6. Revenue Budget Virements 6.1. Under the Council’s financial regulations, Directors, and their nominated officers, in consultation with the Director of Finance and Resources, have certain delegated authority to transfer sums between subjective budget headings within a service division to enable budget management throughout the financial year. This is known as ‘budget virement’. 6.2. Transfers between divisions of the same service / department in excess of £100,000, and transfers between services / departments must be authorised by the respective service Director and the Director of Finance and Resources for submission to the relevant policy board for approval. No such virements are proposed this period. 7. Capital Budget Projection – break-even position by 31 March 2025 7.1 The Non-Housing Capital Investment Programme 2024/25 to 2028/29 was approved by the Council on 29 February 2024. For Communities and Housing Service the revised capital spend for 2024/25 is £32.566m. 7.2 The in-year Capital budget is forecast to break-even by 31 March 2025, following a budget adjustment between years that has taken place to reflect revised programming of some capital projects. Details of the £0.518m adjustment is as follows: Capital Budget Adjustments Project Amount (£m) Reason Non Property Expenditure 0.518 This reflects the most recent profiling of the Housing ICT Systems Replacement Project within the overall capital programme. HRA reserves have been earmarked to fund this expenditure. Total 0.518 Page 8 of 204
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Implications of the Report 1. Financial The projected budget outturn position for the Communities and Housing Revenue budget is break-even at 31 March 2025. Income and expenditure will continue to be monitored closely for the rest of the financial year and as far as possible, steps will be taken to mitigate any overspend. The projected outturn position for Communities and Housing Services Capital budget is break-even, after the adjustments outlined in section 7. 2. HR & Organisational Development While staffing budgets form a significant proportion of the Council’s revenue budgets, there are no direct implications arising from the recommendations in this report. 3. Community/Council Planning Community Plan Our Renfrewshire is thriving The Council’s revenue and capital spend ensures that its facilities are fit for purpose and safe for the community, to maximise accessibility. Our Renfrewshire is well Our Renfrewshire is fair Our Renfrewshire is safe Council Plan Reshaping our place, our economy and our future The Council’s revenue and capital spend ensures that its facilities are fit for purpose and safe for the community, to maximise accessibility. Building strong, safe and resilient communities Tackling inequality, ensuring opportunities for all Creating a sustainable Renfrewshire for all to enjoy Ongoing revenue and capital budget monitoring is a tool to enable good financial management so that the Council has resources now and in the future for continued service delivery. Working together to improve outcomes 4. Legal There are no direct implications arising from the recommendations in this report. Page 9 of 204
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5. Property/Assets The capital expenditure noted in this report will result in lifecycle maintenance improvements to existing properties and replacement of ICT assets and infrastructure. 6. Information Technology ICT assets and revenue costs are included within these reported budgets, and the costs associated with the replacement of the Housing Management system will have both an ongoing revenue and capital budget impact. 7. Equality & Human Rights While new areas of spend may impact on particular groups, any such impact would be assessed prior to the spend being incurred, therefore there are no direct implications arising from the recommendations in this report. 8. Health & Safety The capital expenditure noted in this report will result in lifecycle maintenance improvements to existing properties and replacement of ICT assets, which may in some cases rectify health and safety issues. 9. Procurement While Procurement is an important consideration prior to the Council incurring any revenue or capital spend, there are no direct implications arising from the recommendations in this report. 10. Risk The potential financial risk that the Council will overspend its approved revenue budgets for the year is managed at a Council-wide level by the Chief Executive and Directors. 11. Privacy Impact There are no direct implications arising from the recommendations in this report. 12. Cosla Policy Position N/a. 13. Children’s Rights There are no direct implications arising from the recommendations in this report. Page 10 of 204
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14. Climate Change The Council aims to reduce its carbon and other emissions to net zero by 2030, however there are no direct implications arising from the recommendations in this report. List of Background Papers Housing Revenue Account Budget & Rent Levels 2024/25 and Housing Capital Investment Plan 2024/25 to 2028/29, Council 29 February 2024. Non-housing Capital Investment Programme, prudential Framework and Treasury Management Strategy, and Capital Strategy 2024/25 – 2028/29, Council 29 February 2024. Author: John Kilpatrick, Finance Business Partner; Geoff Borland, Finance Manager. Page 11 of 204
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RENFREWSHIRE COUNCIL REVENUE BUDGET MONITORING STATEMENT 2024/25 1 April 2024 to 7 January 2025 POLICY BOARD: COMMUNITIES AND HOUSING ‐ All SERVICES Objective Summary Annual Budget at Period 6 Budget Adjustments Revised Annual Budget at Period 8 Projected Outturn Budget Variance (Adverse) or Favourable Previous Projected Outturn Variance Movement £000 £000 £000 £000 £000 % £000 £000 Housing Revenue Account (HRA) 0 0 0 0 0 0.0% 0 0 Housing ‐ General Services (Non‐HRA) 4,904 83 4,987 4,987 0 0.0% 0 0 Communities and Public Protection (including Regulatory Services) 5,882 224 6,106 6,106 0 0.0% 0 0 Criminal Justice 4,092 106 4,198 4,198 0 0.0% 0 0 NET EXPENDITURE 14,878 413 15,291 15,291 0 0.0% 0 0 Page 12 of 204
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RENFREWSHIRE COUNCIL REVENUE BUDGET MONITORING STATEMENT 2024/25 1 April 2024 to 7 January 2025 POLICY BOARD: COMMUNITIES AND HOUSING ‐ GENERAL SERVICES (excluding HRA) Subjective Summary Annual Budget at Period 8 Budget Adjustments Revised Annual Budget at Period 10 Projected Outturn Budget Variance (Adverse) or Favourable Previous Projected Outturn Variance Movement £000 £000 £000 £000 £000 % £000 £000 Employees 12,561 406 12,968 12,734 234 1.8% 334 (100) Premises Related 2,398 4 2,402 2,413 (11) (0.4%) (21) 11 Transport Related 197 0 197 255 (58) (29.4%) (50) (8) Supplies and Services 6,093 0 6,093 6,159 (66) (1.1%) (118) 53 Third Party Payments 112 239 351 343 8 2.3% (43) 51 Transfer Payments 2,799 (236) 2,563 2,733 (170) (6.6%) (113) (57) Support Services 53 0 53 19 34 64.4% 2 33 Depreciation and Impairment Losses (23) 0 (23) (11) (12) (52.2%) (12) 0 GROSS EXPENDITURE 24,191 414 24,605 24,645 (40) (0.2%) (22) (18) Income (9,313) (1) (9,314) (9,354) 40 0.4% 22 18 NET EXPENDITURE 14,878 413 15,291 15,291 (0) 0.0% 0 (0) Page 13 of 204
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RENFREWSHIRE COUNCIL REVENUE BUDGET MONITORING STATEMENT 2024/25 1 April 2024 to 7 January 2025 POLICY BOARD: COMMUNITIES, HOUSING AND PLANNING SERVICES ‐ Housing Revenue Account (HRA) Only Subjective Summary Annual Budget at Period 8 Budget Adjustments Revised Annual Budget at Period 10 Projected Outturn Budget Variance (Adverse) or Favourable Previous Projected Outturn Variance Movement £000 £000 £000 £000 £000 % £000 £000 Employees 11,293 0 11,293 11,332 (39) (0.3%) 9 (48) Premises Related 25,110 200 25,310 25,431 (121) (0.5%) (26) (95) Transport Related 53 0 53 63 (10) (18.9%) (10) 0 Supplies and Services 768 0 768 766 2 0.3% (13) 15 Third Party Payments 0 0 0 0 0.0% 0 0 Transfer Payments 5,003 (200) 4,803 4,730 73 1.5% 6 67 Support Services 3,322 0 3,322 3,277 45 1.4% 12 33 Depreciation and Impairment Losses 18,427 0 18,427 18,427 0 0.0% 0 0 GROSS EXPENDITURE 63,976 0 63,976 64,026 (50) (0.1%) (22) (28) Income (63,976) 0 (63,976) (64,026) 50 0.1% 22 28 NET EXPENDITURE 0 0 0 0 0 0.0% 0 0 Page 14 of 204
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Prior Years Approved Budget Revised Projected Total Approved Projected Expenditure Budget Adjustments Budget Outturn Budget Outurn to 31/03/2024 2024‐25 since previous 2024‐25 2024‐25 to 31‐Mar‐29 to 31‐Mar‐29 Project Title Board report £000 £000 £000 £000 £000 £000 £000 HOUSING(HRA) Improvements To Existing Properties 0 16,538 0 16,538 16,538 0 0% 111,757 111,757 0 0% Regeneration 10,743 7,682 0 7,682 7,682 0 0% 7,587 7,587 0 0% Other Assets 0 3,265 0 3,265 3,265 0 0% 4,550 4,550 0 0% Non Property Expenditure 0 900 518 1,418 1,418 0 0% 10,860 10,860 0 0% Council House New Build 42,665 627 0 627 627 0 0% 74,690 74,690 0 0% Professional Fees 0 1,850 0 1,850 1,850 0 0% 9,700 9,700 0 0% Total Housing (HRA) Programme 53,408 30,862 518 31,380 31,380 0 0% 219,144 219,144 0 0% HOUSING(PSHG) Private Sector Housing Grant Programme 0 1,186 0 1,186 1,186 0 0% 2,926 2,926 0 0% Total Housing (PSHG) Programme 0 1,186 0 1,186 1,186 0 0% 2,926 2,926 0 0% TOTAL COMMUNITIES, HOUSING & PLANNING BOARD 53,408 32,048 518 32,566 32,566 0 0% 222,070 222,070 0 0% *Rolling programmes have a prior year year expenditure of £0 as the expenditure is not directly linked from one year to the next as a singular project. Budget Variance (Adverse) or Favourable Budget Variance (Adverse) or Favourable CAPITAL INVESTMENT STRATEGY 1st April to 7th January 2025 POLICY BOARD: COMMUNITES & HOUSING Current Year 2024‐25 Full Programme ‐ All years Page 15 of 204
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__________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 __________________________________________________________________ Report by: Director of Environment, Housing and Infrastructure __________________________________________________________________ Heading: Service Update Report __________________________________________________________________ 1. Summary 1.1 This report provides and overview of key service activities, an operational performance update since the last Policy Board meeting on the services and key projects and updates on any other relevant changes to service areas covered within the remit of this Board. __________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board 2.1 Note the contents of this report. Updates for Communities and Housing Policy Board 3. Housing Services 3.1 Housing Management Income Advice 3.1.1 Information from advice interviews at the end of February 2025 confirms that over 6,236 income advice cases involved households from Council tenancies this financial year. During these interviews staff assess any entitlements to assistance that are due and support people to access benefits they are eligible for, alongside giving advice on all money matters and budgeting. Item 3 CHPB110325 Page 17 of 204
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3.1.2 There are several sources of additional assistance accessed which can include universal credit/housing benefit attendance allowance and disability payment, food vouchers and many more. In monetary terms this equates to £8.3 million between April 2024 and February this year. 3.1.3 Between April 2024 and February 2025 there have been 250 tenants referred for Tenant Support Fund assessment, which have the added value of full income assessment and advice provision. Of the referrals 189 have engaged with Specialist Income Advisors and 170 have qualified for assistance from the fund. Officers continue to engage with tenants to maximise access to any underlying entitlement to benefits and funds available. Housing Advice 3.1.4 There has been continued take up of the option to apply to join the Council’s housing waiting list using the online application form. The online system was introduced in November 2023. At the end of February 2025, we have 3,066 applications received via the online process. 3.1.5 Staff are available to assist in completing online forms. For those applicants who apply online, we offer a follow up housing options discussion. The housing options discussion is an important part of the process, with the aim of assisting those making a housing enquiry to gain a realistic understanding of the choices available to suit their circumstances. 3.1.6 The online housing application is available alongside existing ways to apply, such as telephone, video conferencing (Near Me), and in person as requested. Tenancy Management 3.1.7 Use of the ASB app as a method of online reporting of antisocial behaviour for Renfrewshire Council tenants’ is now in the pilot phase. 3.1.8 Staff have been trained and the App will be piloted for a period of 6 weeks from 8 January 2025. During this period views of staff and customers will be gathered to ensure the App meets the needs of those using it and the service, thereafter, it is anticipated the App will be launched across all housing teams. 3.1.9 The intention of the pilot is to offer the App to customers already engaged with services. Information available to date suggests the App provides additional functionality, it is an all-round tool which enables users to collect and submit noise recordings, diary sheets and videos at the time of an incident. The App is available across all App stores and where a user cannot access the App for any reason a web-based version is available. The App will complement the traditional methods including telephone, email, in writing and in person. 3.2 Housing Innovation Project (HIP) 3.2.1 The Council formally entered into contract with NEC on 29th January 2025 and a project plan with defined milestones and anticipated go live dates for both phases of project implementation was confirmed by the end of February 2025. Page 18 of 204
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3.2.2 Work has begun in earnest with three of the solution design modules now underway in Allocations, Core and Rents. 3.2.3 Recruitment has taken place for Module Team members and four team members are now in place for Allocations, Core, Tenancy Management and Rents Modules. 3.2.4 Work is continuing with NEC to set up Virtual Private Network. Consideration is being given to options available for data migration and archiving and the project team is currently scoping requirements for test and training resources. is being carried out. 3.3 Homeless & Housing Support Services Homeless Applications 3.3.1 The number of homeless applications has continued at the high level of 2023/24, and it is anticipated that there will again be an annual increase in the number of presentations. 3.3.2 The Council is on schedule to meet the target of 55% of general lets going to homeless applicants, and there has been regular liaison with Registered Social Landlords (RSLs) who have responded by similarly having a strong focus on letting their properties to those who are statutorily homeless. 3.3.3 A detailed report will be provided to the next meeting of the Policy Board on a review of 2024/25 performance and an update on the measures in place to mitigate the pressures in the homeless system – including the contribution from RSLs. Early Release Programme 3.3.4 Legislation to help reduce the prison population has been passed by the Scottish Parliament. The Prisoner (Early Release) (Scotland) Bill changes the release point for offenders serving sentences of less than four years from 50% of their sentence to 40%. Homeless Services have been involved in discussions with the Scottish Prison Service and other partners to allow planning for prisoners from Renfrewshire who are will be subject to release over 3 trenches between February and March. Measures have been put in place to provide advice, support and temporary accommodation (if needed) for each prisoner upon their release. Housing Support 3.3.5 Housing Support continue to have very high levels of referrals, with over 950 being received by the end of January since April 2024, which is a significant increase over the last couple of years. Page 19 of 204
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Refugee Resettlement 3.3.6 Our Refugee Resettlement Team are currently supporting 233 households across Renfrewshire, with a small increase in Afghan national arrivals as well as people from Syria and Somalia. Many of the Ukrainians who resettled in Renfrewshire will be eligible to apply for an 18-month visa extension over the coming months. Sheltered Housing 3.3.7 The strong focus on tackling the threat of loneliness continues across our 10 sheltered complexes and a range of meaningful activities, parties and trips to theatre were organised throughout 2024/25. 3.3.8 Joint initiatives have been arranged with our partners such as Erskine Hospital, local schools, Roar - Connections For Life and St Mirren, with music and dance projects/intergenerational working, creative writing projects, domino competitions, and gentle exercise activities. 3.3.9 Our in-house Befriending Services continues to support 13 tenants who do not have family or friends who are able to visit. 3.3.10 There have been improvements carried out to the ‘warden call’ system, and a planned upgrade to fire safety alarms. 3.3.11 The installation of ‘digital notice boards’ at each complex to update tenants with information, support and advice has now commenced. 3.4 Housing Asset and Investment Response to Storm Eowyn 3.4.1 Over 400 repairs were reported in the days immediately following the storm, mainly for minor damage to roofs, guttering, fascia boards, windows and fencing. Colleagues in Building Services attended initially to make safe with follow up repairs arranged as required. 3.4.2 118 inspections were raised during the week following the storm, for the Housing Asset and Investment Team, Repairs and Maintenance officers (RMOs) to attend, the majority of which were for fencing. Repairs to common areas in mixed tenure blocks are required to go through owner consent processes before full repairs can be carried out. 3.4.3 There were 3 properties with more serious damage to roofs that required tenants to be decanted. These properties required to be assessed by the Council’s insurer’s independent loss adjustor prior to reinstatement works being arranged. 3.4.4 There was minor damage to render at Glencairn Court which required the installation of temporary protective measures whilst awaiting the full repair. Page 20 of 204
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3.4.5 The team responded well to the incident with good internal communication through the established winter preparation group. The resultant ongoing repair requirements continue to be managed. Kitchen and Heating Replacement 3.4.6 Housing Services have been working collaboratively with Building Services to consider the feasibility of Building Services undertaking some of the internal capital investment work scheduled over the next 5 years. 3.4.7 Agreement has been reached with Building Services to carry out kitchen replacements and boiler replacements. 3.4.8 Preparations are underway for the required resources to be in place for the new Building Services workstream and it is hoped that work can commence in the second quarter of 2025/26. Targeted annual volume for Building Services will be approximately 350 kitchens and 680 boilers per annum. 3.4.9 The Housing Asset and Investment team will continue to appoint external contractors for other internal investment works such as full kitchen, bathroom and rewires which will supplement the works being carried out by Building Services. The current contract with our external contractor, Bell Group is underway and progressing well. 3.5 Regeneration Update Housing – Led Regeneration and Renewal Programme 3.5.1 Tenant rehousing is complete in blocks approved for demolition in Auchentorlie Quadrant and Waverley Road, Paisley. Officers continue to prioritise phasing of rehousing across the Thrushcraigs and Springbank areas to effectively manage the clearing of blocks in advance of further demolition. 3.5.2 Owner conversations continue to progress well across the programme where acquisition is necessary to facilitate demolition. Similarly, conversations have taken place with several owners in retention blocks within the Auchentorlie area to understand the percentage of private owners within mixed tenure blocks who may be interested in participating in the improvement programme, along with the wholly Council owned blocks receiving enhanced improvements. 3.5.3 Officers from the Housing Investment team are consulting with private owners in the Howard Street area to further encourage participation across mixed tenure blocks as far as possible, before moving on to consult in Howwood Road and Waverley Road areas of the programme later this year. Tannahill Area of Ferguslie Park 3.5.4 The demolition of Council owned blocks in Tannahill area continues to progress well, with all 52 blocks within the initial contract now demolished. Contractors remain on site for site clearance works in line with the contract award. Page 21 of 204
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3.5.5 Voluntary acquisition of the last remaining block in the Tannahill area has been agreed in principle and officers will take forward demolition of this block once the Council have full ownership. Paisley West End 3.5.6 Demolition contractors have been appointed by Sanctuary Housing Association to commence the next phase of demolition in Paisley West End. This is another positive step in the delivery of the wider masterplan approved for this area. The Council will continue to transfer ownership on a phased basis to allow further demolition and newbuild development subject to Planning approval being received in due course. Council Newbuild Projects 3.5.7 Whilst Planning approval has been obtained for both Gallowhill and Howwood Road projects, the statutory approvals process is ongoing in respect of building warrant approval and specifically Scottish Water technical approval for both newbuild developments. 3.5.8 Whilst it is expected approvals will be obtained, officers continue to engage with Scottish Water to ensure the most economic and sustainable design options and solutions are realised. 3.6 Service Improvement Update Scottish Housing Regulator; Outcome of the consultation on the Annual Return on the Charter 3.6.1 At the August Board, members were advised that the Scottish Housing Regulator set out plans to carry out a comprehensive review of the Annual Return on the Charter (ARC) during 2024/25. The Regulator established advisory groups to work with it to consider the current ARC indicators and help it to develop appropriate and meaningful indicators on tenant and resident safety, including new indicators on damp and mould. 3.6.2 This consultation has now concluded and on 14 January 2025 the SHR published its findings and revisions to the ARC return. 3.6.3 The review will see that a small number of indicators have been removed, and a few others have had their definitions improved for clarity. 3.6.4 The Regulator has introduced new tenant and resident safety indicators including fire safety, electrical safety and three new indicators on damp and mould. The SHR has acknowledged complexities regarding the Damp and Mould indicators and as such the usefulness of these indicators will be reviewed after the first year of submission. 3.6.5 All social landlords will start collecting data for the new indicators from 1 April 2025 and the first ARC using the new indicators will be due by 31 May 2026. The Board will receive our performance against these indicators in 2026. Page 22 of 204
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3.6.6 Members can access the full details of the consultation at the following https://www.housingregulator.gov.scot/for-landlords/annual-return-on-the- scottish-social-housing-charter-consultation-outcome/ 4. Public Protection 4.1 Trading Standards 4.1.1 At a UK level, work continues towards a “smokefree future” that is, an eventual full ban on the sale of tobacco. The Tobacco & Vapes Bill will raise the age of sale for tobacco products incrementally, year on year, until the restriction applies to the whole population. This Bill is currently at Committee Stage in the House of Commons. 4.1.2 Operation CECE continues to be a UK-wide priority for HMRC and Trading Standards services, as the illicit trade in tobacco shows no signs of slowing. The Team continues to work with HMRC and Police Scotland to disrupt supply chains, and to impose the most effective enforcement outcomes on offenders. 4.1.3 Figures recovered so far in the financial year 2024/25 are: 7,030 packs of cigarettes, 555 packs of hand-rolling tobacco (28kg), equating to evaded Excise Duty of over £123,000. 4.1.4 Alongside this activity, the Team continue to recover large quantities of non- compliant Nicotine Vapour Products (NVPs or Vapes). Compliance issues include matters such as a lack of health or tactile warnings, or too large a tank size. During routine or unplanned visits, the Team are ensuring traders are aware of the upcoming ban on the sale/supply of single use vapes, which is due to commence on 1 June 2025. Single-use vapes are defined as any vaping device – whether nicotine based or otherwise – which is not both rechargeable and refillable. 4.2 Community Safety 4.2.1 The proposal to implement Fireworks Control Zones (FCZ), where appropriate, was approved at the Communities & Housing Policy Board in August 2024. 4.2.2 A Fireworks Control Zone is defined as a geographical area in which it is illegal to use fireworks outside of a licensed display, on private property. A FCZ can be proposed by the Local Authority themselves, or by a community request. Community requests can be considered where there is justification to do so, by means of 25 or more signatories, as well as evidence of a particular issue which a FCZ can reasonably resolve. Any community requests which can meet the relevant standard, will be considered at a multi-agency group early in March, and any accepted requests will be subject to robust consultation. This is because the imposition of a Zone removes the rights of the citizens in that area to use fireworks in their properties, and indeed would criminalise that use. Page 23 of 204
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4.2.3 The application process for community requests opened on 13 January 2025, and closed on 28 February 2025. Decisions on applications will be published online by the end of March, and any consultation (where relevant) will then take place between April and July. Any established Zones must be publicised at least 60 days before coming into effect and as such must be published by 15 August to be in place for Guy Fawkes period 2025. 4.3 Environmental Health 4.3.1 One of the workplace Health and Safety Priorities for 2024/25 was an assessment of Legionella controls in water systems within hotels. Legionella bacteria is commonly found in water, where the bacteria can multiply where temperatures are between 20-45°C and nutrients are available. Legionnaires' disease is a potentially fatal type of pneumonia, contracted by inhaling airborne water droplets containing viable legionella bacteria. Premises such as hotels must have adequate controls in place to control the risk of legionella. This can include risk assessments, temperature checks of the water system, flushing outlets, improving the design of the water system and sampling. Earlier in the year a general health and safety intervention for hotels were completed and from the information gathered Officers collated a list of hotels, using a risk-based approach, which has been prioritised for a more in-depth Legionella intervention. At the time of the earlier intervention, the level of compliance was found to be generally high; however, where areas of improvement were noted, businesses were provided with advice and guidance. These were subsequently re-visited to confirm compliance. 4.3.2 Officers within the Business Regulations Team have recently completed training on non-surgical cosmetic procedures in advance of the proposed introduction of a new licensing regime to effectively regulate the industry. It is proposed that some lower risk procedures will be licenced by local authorities and Officers require to understand the procedures, their safe administration and use of properly regulated products/medicines as part of the proposed licensing requirement. 4.3.3 The Environmental Health, Business Regulation Team were recently contacted by a multinational company with a premises in Hillington to advise that they had been impacted by a RASFF (Rapid Alert System for Food and Feed). The RASFF system allows for the exchange of information between members countries to support swift reaction by food safety authorities in cases of public health risks arising from the food chain. In this instance the business was advised that a Soya Flour (from a supplier in Serbia) was found to have levels of Aflatoxin B1 above, EU permitted levels. 4.3.4 The business had acted quickly and whilst 40 bags of finished product had been delivered to a customer based in Northern Ireland, 38 of these were unused and quarantined. The remaining 2 bags had been used by the customer to produce products which were already within the market, however a risk assessment was carried out to assess these and because of inclusion rates of flour within the finished products, the Aflatoxin B1 levels were within the permitted levels. All the remaining stock of the soya flour has been held on site in Hillington and all further imports of the Soya Flour had been blocked by the business. Page 24 of 204
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4.3.5 Food Standards Scotland were contacted regarding the issue to make them aware as RASFF notification had not been received in the UK. Officers continue to work with the business and FSS regarding the issue, with FSS providing evidence that the product had been distributed within the UK to the European Commission. 5. Connected Communities Service Update 5.1 CLD Inspection Follow Up 5.1.1 Elected members will recall that Education Scotland undertook an inspection visit in Renfrewshire last February. As previously reported to board we have implemented a number of changes to partnership governance arrangements relating to the delivery of CLD support across all sectors and have also developed and finalised a CLD Partnership Plan. 5.1.2 In recent months we have been working closely with Education Scotland on our partnership development and self-assessment processes, and we anticipate that a follow up visit from the inspection team will take place in March 2025. 5.2 Good Vibes Only Programme Update 5.2.1 As our community outreach work continues in communities across Renfrewshire, we are preparing our next Good Vibes Only programme targeting a new group of young people identified by the Community Safety Partnership. The programme will run for seven weeks during the spring months and feature contributions from Police Scotland, British Transport Police, Scottish Fire & Rescue Service, Youth Services and the Youth Team. Participants will also visit the Regen FX project (The Street) and those who complete the course will receive a personal recognition reward. 5.3 Safe Kids Event 5.3.1 We are currently planning the next Safe Kids event, scheduled to take place before the summer. This event is open to all primary 6 children and aims to educate them on key community safety issues. 5.4 Anti-Social Behaviour Talks 5.4.1 The Community Safety Youth Team continue to deliver anti-social behaviour talks to P7 and S1 students delivering key messages to raise awareness of the impact antisocial behaviour has on our communities and potential consequences should they choose to get involved in risk taking behaviour. Positive feedback has been received from teachers and young people. 5.5 Renfrewshire Youth Commission 5.5.1 The Renfrewshire Youth Commission will be launching in February with the first meeting of young people who voiced an interest at the Youth Assembly. Page 25 of 204
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The group will evaluate the event and begin to collate the findings from the workshops on Safety, Vaping and Violence, and begin to draft the report and proposed work for the Youth Commission into tackling the issues around Violence in 2025. 5.5.2 The End of Project Celebration and Awards Ceremony will be held on 14 March 2025, in Paisley Arts Centre which will celebrate Art Boss, the Creative Young Producers programme that has transformed lives and empowered young people in Renfrewshire since its launch in 2020. This event marks the culmination of an incredible journey of artistic exploration and professional growth by care- experienced young people and young carers aged 12-21. The event will include the presentation of accredited Arts Awards, showcase exhibition of creative projects and highlights from the programme, and a chance to celebrate the collective achievements of our young producers and the community that supported them. 5.6 Duke of Edinburgh 5.6.1 Duke of Edinburgh’s Awards have 524 active DofE participants of whom 26.3% are SIMD 1-3 (which is an increase of 3% from last quarter) and 127 active DofE leaders and supporting adults. The DofE Programme in Renfrewshire is now 48% school based, and 52% in the community, and focussed on targeted groups and 3rd sector. The DofE Celebrations was held at the Paisley Town Hall on the evening of 19 February 2025, focussing on the theme of “Impact” on young people, and their communities. 6. Environmental Taskforce 6.1 Team Up to Clean Up 6.1.1 Team Up to Clean Up grew to 7,000 group members by the end of January ‘25. Overall group viewings increased significantly in January, most likely, because of volunteers and neighbours supporting one another to clean up their neighbourhoods after Storm Eowyn. One post, which focused on neighbours grouping together to clean their street after bins toppled and a tree feel down, reached over 100,000 views. The highest number of daily posts and activity since summer ‘24 was noted on 25 January, with 36 posts of activity, and over 60,000 views to the group. 6.1.2 Fixed signage has been installed on Moss Road to deter flytipping. The sign warns potential offender’s cameras and ANPR (automatic number plate recognition) are in the area. Similar signage has been erected in alternative local rural hotspots warning perpetrators the area is a “No Flytipping Zone”. 6.1.3 Poles have been erected on Moss Road and other rural areas to facilitate mobile cameras. Cameras stream images back to the Environmental Taskforce Officers to assist in identifying those responsible for flytipping. 6.1.4 A positively worded fixed sign, aimed at reducing litter, has also been erected in the Gleniffer Braes car park. Page 26 of 204
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__________________________________________________________________ Implications of the Report 1. Financial – Any financial elements referenced in this report will be progressed through the Council’s financial & budget planning process. 2. HR & Organisational Development – None. 3. Community/Council Planning – The report details a range of activities which reflect local community and council planning themes. 4. Legal – None. 5. Property/Assets – None. 6. Information Technology – None. 7. Equality & Human Rights – The recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – None. 9. Procurement – None. 10. Risk – None. 11. Privacy Impact – None. 12. Climate Risk – there are a range of actions and activities throughout the Service Update Report which support the Council’s Plan for Net Zero. 13. Children’s Rights – None. 14. Cosla Policy Position – None. _______________________________________________________ List of Background Papers: None. _______ __________________________________ Author: Gordon McNeil, Director of Environment, Housing & Infrastructure Email: Gordon.mcneil@renfrewshire.gov.uk Page 27 of 204
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 __________________________________________________________________ Report by: Director of Environment, Housing and Infrastructure ___________________________________________________________________ Heading: Renfrewshire Common Housing Allocation Policy Review 2024 ___________________________________________________________________ 1. Summary 1.1 The Renfrewshire Common Housing Allocation Policy came into effect in 2019. As well as Renfrewshire Council, four local Registered Social Landlords (RSLs) operate the policy, namely Bridgewater Housing Association, Linstone Housing Association, Paisley Housing Association and Williamsburgh Housing Association. 1.2 The policy was scheduled for review three years after its inception, but due to the impact of the pandemic on housing lets this review was postponed until 2024 to ensure three full years of normal letting activity. 1.3 This report provides a summary of the policy review and the amendments therein. The areas for clarification and minor rewording of the policy are advised at paragraphs 4.7 and 4.8 within this report. The revised policy is attached at Appendix 1. ______________________________________________________________ 2. Recommendations It is recommended that the Policy Board 2.1 Note the outcome of the review. 2.2 Approve the Renfrewshire Common Housing Allocation Policy. If approved the policy will be effective from today and subject to a review in three years. Item 4 CHPB110325 Page 29 of 204
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3. Renfrewshire Common Housing Allocation Policy Review 2024 3.1 The Communities Housing and Planning Policy Board approved the Renfrewshire Common Housing Allocation Policy on 19 January 2019. 3.2 The Renfrewshire Common Housing Allocation Policy is used by the Council and four local housing associations: Bridgewater, Linstone, Paisley and Williamsburgh. The policy gives priority to people in the greatest need of housing and in line with housing legislation, the policy gives reasonable preference to: People who are homeless or threatened with homelessness. People living in unsatisfactory housing conditions. Tenants of social housing landlords who are considered to be under- occupying their current home 3.3 The Policy places applicants into one of five groups as set out in the table below, based on their circumstances. Depending on the group applicants are placed in, a level of priority may also be awarded, as shown below. Where an applicant has more than one type of housing need, they may be awarded an additional level of priority - a ‘plus’ award to recognise cumulative need. Statutory Homeless Group Mobility Group (general and transfer applicants) General Applicants Group (not landlord’s own tenants) Transfer Applicants Group- with housing need Transfer Applicants Group- no housing need Statutory homeless A critical need A critical need A critical need Based on date of application B urgent need B urgent need B urgent need C moderate need C moderate need C moderate need D no need D no need 3.4 It was agreed that the Policy should be reviewed after three years of operating, but due to the pandemic it was agreed by all parties that this should be postponed until 2024 to ensure there was three full years of normal letting activity. 4. Review findings 4.1 A desktop review of lets over the period 2019 – 2024 was undertaken and discussions between the Council and the four participating RSLs took place during 2024. 4.2 On the whole, officers from both the Council and partner RSLs are of the view that the policy is effective and helps manage the demand for social housing, particularly in the current climate where demand is high, and increasing homelessness continues to be a critical factor for the housing sector. Page 30 of 204
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4.3 Renfrewshire Council Lets through the Group System Lets through group system 2020/2021 2021/2022 2022/2023 2023/2024 Group Number of Lets % Number of Lets % Number of Lets % Number of Lets % Statutory Homeless 245 49.0% 368 42.9% 316 41.4% 390 54.0% Mobility 74 14.8% 117 13.7% 98 12.8% 108 15.0% General Applicants (not landlords own Tenant) 128 25.6% 255 29.8% 265 34.7% 158 21.9% Transfer Applicants (with housing need) 47 9.4% 93 10.9% 72 9.4% 64 8.9% Transfer Applicants (no housing need) 6 1.2% 24 2.8% 13 1.7% 2 0.3% Total Group lets 500 857 764 722 Local RSL Lets *All lets 380 508 476 390 *The RSL figures are reported in the ARC return to the Scottish Housing Regulator includes Section 5 (homeless) Nomination lets. RSLs do not let direct to Homeless applicants, the Council nominate S5 applicants to RSLs through the S5 & Nominations policy. Some of our nominations are successfully let and others are withdrawn. The RSLs only report applicants assessed as Homeless by LA, this is not actual lets to homeless by RSLs. The table demonstrates the policy meets the demand of the housing system and there is flexibility within to address changes in demand. 4.4 The Policy Board has received regular updates on homelessness noting that, as is the case across Scotland, there has been an increase in homeless applications in Renfrewshire. The policy has assisted in partnership working to continue to tackle this, with the Council and RSL partners meeting regularly to ensure targets are met. Allocation group targets are reviewed regularly and the Council’s target for allocations to homeless applicants has been increased each year to reflect the rise in homeless applications. 4.5 Following discussions with officers involved at various stages of the allocation process their feedback is positive. Although operational activity has been impacted at various times, due to the pandemic, officers have been able to identify elements of the policy that have worked well along with some suggestions that may enhance the policy. These will help further improve customer experience when applying for and being allocated housing as well as ensuring we continue to meet the policy aims. 4.6 There have been no significant changes to guidance or legislation affecting housing allocations since the policy was implemented in May 2019. Page 31 of 204
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The current Housing (Scotland) Bill proposes a requirement for social landlords to develop and implement a policy which sets out how they will support tenants who are at risk of homelessness due to domestic abuse. A draft policy is currently being discussed with colleagues in other services. Once developed this policy will be brought to Board for members consideration. 4.7 The review concluded that there were only minimal changes required to the policy. There are 4 areas of the policy to be updated with greater clarity provided, the details of these areas of clarification or amendment are set out in the table below. Point of discussion/Item Comments Agreed Child residence An entitlement for an additional bedroom is acknowledged but the applicant does not receive a priority for this additional bedroom. It was agreed this should be treated as a level C (moderate need) in policy. Critical Housing Needs (Priority A) Discuss either expanding this priority or creating another priority for any customers experiencing similar circumstances but who do not fall under the Domestic Abuse definition used in the allocation policy. It was agreed that applicants presenting with Domestic Abuse should be given priority A (critical need) Applicants with priority who need extra bedroom An applicant can, as a consequence of an extra bedroom requirement, be awarded an underoccupancy priority due to this extra bedroom being needed. This should be looked at further to see if there are ways to address situations like this where the underoccupancy priority award is not appropriate. It was agreed that there would be certain circumstances where underoccupancy would not be considered as appropriate. Housing Need/Refusal of Offers Consider adding the ability to remove a housing need priority if an applicant continually refuses suitable offers of rehousing. It was agreed that this should not be considered a route to access a better property. Should be timebound and restricted number of offers. Policy should be reworded slightly as proposed at 4.8 below to accommodate this. (This is paragraph 4.5 in the Allocation Policy) 4.8 Proposed change to wording 4.5 Responding to critical housing need Our policy is designed to allow us to respond to critical housing need. We are committed to ensuring that people in critical housing need are rehoused as quickly as possible. If you receive an A+ or A priority you have been assessed as having very serious housing needs and we will work with you to make sure we can make you a reasonable offer of housing which meets your needs. Page 32 of 204
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However, we will not expect you to be unnecessarily restrictive in the types of housing or areas for which you will be considered. In particular, if a flat or maisonette would meet your needs we may offer you a property of that type and would consider that to be a reasonable offer. We will also ask you to be flexible about the areas in which you would consider being housed. If we have not been able to make you an offer in one of your areas of choice within 28 days of receiving your A+ or A priority, you will be asked to consider adjoining areas. If you refuse an offer of housing, we will invite you to a housing options and information interview to discuss the best way of ensuring we are able to help you as quickly as possible. We want to avoid having to suspend your housing application, in recognition of the critical nature of your housing needs. 4.9 The Promise, Young people with experience of the care system The Policy has also been refreshed to take account of Corporate Parenting and responsibilities for young people who have experience of the care system, acknowledging that the Council will work closely with any care experienced young person and Health and Social Care partners looking for housing to support keeping Scotland’s Promise. We will support them to complete a housing application and will work with them to find them a home which meets their needs. __________________________________________________________________ Page 33 of 204
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Implications of the Report 1. Financial – None. 2. HR & Organisational Development – None. 3. Community/Council Planning Building strong, safe, and resilient communities – Improving and maintaining neighbourhoods and homes. Working together to improve outcomes – Increasing resident satisfaction with neighbourhoods and communities. 4. Legal – None. 5. Property/Assets – None. 6. Information Technology – None. 7. Equality & Human Rights – The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report because it is for noting only. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – None. 9. Procurement – None. 10. Risks – None. 11. Privacy Impact – None. 12. COSLA Policy Position – N/A. 13. Climate Risk – None. 14. Children’s Rights – None. _________________________________________________________ Background Papers Report to the Communities, Housing and Planning Policy Board on 15 January 2019, ‘Renfrewshire Common Housing Allocation Policy’. Page 34 of 204
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The foregoing background papers will be retained within the Housing Service for inspection by the public for the prescribed period of four years from the date of the meeting. Author: Ray Walkinshaw, Housing Regeneration and Development Manager E Mail: ray.walkinshaw@renfrewshire.gov.uk ___________________________________________________________________ Page 35 of 204
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1 Renfrewshire Common Housing Allocation Policy May 2019 Date approved 15 January 2019 Date implemented 01 May 2019 Date to be reviewed 01 May 2022 Date of Review 05 November 2024 Date of reviewed Policy Implementation 11 March 2025 (TBC) Page 36 of 204
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2 CONTENTS 1. Introduction ................................................................................................. 5 1.1 About this policy........................................................................................... 5 1.2 The partner landlords ................................................................................... 5 1.3 Our policy aims ............................................................................................. 6 1.4 Equality and diversity ................................................................................... 7 1.5 Confidentiality and data protection ............................................................. 7 1.6 Law, good practice and the Scottish Housing Charter.................................. 7 1.7 Developing and reviewing this policy ........................................................... 8 2. Making an application .................................................................................. 9 2.1 Who can apply? ............................................................................................ 9 2.2 Information and advice for applicants ......................................................... 9 2.3 Information provided by applicants ........................................................... 10 2.4 Persons who are subject to Immigration Control ...................................... 10 2.5 Applications from staff, elected members or committee members .......... 11 3. Assessing what size of home you need ....................................................... 12 3.1 Number of bedrooms ................................................................................. 12 3.2 Child residence, contact or access arrangements ...................................... 14 3.3 Other reasons for additional bedrooms ..................................................... 14 4. The housing list and how applications are prioritised ................................. 16 4.1 Factors we must take into account ............................................................ 16 4.2 Unmet housing needs ................................................................................ 16 4.3 Factors we cannot consider ....................................................................... 17 4.4 Our group system ....................................................................................... 17 4.5 Responding to critical housing need .......................................................... 20 4.6 Health and Social Care Priority ................................................................... 20 4.7 Critical housing needs (Priority A) .............................................................. 21 4.8 Urgent housing needs (Priority B) .............................................................. 23 Page 37 of 204
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3 4.9 Moderate housing needs (Priority C) ......................................................... 25 4.10 No assessed housing needs (Priority D) ..................................................... 26 4.11 Further information on Statutory Homelessness Group ............................ 27 4.12 Further information on Mobility Group ..................................................... 28 4.13 Young people with experience of the care system .................................... 28 4.14 Exceptions to the policy, including special lets & management transfers 29 4.15 Mutual exchange ........................................................................................ 30 4.16 Sheltered housing ...................................................................................... 30 5. How we allocate housing ............................................................................ 31 5.1 Allocation targets ....................................................................................... 31 5.2 Nominations and referrals ......................................................................... 31 5.3 How we allocate our properties ................................................................ 32 5.4 Number of offers ....................................................................................... 32 5.5 Tenancy agreements .................................................................................. 33 5.6 Joint tenancies ........................................................................................... 34 5.7 Specially designed or adapted properties .................................................. 34 6. Application status ....................................................................................... 36 6.1 Reviewing applications .............................................................................. 36 6.2 Deferring your application ......................................................................... 36 6.3 Suspension from housing lists ................................................................... 37 7. Other Information ...................................................................................... 41 7.1 Local Lettings Initiatives ............................................................................. 41 7.2 Other lettings approaches ......................................................................... 41 8. Appeals and complaints .............................................................................. 42 8.1 Appeals ...................................................................................................... 42 8.2 Making a complaint ................................................................................... 43 9. Assessing our performance ......................................................................... 44 9.1 Reporting on our performance .................................................................. 44 9.2 Reviewing this policy .................................................................................. 44 Page 38 of 204
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4 List of Appendices Appendix 1 Common Housing Allocation Policy Partners…..……………………45 Appendix 2 Complying with legislation and good practice…..………………….47 Appendix 3 Below Tolerable Standard……………………………………..……………..49 Appendix 4 Succeeding to a Tenancy…………………………………………..….………50 Appendix 5 Assigning a Tenancy………………………………………………………….….52 Appendix 6 Joint Tenancy…………………………………………………………………...….54 Appendix 7 Mutual Exchange…………………………………………………………….……56 Appendix 8 Recovery of Adapted Properties……………………………………….….57 Appendix 9 Statutory Definition of Overcrowding………………………………….59 Appendix 10 Sheltered Common Allocation Policy…………………………………..61 Page 39 of 204
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5 1. Introduction 1.1 About this policy The Renfrewshire Common Housing Allocation Policy (the policy) has been developed in partnership between Renfrewshire Council, Bridgewater Housing Association, Linstone Housing Association, Paisley Housing Association and Williamsburgh Housing Association. This policy is a public document and will be made available on each of our websites. Copies will also be available from our offices. It sets out an agreed, common approach that partner landlords will use to allocate homes that become available for let. By allocating, we mean the process of selecting people from our housing list, offering them a house and, if they accept, signing a tenancy agreement with them. In certain circumstances, participating landlords may choose to exercise all or some of the optional conditions as set out in this policy. This would be done on a case by case basis, to allow the fair and efficient operation of the letting process. This policy is based on a group plus priority approach and has a clear focus on meeting housing need. It replaces all previous allocation policies of the partner landlords. We will review the policy every 3 years, unless changes to legislation, regulation or the results of our performance monitoring require otherwise. 1.2 The partner landlords Summary information on each of the four landlords that operate the policy is set out below. Further information about each landlord, including where they have properties and how many properties usually become available for let, can be accessed on each landlord’s own website or by visiting one of their offices. Renfrewshire Council is the largest social rented sector landlord in the area with 12,305 properties across Renfrewshire. These include general needs housing, housing for older people and sheltered housing properties. Bridgewater Housing Association has 847 properties in Erskine. These include general needs, sheltered and extra care housing as well as amenity and wheelchair accessible homes. Page 40 of 204
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6 Linstone Housing Association has 1,572 properties located mainly in Linwood and Johnstone with the remainder spread throughout Paisley, Renfrew and villages throughout Renfrewshire. Their properties include general needs housing and housing for older people. Paisley Housing Association has 1,302 properties, the majority of which are for general needs but they also have some amenity properties and homes for wheelchair users. The properties are in Foxbar, Glenburn, and in the South, West and Town Centre of Paisley. Williamsburgh Housing Association has 1,685 properties. The majority are general needs but they also have some amenity properties and homes for wheelchair users. Their properties are in Paisley East, West and North, Renfrew and Johnstone. A number of other social landlords provide housing in Renfrewshire. Further information on these landlords can be found in the housing section of the Renfrewshire Council website at www.renfrewshire.gov.uk and in Appendix 1 of this document. 1.3 Our policy aims We are committed to providing high quality, affordable housing that meets housing needs. When allocating properties, we will aim to: Make sure we offer people accommodation that meets their needs. Maximise housing options. Make best use of the properties that are available for let. Help build sustainable communities by creating successful and sustainable tenancies. Work to provide excellent customer services to those seeking housing in Renfrewshire. Meet all our legal obligations and operate under the principles set out in the Scottish Social Housing Charter. We will do this by taking an approach to allocating homes that: Is fair, open and transparent. Takes a consistent approach to decision‐making. Promotes equality. Page 41 of 204
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7 Treats all applicants with respect, including respecting the confidentiality of information given to us. 1.4 Equality and diversity We are committed to preventing discrimination and providing equal opportunities for everyone who applies to us for housing. In applying this policy, we will not discriminate against any individual, household or group on grounds of race, gender, sex, marital status/civil partnership, gender reassignment, sexual orientation, pregnancy or maternity, religion or belief, language, social origin, disability, age or other personal attribute. We will make this policy available in alternative formats such as large print or Braille on request. Translation services for other languages can also be made available. Where practical, we will arrange for an interpreter if you speak a language other than English. We can also provide a British Sign Language interpreter if required. 1.5 Confidentiality and data protection Any information given to us as part of the application process will be processed in compliance with Data Protection legislation. You can ask to look at the information held on your record. If you wish to do this, you should make a written request to the relevant landlord. We will respond within one calendar month. We will not keep your personal information longer than is needed. 1.6 Law, good practice and the Scottish Housing Charter This policy has been developed to be compliant with housing and other relevant legislation. A list of the laws which have been taken into account are set out in Appendix 2. The policy also takes account of good practice guidance from the Scottish Government and the Scottish Housing Regulator. This includes the standards set out in the Scottish Social Housing Charter. Page 42 of 204
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8 Further information can be found on the Scottish Government’s website at: http://www.gov.scot/Publications/2012/03/2602 1.7 Developing and reviewing this policy We will consult with housing applicants, tenants, registered tenant organisations and others when developing and making changes to this policy. We will review this policy every three years, or earlier if required in light of changes in the law or good practice guidance. Page 43 of 204
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9 2. Making an application 2.1 Who can apply? Each of us operates our own separate housing list. You can get information on how to join each landlord’s list by contacting them directly. Contact information for each of us is included in Appendix 1. Anyone aged 16 years or over is entitled to apply and be placed on any of the lists, provided they are eligible to receive an offer of housing. You can make a joint application with another person or people who want to live with you, even if you are not living in the same household at the moment. 2.2 Information and advice for applicants We recognise the importance of offering high quality information and advice to those applying for housing in Renfrewshire. Someone making an application may be invited to attend an interview with the landlord to whom they are applying. We will provide information on: How we will process your application. How long it will take to process and decide on your application. Affordability, including the average cost of renting a property. Some landlords may also be able to discuss other housing options with you. In many areas of Renfrewshire, the demand for housing is considerably higher than the supply. We may not be able to make everyone an offer of housing or people might have a long wait. This is most likely to be the case if you have no or low‐ level housing need and you are looking to be housed in one of the areas for which demand is higher and the number of properties becoming available is low. However, in areas in which demand is lower and more properties become available, you may have a greater chance of being made an offer. We will give you realistic advice about the likelihood of being re‐housed based on the choices you have made. We will also provide information on opportunities to find housing with other local providers. Page 44 of 204
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10 If you cannot call into the office of the landlord(s) to which you have applied because you have health or mobility problems, a member of staff will visit you at home or arrange a telephone interview. If you live outwith Renfrewshire, or we are not able to visit for some other reason, we will send you an application by post. 2.3 Information provided by applicants It is important for us to have accurate and up‐to‐date information on your circumstances. If you fail to provide the necessary information to support your application, this may mean that your application cannot be fully assessed. We will ask you to provide any required information and will re‐assess your application once that information has been received. If we do not receive the information we have asked for within 30 days of us asking for it, your application may be cancelled. If you deliberately provide false or misleading information, or withhold information, your application may be suspended. Any offer of housing that has been made may be withdrawn and if a tenancy has been granted on the basis of false information, your landlord could take action to end the tenancy. You must tell us if your circumstances change as this could affect your housing application. Changes of circumstances might include you moving to a new house, someone moving into or out of your current home or someone having a baby. Changes such as these could affect the size of property you require and how your housing need is assessed. It is important to contact each of the landlords you have applied to and tell them about the changes. 2.4 Persons who are subject to Immigration Control The law covering asylum and immigration is complex and applies differently to the Council and the housing association partners. If you could be affected by the legislation, you must tell us. We may be unable to assist but may be able to provide details to you of agencies who can help you. Page 45 of 204
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11 2.5 Applications from staff, elected members or committee members Applications made by staff, elected members or management committee members will be accepted onto the housing list in the same way as other applicants. We will comply with all relevant legislation, regulatory guidance and best practice in dealing with any of these applications. To make sure that no‐one benefits from a personal connection, applicants will be asked and required to declare whether they are related to a member of staff, management committee member or elected member for the landlord to which they are applying. Further information will be set out in the housing application form. Page 46 of 204
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12 3. Assessing what size of home you need 3.1 Number of bedrooms We will work out the number of bedrooms that you require based on who will be living with you. Although we want to give you as much choice as possible, we need to balance this with making best use of the properties that become available. We also want to work with you to make sure your choices are affordable. Our starting point will be to assess the number of bedrooms required as follows: Couples/partners share one bedroom. Other adults or single parents have one bedroom. Two children of the same sex under the age of 16 share one bedroom. Two children under the age of 10, regardless of their sex, share one bedroom. Children of different sexes will need a bedroom each once they reach 10 years old, unless there is another child in the household of the same sex with whom they could share a bedroom. No more than two people should share a bedroom. Where applicants or other members of the household are pregnant, we will include their unborn child/children when working out the number of bedrooms required from 3 months before the due date. Household size House size Single person 1 bedroom or bedsit Couple/partners 1 bedroom Couple/partners or single parent with 1 child 2 bedrooms Couple/partners or single parent with 2 children 2 or 3 bedrooms (depending on the age and sex of the children) Couple/partners or single parent with 3 children 3 or 4 bedrooms (depending on the age and sex of the children) Couple/partners or single parent with 4 children 3 or 4 bedrooms (depending on the age and sex of the children) Couple/partners or single parent with 5 or 6 children 4 bedrooms (depending on the age and sex of the children) Page 47 of 204
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13 The type and size of properties becoming available will vary depending on the stock of each landlord. In particular, some landlords may have properties with smaller bedrooms. Some partners have properties with bedrooms which they have classed as single bedrooms. If a bedroom has been classed as a single bedroom, any offer made by the landlord will be based on only one person occupying that bedroom. We will aim to make good use of each property becoming available by offering it to a household which needs a property of that size. However, if there is limited interest in a property amongst those needing a property of that size, we may consider making offers to other households. In certain circumstances, when offering a property, landlords may choose to make offers of properties of one bedroom more than the applicant requires. This would be for high priority applicants, where Renfrewshire Council requires to fulfil their statutory duty. This would only be done where the applicant has indicated that they would accept a property that has one more bedroom than they require. We also recognise that some applicants may prefer that children do not share bedrooms. You can request that the bedroom requirement be assessed based on children aged 10 or over having their own bedroom. However, we would only consider you for a property with the higher number of bedrooms if there is no other household in housing need and requiring a property of that size. If you did decide you would prefer to have the additional bedroom, this bedroom would not be taken into account when assessing any priority based on overcrowding. There is a very limited supply of larger properties. If you need a property with 4 or more bedrooms we will work with you to make sure that your area choices maximise your chance of being made an offer. However, given our stock limitations and lack of suitable supply of appropriately sized homes, we may in some circumstances have to make an offer of a property that will reduce a household’s overcrowding or under occupying, but may not fully meet their accommodation requirements. This will only be done under exceptional circumstances to improve a household’s overall housing situation. Page 48 of 204
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14 3.2 Child residence, contact and access arrangements For parents, guardians and kinship carers with formal residency rights and overnight contact orders or overnight access arrangements that are shared on an equal basis (child staying overnight an average of at least 3 nights a week at each home), a child may be entitled to a bedroom within each home in accordance with our bedroom entitlement. Where a child or children stay less than an average of 3 nights a week at the home, one additional bedroom more than required by the rest of the household may be provided. This will be irrespective of the number of children for whom the home will not be their principal home. This bedroom would not be taken into account when assessing any priority based on overcrowding. In exceptional circumstances, a senior officer may exercise discretion in deciding upon the size of a home a household requires. 3.3 Other reasons for additional bedrooms We understand that there may be other circumstances which can affect the number of bedrooms you need. The Department of Work and Pensions regulations covering the UK Government’s Under‐Occupancy charges also recognise certain circumstances under which you may require an extra bedroom. We will discuss this with you on a case‐by‐case basis. You may be entitled to an additional bedroom under the following circumstances: If there is a health, care or mobility reason for needing an additional bedroom. For example, for a carer (or team of carers) that provides someone in the household with overnight care or if a long‐term condition (such as dementia) makes it difficult for a couple to share a room. This bedroom entitlement would be used to assess any priority based on overcrowding. If someone in the household is, or wishes to be, a kinship carer for a child or children but those children are not yet living in the household. This bedroom entitlement would be used to assess any priority based on overcrowding. Page 49 of 204
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15 If someone in the household is caring for a foster child or has been accepted as a foster carer but has no child living with them, as long as the period without a child does not exceed 12 months. If someone has applied to foster and have been approved in principle, pending suitable housing, they could be listed as looking for a property with an additional bedroom. However, we would not make an offer of a property with an additional bedroom until their application to foster has been approved by Renfrewshire Council or any other fostering agency. This bedroom entitlement would be used to assess any priority based on overcrowding. If someone in the household is adopting a child or has been approved in principle pending suitable housing, they could be listed as looking for a property with an additional bedroom. However, we would not make an offer of a property with an additional bedroom until their application to adopt has been approved by Renfrewshire Council or any other adoption agency. This bedroom entitlement would be used to assess any priority based on overcrowding. Page 50 of 204
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16 4. The housing list and how applications are prioritised This policy has been developed to give priority to those in the greatest housing need and all applications will be assessed and given priority in accordance with this policy. 4.1 Factors we must take into account There are certain factors which the law states we must consider when deciding to whom we offer any homes that become available. Housing legislation states that we must give reasonable preference to: People who are homeless or threatened with homelessness and who have unmet housing needs. People living under unsatisfactory housing conditions and who have unmet housing needs. Social housing tenants who the landlord allocating a property considers are under‐occupying their current home. These reasonable preference categories have been considered in the development of this policy. 4.2 Unmet housing needs The Housing (Scotland) Act 2014 sets out the categories of applicant to whom social landlords must give reasonable preference if they have unmet housing needs. This means that landlords should consider whether applicants have housing needs which cannot be met through other housing options which are available. Landlords should consider what those other options might be and whether they are accessible to the applicant. The Housing (Scotland) Act 2014 removes the prohibition on taking ownership of property into account in allocating social housing. This means that if you or someone else on your application owns land or property, or previously owned land or property, we may take this into account when deciding on your priority for social housing. This applies to existing tenants as well as new applicants. Page 51 of 204
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17 4.3 Factors we cannot consider There are also certain factors which the law states we cannot consider when allocating housing. These are: How long an applicant has lived in the area. Any debt relating to a house of which the applicant was not a tenant. Any rent or other debt the applicant built up on a previous tenancy which has now been paid. Any amount which still needs to be paid where: ‐ The amount owed is not more than 1/12th of the yearly amount due (or which was paid) by the applicant to the landlord for the tenancy; or ‐ The applicant has an agreement in place with the landlord to repay the money, has made payments in line with the arrangement for at least three continuous months, and is continuing to make these payments. Any outstanding debts (including missed Council Tax payments) which do not relate to the tenancy of a house. The age of the applicant, as long as he or she is 16 or over except when allocating: ‐ Houses which have been designed or substantially adapted for a particular age group; or ‐ Houses for people who are, or will be, receiving housing support services for people of a particular age group. The income of the applicant and his or her family. 4.4 Our group system Our housing list is divided into five groups. Your application will be assessed based on your circumstances and will then be placed into one of those groups. Homelessness: Applicants will be placed in this group if the Council has found them to be unintentionally homeless. Mobility Group: Applicants will be placed in this group if they require a home which is suitable for someone needing an adapted or accessible property. All Page 52 of 204
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18 applicants, including those who are already a tenant of the landlord they are applying to but are looking for a move, will be placed in this group General Applicants Group: Applicants will be placed in this group if they have been assessed as having a housing need but are not a tenant of the landlord to which they have applied. This group includes but is not restricted to: owner‐ occupiers, tenants of private landlords, people living ‘care of’ and tenants of social landlords other than the one to which they are applying. Transfer Applicant Group (with housing need): Applicants will be placed in this group if they have been assessed as having a housing need, are a tenant of the landlord to which they have applied, and they do not need an adapted or accessible property (in which case they will be placed in the Mobility Group). Transfer Applicant Group (no housing need): Applicants will be placed in this group if they are assessed as not being in housing need, are a tenant of the landlord to which they have applied, and they do not need an adapted or accessible property (in which case they will be placed in the Mobility Group). Depending on the group your application has been placed in, we may also award a level of priority to your application. We use four levels of priority, with Priority A being for those in the most urgent need. If you have more than one type of housing need you will be awarded an additional level of priority. We refer to this as a ‘plus’ award. Our approach is set out in the table below. Page 53 of 204
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19 Statutory Homeless Level of Priority Mobility Group (general and transfer applicants) General Applicants Group (not landlord’s own tenant) Transfer Applicants Group (with housing need) Transfer Applicants Group (no housing need) No other award required Priority A: Critical Need Priority A +: Critical Need and one or more other need (Priority A to C) Requires a mobility property Critical health and social care, mobility, domestic abuse, harassment, insecure accommodation, leaving institutions or specialist accommodation, overcrowding or below tolerable standard. + award: another of the above or one or more of the B or C awards below. Critical health and social care, domestic abuse, harassment, insecure accommodation, leaving institutions or specialist accommodation, overcrowding or below tolerable standard. + award: another of the above or one or more of the B or C awards below. Critical health and social care, domestic abuse, harassment or overcrowding. + award: another of the above or one or more of the B or C awards below. No need based award possible Based on date of application Priority B: Urgent need Priority B +: Urgent Need and one or more other need (Priority B or C) Requires a mobility property Urgent health and social care, mobility, social, community or family support, harassment, overcrowding, under‐ occupying or relationship breakdown. + award: another of the above or one or more of the C awards below. Urgent health and social care, social, community or family support, harassment, overcrowding, under‐occupying, relationship breakdown. + award: another of the above or one or more of the C awards below. Urgent health and social care, social, community or family support, harassment, overcrowding, under‐ occupying, or relationship breakdown. + award: another of the above or one or more of the C awards below. Priority C: Moderate need Priority C+: Two or more moderate housing needs Requires a mobility property Moderate health and social care, mobility, social, community or family support, insecure accommodation, leaving institutions or specialist accommodation, overcrowding, under‐occupying, take up or stay in employment. + award: another of the above. Moderate health and social care, social, community or family support, insecure accommodation, leaving institutions or specialist accommodation, overcrowding, under‐occupying, take up or stay in employment. + award: another of the above. Moderate health and social care, social, community or family support, overcrowding, under‐occupying, take up or stay in employment. + award: another of the above. Priority D: No housing need Lives in a property that meets their mobility needs. Would need to be rehoused into a mobility property. No housing need. No housing need. (Placed in Transfer with no housing need group) Page 54 of 204
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20 4.5 Responding to critical housing need Our policy is designed to allow us to respond to critical housing need. We are committed to ensuring that people in critical housing need are rehoused as quickly as possible. If you receive an A+ or A priority you have been assessed as having very serious housing needs and we will work with you to make sure we can make you a reasonable offer of housing which meets your needs. However, we will not expect you to be unnecessarily restrictive in the types of housing or areas for which you will be considered. In particular, if a flat or maisonette would meet your needs we may offer you a property of that type and would consider that to be a reasonable offer. We will also ask you to be flexible about the areas in which you would consider being housed. If we have not been able to make you an offer in one of your areas of choice within 28 days of receiving your A+ or A priority, you will be asked to consider adjoining areas. If you refuse an offer of housing, we will invite you to a housing options and information interview to discuss the best way of ensuring we are able to help you as quickly as possible. We want to avoid having to suspend your housing application, in recognition of the critical nature of your housing needs. 4.6 Health and Social Care Priority Health and Social Care Priority is awarded by the Health and Social Care Panel. This Panel assesses the housing and/or support needs of people with specific requirements, to allow them to live in the community. Applicants, or members of their household, who have housing or support needs, will have their circumstances referred to the Panel. The Panel is made up of Renfrewshire Council officers, health professionals and local housing associations. Applicants will include those who: Have received or are receiving, treatment for serious health issues. This may include physical disability (not covered by a mobility award), post‐traumatic stress disorder and other related conditions. Page 55 of 204
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21 Have a learning disability. Have mental health needs. Have medical needs not addressed by the mobility priority. Have any other significant health and social care needs not covered elsewhere in this policy. In particular circumstances, victims of crime may also be eligible. A referral will be made on behalf of applicants with a health and social care need by appropriate Renfrewshire Council services, housing associations, support workers or health professionals. The Panel considers each case that has been referred to them in order to provide appropriate housing and/or support. This is intended to help applicants keep their tenancy longer‐term, taking account of things like: The applicant’s wider support network. Their ability to use community facilities. Particular needs outlined by the agency that referred them. The Panel will decide the type and location of suitable accommodation and award a priority appropriate to requirements. We will make offers in line with the Panel’s decision to grant increased priority awards. The Panel is one of a range of options we have to help people with particular needs to live in the community. As a result, the Panel may not always be the most appropriate option. If more than one person in an applicant’s household has a Health and Social Care award, we will only take account of the highest priority when allocating housing but will take into account the needs of those with the awards. 4.7 Critical housing needs (Priority A) The following housing needs will be awarded an A priority: Can be awarded to Mobility, General Applicants and Transfer with Housing Need Group Page 56 of 204
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22 Health and social care A: To be given an A award by the Health and Social Care Panel, you will have critical health or social care needs, other than mobility needs, which are not met by your current housing situation and which are impacting on your well‐being. The Panel will make an A award to people whose needs are critical. This can include where current accommodation makes it impossible to carry out day to day tasks. See point 4.6 for more information about the Health and Social Care Panel. Domestic abuse A: We use the Scottish Government’s definition of domestic abuse as gender‐based abuse which can be perpetrated by partners or ex‐partners and can include physical abuse, sexual abuse and mental and emotional abuse. If you give domestic abuse as the reason for applying for a house, we may seek information to support your case, including from Police Scotland, but will not contact the person that is responsible for the abuse. Harassment A: You are experiencing harassment that is specifically targeted at you, in or around your current accommodation and you are not safe in your current accommodation. Harassment can take many forms including intimidating, threatening or aggressive behaviour, both verbal and physical, and can involve attacks on property as well as people. Harassment is often premeditated and reoccurring. The A level priority will, unless in exceptional circumstances, require a recommendation from Police Scotland that a move is required to ensure your safety. Overcrowding A: Your current home has three or more bedrooms fewer than the number you need. We will calculate the number of bedrooms you are short by comparing the number you have and the number we have assessed you as needing. If members of the household applying to live together are currently living in different properties, we will assess overcrowding against the home which comes closest to meeting the combined household’s needs. Can be awarded to Mobility Group only Mobility A: Your current accommodation makes it impossible for you or a member of your household to perform day‐to‐day tasks or poses a danger to life because it does not meet your or their mobility needs. If you receive a mobility award your application will be placed into the Mobility Group. The assessment process will include a recommendation of suitable house types or adaptations Page 57 of 204
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23 needed in the house to meet your mobility needs and we will only make offers in line with this recommendation. Can be awarded to Mobility and General Applicants only Insecure accommodation A: If you have a definite date, within two months, when you will lose your accommodation through no fault of your own. For example, you are losing accommodation which is linked to your employment or have been issued with a Court Notice to leave your private rented or owned accommodation within two months (such as a Notice to Leave or Mortgage Repossession papers). Leaving institutions or specialist accommodation A: You are leaving the armed forces, hospital, long‐term residential care, supported accommodation or accommodation provided by Renfrewshire Council as a corporate parent, and you have a date to leave but have nowhere to live when you leave. Property below tolerable standard A: You are living in a property which is below tolerable standard according to the definition as set out in the Housing (Scotland) Act 1987 (as amended by the Housing (Scotland) Act 2001). Being below tolerable standard will include things such as not having a sink with a supply of both hot and cold water or not having an effective system for getting rid of waste water. The full definition is contained in Appendix 3. Renfrewshire Council must confirm in writing that a house is below the tolerable standard for this to be applied. 4.8 Urgent housing needs (Priority B) The following housing needs will be awarded a B priority: Can be awarded to Mobility, General Applicants and Transfer with Need Group Health and social care B: To be given a B award by the Health and Social Care Panel, you will have urgent health or social care needs, other than mobility needs, which are not met by your current housing and which are impacting on your well‐ being. The Panel will make a B award to people whose needs are urgent and this can include where current accommodation makes it difficult to carry out day to day tasks. See point 4.6 for more information about the Health and Social Care Panel. Social, community or family support B: You need to move to be closer to a family member to give or receive essential support to carry out day‐to‐day tasks and the Page 58 of 204
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24 support you give or receive is necessary to allow you or your family member to live independently. You would receive this award if it is not possible or reasonable for you to give or receive the support where you currently live and you are looking to move to within a reasonable distance of the person giving or needing the support. Harassment B: You are experiencing harassment that is specifically targeted at you, in or around your current accommodation, but you are safe in your current accommodation. Or you fear violence, and this fear is justified. Harassment can take many forms including intimidating, threatening or aggressive behaviour, both verbal and physical, and can involve attacks on property as well as people. Harassment is often premeditated and reoccurring. The B level priority will usually require a recommendation from Police Scotland that a move is required to ensure your safety. Overcrowding B: Your current home has two bedrooms fewer than the number you need. We will calculate the number of bedrooms you are short by comparing the number you have and the number we have assessed you as needing. If members of the household applying to live together are currently living in different properties, we will assess overcrowding against the home which comes closest to meeting the combined household’s needs. Under‐occupying B: You live in a social rented property and your current home has two or more bedrooms more than you need. We will calculate how many extra bedrooms you have by comparing the number in your current home and the number we have assessed you as needing. You will only receive this level of priority if you are looking to move to a property that has two or more fewer bedrooms than you currently have. Relationship breakdown B: If the relationship between you and a partner with whom you live has broken down, you are still living together and you wish to move to another property. The priority will only be awarded to the household wishing to move out of the current home. Can be awarded to Mobility Group only Mobility B: Your current accommodation severely restricts your or a member of your household’s ability to carry out day‐to‐day tasks because it does not meet your or their mobility needs. If you receive a mobility award your application will be placed into the Mobility Group. The assessment process will include a Page 59 of 204
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25 recommendation of suitable house types or adaptations needed in the house to meet your mobility needs and we will only make offers in line with this recommendation. 4.9 Moderate housing needs (Priority C) The following housing needs will be awarded a C priority: Can be awarded to Mobility, General Applicants and Transfer with Housing Need Group Health and Social Care C: To be given a C award by the Health and Social Care Panel, you will have health or social care needs, other than mobility needs, which are not met by your current housing and are impacting on your well‐being. The Panel will make a C award to people who have health or social care needs, which can include where current accommodation makes carrying out day to day tasks less easy. See point 4.6.for more information about the Health and Social Care Panel. Social, community or family support C: You need to move to be closer to a family member to give or receive support to carry out day‐to‐day tasks and the support you give or receive is necessary to allow you or your family member to live independently. You would receive this award if it is difficult for you to give or receive the support where you currently live and you are looking to move to within a reasonable distance of the person giving or needing the support. Overcrowding C: Your current home has one bedroom fewer than the number you need. We will calculate the number of bedrooms you are short by comparing the number you have and the number we have assessed you as needing. If members of the household applying to live together are currently living in different properties, we will assess overcrowding against the home which comes closest to meeting the combined household’s needs. Under‐occupying C: You live in a social rented property and your current home has one bedroom more than you need. We will calculate how many extra bedrooms you have by comparing the number in your current home and the number we have assessed you as needing. You will only receive under occupation priority if you are looking to move to a smaller property. Page 60 of 204
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26 Take up or stay in employment C: If you need to move so you can keep your job or you have an offer of employment and need to move to take up the offer. We will only make this award if the move you are looking for will mean you live closer to your place of employment and/or to suitable public transport links. Can be awarded to Mobility Group only Mobility C: Your current accommodation does not fully meet your mobility needs and moving will improve your ability to carry out day‐to‐day tasks. If you receive a mobility award your application will be placed into the Mobility Group. The assessment process will include a recommendation of suitable house types or adaptations needed in the house to meet your mobility needs and we will only make offers in line with this recommendation. Can be awarded to Mobility and General Applicants only Insecure accommodation C: You have no home of your own and are living in accommodation you have no right to occupy but you do not have a date when you will have to leave. Leaving institutions or specialist accommodation C: You will be leaving the armed forces, hospital, long‐term residential care or supported accommodation and will have nowhere to live when you leave but you do not have a date when you will have to leave. Also, if you are leaving prison and irrespective of whether you have a date to leave or not. 4.10 No assessed housing needs (Priority D) This means that you do not have any of the housing needs set out above. However, you are looking to move to another property. This might be because you would like to live in a different area or you would like a property of a different type. You may already live in one of our properties, you could be a tenant of another social rented sector landlord or you might not have a social rented sector tenancy but would like one. Page 61 of 204
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27 4.11 Further information on Statutory Homelessness Group Your application will be placed in this group by Renfrewshire Council if you have made a homelessness application to the Council and the Council has found you to be unintentionally homeless. The Council’s Housing Advice and Homeless Services Team assess homeless applications. Under Part II of the Housing (Scotland) Act 1987, as amended by the Housing (Scotland) Act 2001 and the Homelessness etc. (Scotland) Act 2003, the Council must assess applicants who are homeless or threatened with homelessness. If you are assessed as being unintentionally homeless, or unintentionally threatened with homelessness, the Council must give you advice and support, provide temporary accommodation if necessary, and find you permanent accommodation. Offers of permanent accommodation could be made by the Council or one of the housing associations. The housing association landlords have a duty to assist Renfrewshire Council in securing permanent homes for households experiencing Statutory Homelessness. When offering accommodation to statutory homeless applicants, we will take account of what housing is available, and where relevant how close housing is to schools, family support and your place of work. Homeless legislation states that if you are deemed to be unintentionally homeless, Renfrewshire Council has a duty to make you at least one reasonable offer of housing. We may make up to two reasonable offers. In deciding what is a reasonable offer, the Council will take account of the factors listed in the Homelessness Code of Guidance. If you refuse both these offers, you may lose your homeless priority. Where you had a pre‐existing application for housing registered with Renfrewshire Council and you are able to update your current circumstances following your homeless priority being lost, Renfrewshire Council will reassess your application and your application will be moved into the most appropriate group for your assessed need. If you did not have a pre‐existing application, you can apply at any time and be placed on our housing list. Homeless applicants have the right to appeal against these decisions, under the homelessness procedures, and Renfrewshire Council will write to you to tell you how to appeal. You can get details of the appeals procedure from the Housing Page 62 of 204
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28 Advice and Homeless Services Team (please see the contact details at the end of this document). 4.12 Further information on Mobility Group Your application will be placed in this group if you, or a member of the household you are applying with, requires a home which is suitable for someone needing an adapted or accessible property. You may be an existing tenant of the landlord you are applying to. We aim to make best use of the properties which become available for let and when certain types of property become available we will aim to offer them to households who need a property of that particular type. This will apply to all properties which were built for or have already been adapted to meet the needs of someone with mobility problems or a disability. We will normally only offer adapted properties and properties with wheelchair access to applicants who need the facilities they contain. If an empty property has been ‘substantially adapted’ to meet the needs of a person with certain disabilities, we will try to match this property to an applicant within the mobility group with similar needs. By ‘substantially adapted’, we mean it has the following adaptations such as: Doorways widened for wheelchairs to fit through Internal vertical lift Ramp (inside or outside, or both) Wet floor area Changed heights and positions of kitchen units. If you live in a mobility property which meets your needs, your application would also be placed in this group. However, you would not receive priority based on needing a mobility property. 4.13 Young people with experience of the care system Renfrewshire Council has corporate parent responsibilities for young people who have experience of the care system. Page 63 of 204
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29 The Council will work closely with any care experienced young person and Health and Social Care partners looking for housing to support keeping Scotland’s Promise. We will support them to complete a housing application and will work with them to find them a home which meets their needs. 4.14 Exceptions to the policy, including special lets & management transfers There may be exceptional cases where one of the landlords considers it appropriate to make an allocation outwith the terms of this policy. It is not possible to predict all the exceptional circumstances that may arise but these could include: Where new build properties will help meet housing needs that we have otherwise been unable to address. Where you are living in a property which has been specially adapted, no‐ one currently living in the house needs the adaptations but someone else on the housing list does. Where a landlord needs to make a management transfer in the event of an emergency. To free up a property of a type that is in very short supply and which is needed to meet an urgent housing need. Where a landlord makes an exceptional allocation to someone who does not qualify to succeed to a tenancy. Where two households both of which live in a social rented property wish to move together into a new home and both of their current properties would be available to be relet. Where the landlord and tenant agree that due to exceptional circumstances the tenant has to terminate their tenancy, but they will be looking to be rehoused within 2 years. If another agency, such as Police Scotland, asks for assistance. As part of a regeneration or similar programme or if a tenant’s current home is subject to a closing order or is to be demolished, or part of a Housing Renewal Area, for example. Page 64 of 204
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30 Due to the exceptional nature of these lets, the numbers involved will be very low and will be clearly documented for audit purposes. A senior officer must authorise any special lets or management transfers. 4.15 Mutual exchange If you rent your home from another local authority or housing association and you would like to swap homes with another tenant from any of these landlords, you can apply in writing to exchange your home. Anyone who has a Secure Tenancy can apply. Your landlord can only refuse permission if it is reasonable to do so. You must not exchange homes until you have written permission from your landlord and the landlord of the tenant you want to exchange with. Each of the landlords has a separate policy that sets out the rules that apply if one of their tenants wants to take part in a mutual exchange. These rules are available on request. 4.16 Sheltered housing In addition to our general needs housing, three of us (Bridgewater Housing Association, Linstone Housing Association and Renfrewshire Council) also provide sheltered housing. In general, sheltered housing is open to applicants aged 60 or over. If you are interested in applying for sheltered housing, you should complete the relevant section on the housing application form for the landlord(s) to which you are applying. When assessing your application, we will consider whether you would benefit from the particular services available within our sheltered housing and award priority accordingly. The services available may vary between landlords and further information on their sheltered housing policies and assessment process can be obtained from each of the landlords concerned. Please see Appendix 10 for further information on Sheltered Housing. Page 65 of 204
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31 5. How we allocate housing 5.1 Allocation targets We will allocate housing according to targets for the proportion of lets to each group. Allocation targets are set to ensure that those in housing need receive an equitable share of allocations. Each of the landlords will set and publish their own annual allocation targets. Renfrewshire Council will set a target for the proportion of their lets which will be made to those in the Homeless Group. However, the lets made by the housing association partners to this group are covered by a separate agreement with Renfrewshire Council. Landlords may choose to set a target for lets to the Transfer Applicants with no housing need group, but are not required to do so. In addition to setting an overall target for the Mobility Group, landlords may choose, but would not be required, to consider the proportion of Mobility Group lets going to transfer or general needs applicants. The targets will be reviewed each year and each of the landlords will report on the percentage of lets made to each group and on any changes to the targets for the next year. 5.2 Nominations and referrals The Council has nomination agreements with other social housing landlords which have housing in Renfrewshire. This includes the four housing association landlords that will be using this policy. If you have joined the Council’s housing list, and have agreed to be nominated to a housing association, you may be referred to a housing association landlord for an offer of housing. The Council and the housing associations also have an agreement covering offers of housing to households who are statutorily homeless. These arrangements are in line with Section 5 of the Housing (Scotland) Act 2001. The Council and housing association landlords agree on an annual percentage of empty properties that will receive Section 5 referrals. These lets are those made to applicants in the Homeless Group. Page 66 of 204
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32 5.3 How we allocate our properties When a property becomes available for re‐let, we will check if it is suitable for someone with mobility needs. If so, it will normally be offered to Mobility Group applicants first. With all other lets, we will decide to which of the remaining groups we will allocate to. This decision will take account of our letting targets along with the number and profile of applicants in each group and the types and level of housing need they have. We will always aim to make an offer to applicants looking for a property of that type and in that location. We will then take account of overall level of priority. If more than one applicant has the same priority, the first offer will be made to the applicant who has held that level of priority the longest. The date on which the level of priority is awarded is known as the eligible date. If you have no assessed housing need, the eligible date will be the date on which that assessment was made. If your circumstances change and your level of priority increases, the eligible date for your application will change to the date on which the new, higher level priority is awarded. However, if your level of priority decreases, we will continue to use the eligible date of application, from before the change of circumstances. If we are making an offer to applicants with no level of priority under this policy, including to Transfer Applicants with no housing need, we will make allocations based on your eligible date. 5.4 Number of offers We aim to work with applicants to help them make the best choices. We make offers based on your housing needs and preferences after contacting you to confirm that the details we hold on your application form are accurate. This is good practice as it allows us to reduce inappropriate offers and ensures that your application details are as up‐to‐date and accurate as they can be. We may make up to two offers of housing. Offers will be made on the basis of what is considered to be reasonable for your household to occupy. Page 67 of 204
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33 In deciding what is reasonable, we will take account of your choices and preferences, balanced against the supply of suitable properties and the urgency of your need for housing. If you have been placed in priority band A or A+ you will have a very urgent need to be housed. In order to make you an offer as quickly as possible, we may need to make you an offer of housing in an adjoining area or of another property type to those you have chosen. We will consider such an offer to be a reasonable offer of housing. If you refuse a first reasonable offer of housing from one of us, that landlord may invite you to a housing information and advice interview to discuss your choices. We would not normally make any further offers until that interview has taken place. After receiving this housing advice, if you refuse a further reasonable offer from that landlord within the next 12 months they may suspend you from their list for up to 6 months. Statutory homeless applicants may also receive up to two reasonable offers from Renfrewshire Council. If the applicant declines a second reasonable offer, their application will be removed from the Homeless Group and cancelled. If the applicant still wishes to be considered for housing and they had a previous housing application registered they will be required to update it to allow reassessment. Where no previous application exists, the applicant can complete a new application for housing. They will then be placed into whichever of the Mobility or General Housing Needs Groups is appropriate. Their level of priority will be assessed based on their current housing circumstances. They will then be entitled to receive up to a further two reasonable offers from Renfrewshire Council or the landlord they apply to, based on the process for all other applicants explained in the paragraph above. If you are suspended from one of our lists, the landlord concerned will not make you any more offers until that suspension is removed. Further information on suspensions is provided in Section 6 of this policy. 5.5 Tenancy agreements If you accept an offer of housing, you will generally be offered a Scottish Secure Tenancy. Page 68 of 204
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34 In some cases, under the Housing (Scotland) Act 2001, a Short Scottish Secure Tenancy will be offered. We can only use a Short Scottish Secure Tenancy in very specific circumstances. These include if: You, a household member, or a visitor, has been involved in antisocial behaviour in or near your house within the last three years. In this case, we will give you a Short Scottish Secure Tenancy for a minimum period of 12 months to allow sufficient time for any support services offered to help address the antisocial behaviour. We may extend the Short Scottish Secure Tenancy by an additional six months if required. Your current home with us is scheduled for development and we need you to move to allow us to get the work done. You are a homeowner who cannot occupy their home on a short‐term basis. For example, if you need to move out while repairs are carried out to make the home safe. If we offer you a Short Scottish Secure Tenancy, we will serve you with a notice which will set out why you are being offered a Short Scottish Secure Tenancy and the period for which the tenancy is being offered. If you would like further information on the use of Short Scottish Secure Tenancies, please contact the landlord to whom you are applying. 5.6 Joint tenancies You can make a joint application with someone who is staying with you or someone you intend to stay with you. If you are offered housing, you can choose to have a joint tenancy. This will mean that both of you have similar legal rights. 5.7 Specially designed or adapted properties There may be exceptional circumstances where a property designed for someone with special needs, or which has undergone major adaptations, becomes available but there is no‐one on our housing list who needs a property of that size and design or who can make good use of the adaptations that have been carried out. Page 69 of 204
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35 Rather than leaving the property empty, we reserve the right to offer the property on a Scottish Secure Tenancy to an applicant who does not need a property with the special features available. However, we would expect them to agree to move to another suitable property provided by us, if someone requires the specially designed or adapted property at a later time. If we were offering someone a property on this basis, we would make this arrangement clear to the applicant at the offer stage. If the applicant preferred not to accept the offer, the offer would not count against their entitlement to two reasonable offers. 6. Application status 6.1 Reviewing applications It is important for us to have up‐to‐date and accurate information about those looking for housing and you should tell us about any relevant changes to your circumstances. We will review all applications at least a once a year. The date of this review is based on the date you registered your housing application with the landlord(s). As part of this review, we will ask you to advise us within 10 working days if you wish to remain on the housing list. If no response is received, we will send a further letter. If we still receive no response your application may be removed from the housing list. If you contact us within a further 6 weeks of your application being removed, your application can be reinstated. Applicants who have had their application cancelled have the right to appeal against this decision. We will reinstate a cancelled application up to 6 months after the date we cancelled it, if the applicant can give good reasons for not replying to the review. However, applicants who contact us more than 6 months after the date of cancellation will need to fill in a new form and will not be entitled to have their application backdated to the date of the original application. You will be able to make a new application to any of the landlords at any time and join one or more of the housing lists. If you join one of our lists, your application date will be the date on which you joined the list again. Page 70 of 204
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36 6.2 Deferring your application You may wish to apply for housing but not be considered for offers in the immediate future. We appreciate that there may be times when a move is not right for you, for example, because you are not well or cannot afford to move at this time. If this is the case, you can ask to have your application placed on hold until a future date. This means that we will not make offers of housing until you ask us to. We will check whether you wish your application to stay on hold, when we review your housing application. Alternatively, you can contact us at any time to tell us that you want to be actively considered for offers of housing. We will accept housing applications from asylum seekers and others subject to immigration control. However, we will defer these applications until the applicant has received a positive decision about the applicant’s leave to remain from UK Visas and Immigration. 6.3 Suspension from housing lists – A suspension is a period of time during which an applicant for housing or an existing tenant applying to move to another property will not be considered for an offer of housing. Although we will aim to suspend as few applicants as possible, there may be occasions when suspending an application is necessary. Before suspending your application, we will consider: Whether there are other options available to us, such as offering further information and advice or proactively managing the problem that makes suspension a possibility? Whether suspending your application would be proportionate and if so for how long? Whether we have sufficient, robust evidence to justify our decision to suspend your application? The consequences of suspending your application for you and other members of your household? Page 71 of 204
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37 If your application is suspended, you will receive a letter detailing why we have taken that decision, the length of the suspension and the date(s) on which the suspension will be reviewed. The letter will also tell you if the suspension is under the statutory powers to suspend set out in the Housing (Scotland) Act 2014. The letter will set out any action you can take to have the suspension removed before the review date. Although we may reduce the length of the suspension, we will never increase the length of the suspension. You are entitled to appeal our decision and further information on how to make an appeal will be set out in the letter sent to you. The appeals process will be in line with that set out in Section 8 of this policy. If you make a new application, including a new transfer application, and we decide to suspend your application at the application stage, we would do so under the statutory powers to suspend set out in the Housing (Scotland) Act 2014. These new powers allow us to suspend an application for a period from the date of application. If you are eligible to join our housing list, your application will still be placed on the housing list, but you will not receive any offers of housing while the suspension remains in place. Renfrewshire Council will not use the statutory powers set out in the Housing (Scotland) Act 2014 to suspend any new applicant who has been found to be statutorily homeless. However, once two reasonable offers of housing have been made to the statutory homeless applicant, the applicant will no longer have a statutory homeless priority and may be suspended under the circumstances set out below. The circumstances which may result in an application being suspended are the same for new applicants and those already on the housing list. They are: Rent arrears and other tenancy related debt Where there are significant, outstanding and unresolved social rented sector tenancy‐related debts and until such debts are either cleared, fall below 1/12th of the annual rent charge, or an agreement has been set up and adhered to for a period of at least 3 months. The suspension would be removed as soon as the necessary conditions have been met. Page 72 of 204
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38 Antisocial Behaviour The applicant has: ‐ acted in an antisocial manner in relation to another person residing in, visiting or otherwise engaged in lawful activity in the locality of a house occupied by the person, or ‐ pursued a course of conduct amounting to harassment of such other person, or a course of conduct which is otherwise antisocial conduct in relation to such other person, or ‐ acted in an antisocial manner, or pursued a course of conduct which is antisocial conduct, in relation to an employee of the social landlord in the course of making the application. We may consider antisocial behaviour from up to 3 years previously, or longer in exceptional circumstances. Suspension under this category will be to a maximum of 6 months but there will not be a set time limit and applicants will be notified individually of timescales. Timescales will be reviewed in the event of a change of the applicant’s circumstances. Previous Convictions The applicant has been, or has resided with a person who has been, convicted of: ‐ using a house or allowing it to be used for immoral or illegal purposes, or ‐ an offence punishable by imprisonment which was committed in, or in the locality of, a house occupied by the person. We may consider convictions from up to 3 years previously. Suspension under this category will be to a maximum of 6 months but there will not be a set time limit and applicants will be notified individually of timescales. Timescales will be reviewed in the event of a change of the applicant’s circumstances. Order for Recovery of Possession An order for recovery of possession has been made against the applicant. This could apply to orders within the previous 3 years and made under Scottish housing legislation and housing legislation for other parts of the UK. Suspension will be to a maximum of 6 months. Page 73 of 204
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39 Abandoning a tenancy or neglecting a let property Where the applicant has previously had a property repossessed by a social landlord because the property had been abandoned, or where a court has ordered recovery of possession due to the deterioration of the condition of the property or furniture provided for the tenant’s use. We may consider repossessions from up to 3 years previously. Suspension under this category will be to a maximum of 6 months but there will not be a set time limit and applicants will be notified individually of timescales. Timescales will be reviewed in the event of a change of the applicant’s circumstances. Making a false statement in an application for housing Where deliberately false or misleading information has been provided by the applicant, suspension will be for 6 months. Applicants who have refused two offers of housing When an applicant refuses two reasonable offers of housing. In this case, the applicant will be suspended for up to 6 months, unless the applicant’s housing circumstances worsen during the suspension period, in which case the application will be reassessed. Page 74 of 204
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40 7. Other Information 7.1 Local Lettings Initiatives A Local Lettings Initiative can be a useful way of helping to create sustainable communities and there may be occasions when one or more of the landlords will develop and implement such an Initiative. An Initiative might be designed to boost demand in a particular area or to help us make lets which promote a balanced community. Any Initiative will apply only to a geographically defined area and any changes made to this policy will be designed to meet specific local aims. Any Initiative will have clear outcomes and will be supported by evidence as to why it is required. As part of the development process, we will consult with the local community and key external partners. The Initiative will be compliant with all the relevant legislation, will be published in the same way as this policy and will include: An explanation of why the Initiative is needed and the evidence that has been used to inform the decision to introduce it. Clear and specific aims and objectives. The time period for which the Initiative is expected to remain in place. An effective monitoring framework to make sure the aim of the Initiative is being met and there are no unforeseen consequences. This will include criteria that will be used for deciding whether to curtail or extend the time period for which the Initiative will run. The Initiative will be reviewed regularly to ensure it is still required. 7.2 Other lettings approaches We are committed to continually improving access to housing for people who apply to us. In the future, one or more of the landlords may wish to consider taking an alternative approach to letting some of their properties. An example might be piloting a Choice Based lettings approach. If any landlord is considering using an alternative approach (outwith that set out in this policy) they will consult with their tenants, applicants and other key stakeholders as part of the development process. Any plans will be published and the landlord will also monitor and report on their performance. Page 75 of 204
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41 8. Appeals and complaints 8.1 Appeals We will always aim to give you an excellent service, but we recognise that you may disagree with some of our decisions and may wish to make an appeal. Each of the landlords operates its own appeals policy. Information on this will be available on their website or from their office(s). You can get information from your landlord or the landlord you have applied to about making an appeal. We also offer interpreting and translation services if English is not your first language. We can also provide a British Sign Language interpreter if required. When you make an application for housing, you have the right to appeal against: The priority we have awarded to your application. Whether an offer we have made you is reasonable. A decision to suspend you from receiving offers. A decision to cancel your application. Any other decision we make which you believe has not been dealt with in accordance with this policy. The arrangements for statutory homeless applicants are set out in the Housing (Scotland) Act 1987 as amended. Further information on appealing a statutory homelessness decision can be found in the Scottish Government’s Code of Guidance on Homelessness which can be found at: https://beta.gov.scot/publications/code‐guidance‐homelessness/ If you are appealing a suspension which has been made using the statutory powers to suspend set out in the Housing (Scotland) Act 2014 you have a right of appeal to the sheriff, by summary application. Further information on the summary applications rules can be found on the Scottish Court Services website at: https://www.scotcourts.gov.uk/taking‐action/summary‐applications Page 76 of 204
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42 8.2 Making a complaint If you are not satisfied with the service you have received from us, you can make a complaint. Each landlord has its own complaints policy and process. If you wish to make a complaint you should contact the landlord involved. They will also publish information on their website about their complaints process. Contact details are provided at Appendix 1. If you make a complaint to a landlord but are not satisfied with the outcome, you can refer your case to the Scottish Public Services Ombudsman. Each of our complaints policies will explain each step of the process, including how you can appeal to the Scottish Public Services Ombudsman. The Ombudsman is a government‐based organisation which can review your case, if you have already been through a landlord’s complaints procedures and you feel they have not dealt with your complaint fairly. If you feel that your landlord has done, or failed to do something that puts the interests of its tenants at risk, you can also refer your case to the Scottish Housing Regulator. The Scottish Housing Regulator’s website provides information about significant performance failures and what you should do and how to raise your concerns with them. You can find this information at: www.scottishhousingregulator.gov.uk Page 77 of 204
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43 9. Assessing our performance 9.1 Reporting on our performance We will monitor the implementation of this policy to make sure it is meeting our aims, is effective, non‐discriminatory and promotes equal opportunities. Each of us will collect information and report every year on: The number of new applicants added to our housing list. The number of applicants on our housing list by group. The number of offers made to each group. The housing needs of applicants and of those to whom we have offered housing. The average time to re‐let a property. The percentage of tenancy offers refused. The number of suspensions from the housing list. The number of appeals or complaints we receive and how these have been dealt with. Some of the partners monitor and report their performance against their equal opportunities commitments. The information these partners use to monitor equal opportunities will include: details of the background, age, sex and disability of the people applying to us for housing, compared to the ethnic background, age, sex, and disability of the people we offered housing to, and the ethnic background, age, sex and disability of the general population within Renfrewshire. We will report on our performance to the Scottish Housing Regulator and to our elected members or management committee. 9.2 Reviewing this policy We will keep this policy under review. If the monitoring of our performance suggests areas in which the policy needs to be improved, we may amend the policy if required. If any changes to be made are substantive, we will consult with tenants, applicants and other key stakeholders before making these changes. We will undertake a full review of this policy every three years, or earlier if required by changes to legislation or guidance. Page 78 of 204
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44 APPENDIX 1 ‐ Common Allocation Policy Partners Renfrewshire Council, Environment Housing and Infrastructure www.renfrewshire.gov.uk Paisley: Customer Service Centre, Renfrewshire House, Cotton Street, Paisley, PA1 1AN. Opening hours: Monday to Thursday 8.45am to 4.45pm and Friday 8.45am to 3.55pm. Telephone: 0300 300 0222 Johnstone: Customer Service Centre, Johnstone Town Hall, 25 Church Street, Johnstone, PA5 8FA. Opening hours: Monday to Thursday 8.45am to 4.45pm, Friday 8.45am to 3.55pm. Telephone: 0300 300 0222 Renfrew: Customer Service Centre, 14 Renfield Street, Renfrew, PA4 8RN. Opening hours: Monday to Thursday 8.45am to 4.45pm, Friday 8.45am to 3.55pm. Telephone: 0300 300 0222 Housing Advice & Homeless service: 15 Abercorn Street, Paisley, PA3 4AA. Telephone during office hours 03003000222 Telephone outwith office hours 08001214466 Bridgewater Housing Association www.bridgewaterha.org.uk Head office: 1st Floor Bridgewater Shopping Centre, Erskine, PA8 7AA. Opening hours: Monday to Friday – 9.00am – 12.00pm and 1.00pm – 4.00pm. Telephone: 0141 812 2237 Linstone Housing Association www.linstone.co.uk Head office: 17 Bridge Street, Linwood, PA3 3DB. Opening hours: Monday, Tuesday, Thursday and Friday 9.00am – 4.30pm, Wednesday 1.30pm – 6.00pm. Telephone: 01505 382383 Paisley Housing Association www.paisleyha.org.uk Head office: 64 Espedair Street, Paisley, PA2 6RW. Opening hours: Monday to Thursday 9.00am – 5.00pm and Friday 9.00am – 4.00pm. Telephone: 0141 889 7105 Williamsburgh Housing Association www.williamsburghha.co.uk Head office: Ralston House, Cyril Street, Paisley, PA1 1RW. Opening hours: Monday to Friday 9.00am – 12.30pm and 1.30pm – 5.00pm. Telephone: 0141 887 8613 Page 79 of 204
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45 Other social landlords providing housing in Renfrewshire: Cairn Housing Association ‐ housing for older people. www.cairnha.com Head office: Bellevue House, 22 Hopetoun Street, Edinburgh, EH7 4GH. Telephone: 0800 990 3405 Ferguslie Park Housing Association ‐ housing for general need and also older and disabled people. www.fpha.co.uk Head Office: The Tannahill Centre, 76 Blackstoun Rd, Paisley PA3 1NT. Telephone: 0141 887 4053 Hanover Housing Association ‐ housing for older people. www.hanover.scot Head office: Western Area Office, 345 Govan Road, Glasgow, G51 2SE. Telephone: 0141 553 6300 Horizon Housing Association ‐ housing for general needs and also older and disabled people. www.horizonhousing.org Head office: Leving House, Fairburn Place, Livingston, EH54 6TN. Telephone: 01506 424140 Lorretto Housing Association ‐ housing for general need and also older and disabled people. www.lorettoha.co.uk Head office: 2nd Floor Lipton House, 170 Crown Street, Glasgow, G5 9XD. Telephone: 0141 420 7950 Blackwood Housing Association ‐ housing for general need and also older and disabled people. www.blackwoodgroup.org.uk Head office: Suite 102 Pentagon Business Centre, 36 Washington Street, Glasgow, G3 8AZ. Telephone: 0141 221 1606 Sanctuary Housing Association ‐ housing for general need and supported accommodation. www.sanctuary‐group.co.uk Head office: 7 Freelands Drive, Priesthill, Glasgow, G53 6PG. Telephone: 0141 876 4900 Page 80 of 204
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46 APPENDIX 2 ‐ Complying with legislation and good practice This policy has been developed to meet the legal requirements set out in the following legislation: Housing (Scotland) Act 2014 Equality Act 2010 Housing (Scotland) Act 2010 Housing (Scotland) Act 2006 Homelessness etc. (Scotland) Act 2003 Housing (Scotland) Act 2001 Human Rights Act 1998 Data Protection Legislation The Civil Partnership Act 2005 Housing (Scotland) Act 1987 Matrimonial Homes (Family Protection) (Scotland) Act 1981 This policy has been developed in line with good practice from the Scottish Government, the Scottish Housing Regulator, the Scottish Federation of Housing Associations and the Chartered Institute of Housing. Scottish Social Housing Charter The Scottish Housing Regulator (SHR) is the independent regulator for landlord services provided by local authorities and Registered Social Landlords (RSLs) and statutory homelessness services provided by local authorities. All the partners are required to provide information to, and are regulated by, the SHR. The SHR uses the outcomes and standards in the Scottish Social Housing Charter (SSHC) to assess the performance of social landlords. The particular SSHC outcomes that have been considered in the development of this policy are: Outcome 1: Every tenant and other customer has their individual needs recognised, is treated fairly and with respect, and receives fair access to housing and housing services. Outcome 2: Tenants and other customers find it easy to communicate with their landlord and get the information they need about their landlord, how and why it makes decisions and the services it provides Page 81 of 204
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47 Outcome 7: People looking for housing get information that helps them make informed choices and decisions about the range of housing options available to them. Outcome 8: Tenants and people on housing lists can review their housing options. Outcome 9: People at risk of losing their homes get advice on preventing homelessness. Outcome 10: People looking for housing find it easy to apply for the widest choice of social housing available and get the information they need on how the landlord allocates homes and their prospects of being housed. Page 82 of 204
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48 APPENDIX 3 ‐ Below tolerable standard The tolerable standard is set out in the Housing (Scotland) Act 1987 as amended by the Housing (Scotland) Act 2001 A house will, for the purposes of the Act, meet the tolerable standard if the house: a) is structurally stable b) is substantially free from rising or penetrating damp c) has satisfactory provision for natural and artificial lighting, for ventilation and for heating d) has an adequate piped supply of wholesome water available within the house e) has a sink provided with an adequate supply of both hot and cold water within the house f) has a water closet or waterless closet available for the exclusive use of the occupants of the house and suitably located within the house g) has a fixed bath or shower and a wash‐hand basin, all with a satisfactory supply of hot and cold water suitably located within the house h) has an effective system for the drainage and disposal of foul and surface water i) has satisfactory facilities for the cooking of food within the house j) has satisfactory access to all external doors and outbuildings Page 83 of 204
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49 APPENDIX 4 ‐ Succeeding to a tenancy The legal provisions relating to succession of a Scottish Secure Tenancy are contained within the Housing (Scotland) Act 2001, as amended by the Housing (Scotland) Act 2014. Succession can arise only on the death of the tenant and where there is a relevant qualifying person. Only two rounds of succession to a tenancy are allowed in law. After a second succession, the tenancy will terminate. If a tenant dies, the tenancy will pass to a qualified person in order of priority, as follows. First priority: the first priority goes to a tenant’s surviving husband, wife or civil partner (living in the property as their only or principal home at the time of the tenant’s death), or partner (as long as the house has been their only or principal home for the twelve months before the tenant died and we have been notified of this), or a joint tenant. (a civil partnership is a formal arrangement that gives same‐sex partners the same legal status as a married couple). Second priority: if no‐one in the above category qualifies or chooses to succeed, the second priority goes to a member of the tenant’s family aged 16 or over, as long as the home was their only or principal home for the 12 months prior to the death of the tenant. Third priority: if no‐one in the above categories qualify or choose not to succeed, the third priority goes to a carer who is providing, or who has provided care for the tenant or a member of the tenant’s family. The carer must be aged 16 or over and have given up his or her previous only or principal home for the 12 months prior to the death of the tenant (and we have been notified of this), to be qualified to succeed. In all cases, the house of the tenant who has died must have been the only or principal home for the qualifying person, (with the exception of the person’s spouse, civil partner or joint tenant). This is subject to meeting the 12 month prior notification of residency and notification requirements. If there is no qualified person, the tenancy terminates, unless there are exceptional circumstances to consider. Page 84 of 204
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50 Where there is more than one qualifying person within the levels of priority, for example family members, it is for them to decide who will succeed, failing which the landlord will make the decision. The Housing (Scotland) Act 2014 stipulates that the qualifying person or the tenant must have notified the landlord that the person wishing to succeed the tenancy is living in the house and that it is their only or principal home. The 12 month notice period does not start until that notice of residency has been given. In all cases, the house of the tenant who has died must have been the only or main home for the qualifying person and they must have notified the landlord that they reside there at least 12 months before the tenant’s death. If a house has been designed or substantially adapted for the use of a person with special needs to use, only their husband, wife or civil partner (living in the property as their only or main home at the time of the tenant’s death), or partner (as long as the house has been the partner’s only or main home for the twelve months before the tenant died), joint tenant or a person with special needs can succeed to the tenancy. Other people who would otherwise be qualified to succeed have a right to alternative suitable accommodation. When deciding whether accommodation is reasonably suitable to the needs of the applicant and the applicant’s family, we will take into account the following: a. How close it is to the place of work (including a school or college) of the applicant and of members of the applicant’s family, compared with the existing house. b. What accommodation the applicant and the applicant’s family requires. c. The character (property type) of the accommodation offered, compared to the existing house. d. The conditions on which the accommodation is offered to the applicant, compared with the conditions of the existing tenancy. e. If the landlord provided any furniture to use under the exiting tenancy, whether furniture will be provided under the new tenancy. f. Any special needs of the applicant or the applicant’s family. Page 85 of 204
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51 APPENDIX 5 ‐ Assigning a Tenancy The legal provisions relating to assignation of a Scottish Secure Tenancy are contained within the Housing (Scotland) Act 2001, as amended by the Housing (Scotland) Act 2014. A tenant may assign (transfer) their tenancy to another person as long as they get their landlord’s permission in writing. Applications should be made in writing to your local housing office. In terms of the residency, the Housing (Scotland) Act 2014 stipulates that: The house must have been the tenant’s only or principal home during the 12 months immediately before the tenant applies for written permission to pass their tenancy to someone else; and The person the tenant wishes to pass their tenancy to must have lived at the property as their only or principal home for the 12 months before they apply; and The tenant, joint tenant or person they wish to assign their tenancy to must have notified the landlord that the person they wish to assign the tenancy to is living in the house. The 12‐month period does not start unless the landlord has notified that the person is living in the property as their only or principal home. We will not unreasonably withhold permission, unless there are justified reasons for this. We will deal with all applications individually. Examples for refusing an application are listed below Where the landlord would not give the person the tenant wishes to pass the tenancy to reasonable preference under their allocations policy. Where, in the landlord’s opinion, the assignation would result in their home being under occupied. A Notice of Proceedings for Possession has been served on the tenant warning that we may evict them. Page 86 of 204
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52 We have a court order to evict the tenant. The tenant still needs to carry out some repairs which they are responsible for. It appears to the landlord that the tenant is to receive a payment for the assignation The planned move would result in overcrowding. The property is much larger than the person who wants to take over the tenancy needs (up to one bedroom more than would be offered under the allocation policy). There are plans to carry out work on the house or building. The accommodation is designed or significantly adapted for a person with special needs, and the person who the property is to be transferred to, including family members, does not have any special needs. Page 87 of 204
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53 APPENDIX 6 ‐ Joint tenancy A council tenant can apply for a joint tenancy with one or more other people. Applications for a joint tenancy should be made in writing to your local housing office. Joint tenants will be jointly and severally liable for their responsibilities under the tenancy, including paying rent. All joint tenants must live in the property as their only or main home. In terms of the residency of the prospective joint tenant, the Housing (Scotland) Act 2014 stipulates that: The proposed joint tenant must have lived at the property as their only or principal home for the 12 months before the tenant applied for them to become a joint tenant; and The tenant, joint tenant or proposed joint tenant must have notified the landlord that the person they wish to become a joint tenant with is living in the house. The 12‐month period does not start unless the landlord has been told that the person is living in the property as their only or principal home. The 12‐month period applies to anyone wanting to be a joint tenant including the tenant’s spouse, civil partner or co‐habiting partner. We will not unreasonably withhold permission for a joint tenancy, unless there are justified reasons for this. We will deal with all applications individually. Examples for refusing a joint tenancy are listed below: Where one of the future tenants owes a lot of rent or has any other tenancy‐ related debt. Where one of the future tenants has been evicted for antisocial behaviour or an interim or full antisocial behaviour order has been made against them. Page 88 of 204
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54 Where one of the future tenants refuses to give up their interest in another tenancy. Where a notice of proceedings for recovery of possession has been issued. Where the 12 month residency and notification period has not been met. Where the application may result in overcrowding. Page 89 of 204
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55 APPENDIX 7 ‐ Mutual Exchange Council tenants have the right to exchange their tenancy with another secure tenant, as long as they get their landlord’s permission in writing. Applications should be made to your local housing office. We will not unreasonably withhold permission, unless there are justified reasons for this. We will deal with all applications individually. Examples for refusing an exchange are listed below: The tenant is under a court order giving us possession of the property. Notice of proceedings for possession have been issued for any of the following reasons: The rent has not been paid or the conditions set out in the lease have been broken. A nuisance is being caused to neighbours by anyone living in the property, or anyone concerned is using it for immoral or illegal purposes. Anyone living in the house has damaged it or has damaged shared areas. Anyone living in the house has damaged our furnishings. The accommodation is larger than the tenant’s family need. The accommodation is not suitable to the needs of the tenant’s family. The accommodation was provided as a result of the tenant’s employment with the council. The accommodation was designed or significantly adapted for a physically disabled person or someone with particular housing needs, and if the exchange was allowed there would no longer be a disabled person or someone who needed this type of property living in the property. We consider that the exchange could result in overcrowding or under‐ occupation. If we do not let the applicant know the outcome of the request within one month, they can assume we have agreed to their request. If we refuse a request for a mutual exchange, the applicant has the right to appeal against our decision. Page 90 of 204
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56 APPENDIX 8 ‐ Recovery of Adapted Properties Schedule 2, paragraphs 11 and 12 of the Housing (Scotland) Act 2001, outlines that where social landlords let an adapted or property designed for special needs and the person who required the adaptations moves out or dies, landlords have the right to seek recovery of this property where we subsequently require it for an applicant who needs the adaptations. The remaining tenant or household member would, where appropriate, be offered alternative suitable housing. In accordance with existing practice, the tenant(s) is advised of this in advance of accepting the property. The decision to recover a property under these circumstances, is made on a case by case basis by the landlord. The Housing (Scotland) Act 2014 amends paragraphs 11 and 12 of schedule 2 of the Housing (Scotland) Act 2001, which only allowed recovery of possession of an adapted property where there was no longer an occupier who required the adaptation. The 2014 Act has amended the 2001 Act, removing the words ‘’no longer’. This means that landlords can seek to recover a property where no occupier required the adaptation in the first place and where the property is subsequently required for a person who needs the adaptation. This is noted in our Common Allocation Policy at Section 5.7. Application The 2014 Act provides landlords with the flexibility to make better use of adapted properties as short‐term temporary accommodation, where at the point of adaptation there is nobody requiring the adapted property. Renfrewshire Council and our partner landlords will always seek to make the best match to available properties and will endeavour to re‐let properties to applicants who require the adaptations offered by available properties. We recognise that some properties will be more challenging to let and that there may be circumstances where we cannot match an applicant to adapted properties and therefore we may require to let to someone requiring mainstream accommodation. Under these circumstances, we reserve the right to decide at the point of allocation, if we would choose to let this property as a Short Scottish Secure Tenancy; where there are grounds to do so, or as a Scottish Secure Tenancy and retaining the right to recover the property at a later date where required. Page 91 of 204
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57 The prospective tenant would be advised that we may seek to re‐house them in suitable alternative accommodation, at a future date should another applicant later require their adapted home, to allow them to fully consider their position prior to accepting the tenancy. The tenant would also be advised that this may restrict any future mutual exchange application they may make, where the person they wish to exchange with does not have a requirement for an adapted home. This will be decided on a case by case basis by the landlord. Suitability of alternative accommodation is determined according to the Housing (Scotland) Act 2001. Where the tenant does not accept the offer of alternative accommodation, the offer will still be deemed to be suitable unless the tenant can satisfy the court that it was reasonable to refuse it. We will make up to two reasonable offers of alternative accommodation, in accordance with our Common Allocation Policy. Where the existing tenant refuses to move voluntarily after receiving up to two reasonable offers of suitable accommodation, the landlord can seek repossession of the property. Where a Short Scottish Secure Tenancy is applied, we have no requirement to provide alternative accommodation at the end of the tenancy term. We recognise the importance of tenancy sustainment and provision of settled accommodation and would therefore not seek to recover an adapted property after a period of 12 months has elapsed from the tenant’s date of entry. Date in force The changes introduced by the Housing (Scotland) Act 2014 in relation to the Recovery of Properties Designed or Adapted for Special Needs, comes into force on 1st May 2019 and this policy assumes the same date. In accordance with the Housing (Scotland) Act 2014, only properties let on or after this date to applicants who do not require the adaptations in the first place, will be subject to this policy. It cannot be applied retrospectively. However the terms of schedule 2, paragraphs 11 and 12 of the Housing (Scotland) Act 2001 continue to remain in force from their original date and does not change the approach to tenancies that pre‐existed this date. Page 92 of 204
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58 APPENDIX 9 ‐ Statutory Definition of Overcrowding (section 136 and 137 of the Housing (Scotland) Act 1987) A house is overcrowded when the number of persons sleeping in the house is such as to contravene:‐ (a) the room standard (b) the space standard Section 136 the room standard: (1) The room standard is contravened when the number of persons sleeping in a house and the number of rooms available as sleeping accommodation is such that two persons of opposite sexes who are not living together as husband and wife must sleep in the same room. (2) For this purpose: (a) children under the age of 10 shall be left out of account, and (b) a room is available as sleeping accommodation if it is of a type normally used in the locality either as a bedroom or as a living room. Section 137 the space standard: (1) The space standard is contravened when the number of persons sleeping in a house is in excess of the permitted number, having regard to the number and floor area of the rooms of the house available as sleeping accommodation. (2) For this purpose: (a) no account shall be taken of a child under the age of one and a child aged one or over but under 10 shall be reckoned as one‐half of a unit, and (b) a room is available as sleeping accommodation if it is of a type normally used in the locality either as a living room or as a bedroom. (3) The permitted number of persons in relation to a house is whichever is the less of: (a) the number specified in Table 1 in relation to the number of rooms in the house available as sleeping accommodation, and Page 93 of 204
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59 (b) the aggregate for all such rooms in the house of the numbers specified in column 2 of Table 2 in relation to each room of the floor area specified in column 1. No account shall be taken for the purposes of either table of a room having a floor area of less than 50 square feet. (4) The Secretary of State may prescribe the manner in which the floor area of a room is to be ascertained for the purposes of this section; and the regulations may provide for the exclusion from computation, or the bringing into computation at a reduced figure, of floor space in a part of the room which is of less than a specified height. (5) Regulations under subsection (4) shall be made by statutory instrument, which shall be subject to annulment in pursuance of a resolution of either House of Parliament. (6) A certificate of the local authority stating the number and floor areas of the rooms in a house, and that the floor areas have been ascertained in the prescribed manner, is evidence for the purposes of legal proceedings of the facts stated in it. Table 1 Number of rooms Number of persons 1 2 2 3 3 5 4 7.5 5+ 2 for each room Table 2 Floor area of room Number of persons 110 sq. ft. or more 2 90 sq. ft. or more but less than 110 sq. ft. 1½ 70 sq. ft. or more but less than 90 sq. ft. 1 50 sq. ft. or more but less than 70 sq. ft. ½ Page 94 of 204
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60 Appendix 10 – Common Sheltered Allocation Policy Renfrewshire Council Linstone Housing Association Bridgewater Housing Association Renfrewshire Common Sheltered Housing Allocation Policy Page 95 of 204
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61 Contents 1.0 Introduction 63 1.5 Customer service standards 66 2.0 Making an application 68 3.0 Assessing the size of house you need 70 4.0 The sheltered housing list and how we prioritise applications 70 5.0 How we allocate housing 81 5.4 Number of offers 81 6.0 Appeals and complaints 83 7.0 Reviewing this policy 84 8.0 Partner Contact Details 85 Page 96 of 204
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62 1.0 Introduction 1.1 What is sheltered housing? Sheltered housing aims to meet the needs of people generally aged 60 years and over, who wish to live independently in their own homes with support and who would benefit from this type of housing. These self‐contained properties offer tenants the safety of living in a secure environment, whilst also enabling people to retain their independent lifestyle. Sheltered housing tenants benefit from a housing support service which is delivered by sheltered housing officers/housing support officers who are based in the developments at certain times or days during the week. The level of service varies amongst the partner landlords, from some complexes having staff based there 7 days a week to less intensive staffing arrangements. You can find out more about this by contacting the landlord for the development(s) you are interested in. Our housing staff will complete a personal support plan with you which will help identify the level of support you need to live at home. This may require support from other agencies or voluntary organisations. Our staff understand people's individual needs and work to enable older people to live independently and be actively engaged within the wider community. Many of our sheltered complexes have a communal lounge where social activities take place and tenants are able to participate if they wish to do so. This is a common sheltered allocation policy and as such there may be some differences in the sheltered accommodation provided by each of the partner landlords. It is recommended that you view the website of the landlord you wish to be housed by, or visit their office, to access further information about their sheltered housing provision. Both Linstone and Bridgewater Housing Associations provide very sheltered housing and/or extra care housing, which is dealt with separately from this policy and any enquiries about this should be directed to them. Page 97 of 204
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63 1.2 About this policy The Renfrewshire Common Sheltered Allocation Policy is underpinned by Renfrewshire’s Common Housing Allocation Policy, specifying the common approach to allocating the properties of the participating landlords in Renfrewshire. You should refer to this policy for additional detail about how we allocate our housing, including sheltered housing. With this as its foundations, the Renfrewshire Sheltered Allocation Policy was developed in partnership with Renfrewshire Council, Linstone Housing Association and Bridgewater Housing Association. In developing this policy we have consulted with applicants, tenants, Registered Tenant Organisations, residents, representatives of community groups and other key stakeholders. This policy is a public document and is available on each of our websites. Copies are also available from our offices. If you require this document in large print, audio or Braille, or in another language, please contact the landlord that you are applying to for sheltered housing. The policy sets out an agreed, common approach that partner landlords will use as their framework to assess and allocate sheltered homes that become available for let. By allocating, we mean the process of selecting people from our housing list, offering them a house and if they accept, signing a tenancy agreement with them. This policy is based on a priority approach and has a clear focus on meeting the need for sheltered housing. It replaces all previous sheltered housing allocation policies of partner landlords. We will review this policy every 3 years, or sooner where changes to legislation, regulation or the results of our performance monitoring require otherwise. 1.3 The partner landlords Summary information on each of the partner landlords that operate this policy is set out later in this document. Further information about each landlord, including where they have sheltered housing properties and how many properties usually become available for let, can be accessed on each landlord’s own website or by visiting one of their offices. Page 98 of 204
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64 Renfrewshire Council is the largest social rented sector landlord in the area with 12,305 properties across Renfrewshire. Of this, over 300 are sheltered properties based in Paisley, Renfrew, Johnstone and Elderslie. Most flats are located on the ground floor, though sheltered housing is also provided on the first and second floors at some complexes – with lifts available in most cases. In addition, some of our sheltered flats are suitable for wheelchair users and all are accessible for people with mobility problems. All our sheltered complexes have a communal lounge where social activities take place. Linstone Housing Association has around 1,572 properties located mainly in Linwood and Johnstone, with a small number in Paisley and Renfrew. Of this, 48 are sheltered properties, with 17 based in Paisley and 31 in Johnstone. Bridgewater Housing Association is the largest provider of social housing in Erskine, with around 847 properties. Of these, 95 are sheltered, comprising 70 one bedroom flats, 17 two bedroom flats and 8 two bedroom bungalows which are suitable for wheelchair users. The flats are mostly located on the ground and first floor. Social activities are held in Community Houses. Please refer to the final page of this document for contact details for each of the partner landlords. 1.4 Our policy aims We are committed to the provision of high quality, affordable sheltered housing that meets both people’s housing needs and housing support needs. When allocating sheltered properties we will aim to: have consistency of approach across Renfrewshire Council, Bridgewater Housing Association and Linstone Housing Association in how we deal with sheltered housing applications. work in partnership to provide excellent customer service to those seeking sheltered housing in Renfrewshire. make sure we offer people accommodation that meets their needs. make best use of the properties that are available to let. give people as much choice as possible. help people live independently offer a safe, secure environment. offer support and social activities. Page 99 of 204
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65 reduce isolation. meet all our legal obligations and operate under the principles set out in the Scottish Social Housing Charter. We will do this by taking an approach to allocating homes that: is fair, open and transparent. takes a consistent approach to decision‐making. promotes equality. treats all applicants with respect, including respecting the confidentiality of information given to us. 1.5 Customer service standards We want to ensure that you are satisfied with the quality of service you receive throughout the housing application and allocation process. We will aim to: Deliver services in a professional and welcoming manner and treat all applicants equally and with courtesy and respect. Deal efficiently with all housing applications and process them in a timely manner. Provide high quality information and advice. Handle all information provided to us with due care and in line with the requirements of Data Protection legislation. Assist with any particular requirements you may have, including by communicating and providing information in ways that meet your needs. 1.6 Equality and diversity We are committed to preventing discrimination and providing equal opportunities for everyone who applies to us for housing. In applying this policy, we will not discriminate against any individual, household or group on grounds of race, gender, sex, marital status/civil partnership, gender reassignment, sexual orientation, pregnancy or maternity, religion or belief, language, social origin, disability, age or other personal attribute. Page 100 of 204
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66 We will aim to make this policy available in alternative formats such as large print or Braille on request. Translation services for other languages can also be made available. Where practical, we will arrange for an interpreter if you speak a language other than English, or a British Sign Language interpreter. 1.7 Confidentiality and data protection Any information given to us as part of the application process will be processed in compliance with Data Protection legislation. You can ask to look at the information held on your record. If you wish to do this, you should make a written request to the relevant landlord. We will respond within one calendar month. We will not keep your personal information longer than is needed. 1.8 Law, good practice and the Scottish Housing Charter This policy has been developed to be compliant with housing and other relevant legislation. A list of the laws which have been taken into account are set out in Appendix 2. The policy also takes account of good practice guidance from the Scottish Government and the Scottish Housing Regulator. This includes the standards set out in the Scottish Social Housing Charter. Further information is included within the Common Allocation Policy appendices, or can be found on the Scottish Government’s website at: http://www.gov.scot/Publications/2012/03/2602 Page 101 of 204
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67 2.0 Making an application 2.1 Who can apply? Each of the partners operates a separate housing list. You can get information on how to join each landlord’s list by contacting them directly. Contact information for each landlord is included in Section 8 of this document. Sheltered housing is designed for older people and therefore we hold a separate waiting list for applicants seeking this type of housing. To apply for sheltered housing, applicants must generally be 60 years of age or over and be able to live independently with support and/or personal care. If you apply as a couple or with another household member, both applicants will usually be aged 60 years or over. 2.2 Information and advice for applicants When applying to Renfrewshire Council for sheltered housing, you must also have a general housing application form registered with them to allow your sheltered housing application to be processed. However, this is not the case for Linstone Housing Association and Bridgewater Housing Association. We recognise the importance of offering high quality information and advice to those applying for housing in Renfrewshire. Anyone making a new application for housing may be invited to attend an interview with the landlord they are applying to. At your interview, we will provide information which may include: How we will process your application How long it will take to process and decide on your application Affordability, including the average cost of renting a property and any service charge you may be liable to pay. Housing options available to you, that takes into account the information you provided to us. We will ask you to complete a short questionnaire that asks questions about your personal, social and support needs as well as other supporting information, to allow us to determine if sheltered housing would meet your housing needs. Page 102 of 204
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68 In many areas of Renfrewshire the demand for housing is considerably higher than the supply. This means that you may have a long wait for housing depending on the areas you choose. This is most likely to be the case if you have no or lower‐ level need for sheltered housing. However there are other areas in which demand is lower and you may have a greater chance of being made an offer. We will give you realistic advice about the likelihood of being re‐housed based on the choices you have made. We will also provide information on opportunities to find housing with other local providers. 2.2.1 Additional assistance If you cannot call into the office of one of the landlords to which you have applied because you have health or mobility problems, a member of staff will visit you at home or arrange a telephone interview. Please let us know if you require this service. If you live outwith our boundaries, or we are not able to visit for some other reason, we will send you an application through the post. 2.3 Information provided by applicants It is important for us to have accurate and up‐to‐date information on your circumstances. If you fail to provide the necessary information to support your application, this may mean that your application cannot be fully assessed. We will ask you to provide any required information and will re‐assess your application once that information has been received. If we do not receive the information we have asked for within 30 days of us asking for it, your application may be cancelled. If you deliberately provide false or misleading information, or withhold information, your application may be suspended. Any offer of housing that has been made may be withdrawn and if a tenancy has been granted on the basis of false information, your landlord could take action to end the tenancy. You must tell us if your circumstances change as this could affect your housing application. Changes of circumstances might include you moving to a new house, someone moving into or out of your current home or a change to your health and social care needs. Changes such as these could affect the size of property you require and how your housing need is assessed. It is important to contact each of the landlords you have applied to and tell them about the changes. Page 103 of 204
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69 2.4 Persons who are subject to Immigration Control The law covering asylum and immigration is complex and applies differently to the Council and the housing association partners. If you could be affected by the legislation, you must tell us. We may be unable to assist but may be able to provide details to you of agencies who can help you. 2.5 Applications from staff, elected members or committee members Applications made by staff, elected members or management committee members will be accepted onto the housing list in the same way as other applicants. We will comply with all relevant legislation, regulatory guidance and best practice in dealing with any of these applications. To make sure that no‐one benefits from a personal connection, applicants will be asked and will be required to declare whether they are related to a member of staff, management committee or elected member for the landlord to which they are applying. Further information will be set out in each landlord’s housing application form. 3.0 Assessing the size of house you need 3.1 Number of bedrooms Sheltered housing sizes can range from 0 bedroom (bedsit), to 1 and 2 bedroom properties. We will work out the number of bedrooms that you require based on who will be living with you, taking account of any health, care or mobility reason for needing an additional bedroom. Further information on bedroom size requirements can be found in Section 3 of our Common Allocation Policy. 4.0 The sheltered housing list and how we prioritise applications This policy has been developed to give priority to those in greatest need for sheltered housing and we aim to make best use of the properties that become available for let given the nature of this type of housing and particular type of services on offer. In addition to any priority awarded for sheltered housing, Renfrewshire Council will also give you a priority on their general housing waiting list which will be Page 104 of 204
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70 different from this. This means that with Renfrewshire Council you may also receive an offer of general, non‐sheltered housing unless you tell them that you only wish sheltered housing. Applications received from a landlord’s own tenants, will be treated in the same way as all other applications. This ensures that those in most need of sheltered housing receive an offer first in most instances. However, where there are particular circumstances that require a person to move to another sheltered property, we will consider these on a case by case basis. To meet local needs, some partners to this policy may operate a separate sheltered transfer list for existing sheltered tenants who wish to transfer to another sheltered property owned by their current landlord. Please contact the landlord you are applying to for further information about their list. 4.1 Factors we must take into account There are certain factors which the law states we must consider when deciding to whom we offer any homes that become available. Housing legislation states that we must give reasonable preference to: People who are homeless or threatened with homelessness and who have unmet housing needs. People living under unsatisfactory housing conditions and who have unmet housing needs. Social housing tenants who the landlord allocating a property considers are under‐occupying their current home. These reasonable preference categories have been considered in the development of this policy. 4.2 Unmet housing needs The Housing (Scotland) Act 2014 sets out the categories of applicant to whom social landlords must give reasonable preference if they have unmet housing needs. This means that landlords should consider whether applicants have housing needs which cannot be met through other housing options which are available. Landlords should consider what those other options might be and whether they are accessible to the applicant. Page 105 of 204
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71 The Housing (Scotland) Act 2014 removes the prohibition on taking ownership of property into account in allocating social housing. This means that if you or someone else on your application owns land or property, or previously owned land or property, we may take this into account when deciding on your priority for social housing. This applies to existing tenants as well as new applicants. 4.3 Factors we cannot consider There are also certain factors which the law states we cannot consider when allocating housing. These are: How long an applicant has lived in the area. Any debt relating to a house which the applicant was not a tenant of. Any rent or other debt the applicant built up on a previous tenancy which has now been paid. Any amount which still needs to be paid where: ‐ The amount owed is not more than 1/12th of the yearly amount due (or which was paid) by the applicant to the landlord for the tenancy; or ‐ The applicant has an agreement in place with the landlord to repay the money, has made payments in line with the arrangement for at least three months, and is continuing to make these payments. Any outstanding debts (including missed Council Tax payments) which do not relate to the tenancy of a house. The age of the applicant, as long as he or she is 16 or over except when allocating: ‐ Houses which have been designed or substantially adapted for a particular age group; or ‐ Houses for people who are, or will be, receiving housing support services for people of a particular age group. The income of the applicant and his or her family. Page 106 of 204
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72 4.4 Our sheltered housing priorities Sheltered housing is generally for applicants who are over 60 years of age and we award a sheltered housing priority to those who it is felt would benefit from a move to a sheltered housing environment and whose needs would be best met in this setting. In instances where an applicant is outwith this age criteria but through exceptional circumstances would benefit from a move to sheltered housing, we may award a priority for sheltered housing. This would be done on a case by case basis making best use of our stock. However, there may be instances where it is concluded that an applicant’s needs are too great to be met in sheltered housing and that alternative, more intensive housing and support is required. In these cases we would recommend alternative routes to settled accommodation and support offered by other organisations, or adaptations to your current home. Where a joint application for housing is made we will assess both parties and their award will be based on the applicant with the highest assessed need for sheltered housing. Our sheltered housing policy recognises those in greatest need for sheltered housing who would benefit from a move to this type of setting. For sheltered housing we focus on your level of social contact, any health issues you may have, or any difficulties you may have in getting out and about and using local facilities and how this affects your wellbeing, which is different from how we consider an application for mainstream housing. This ensures that we cover the aspects of your life that would benefit from a move to sheltered housing. As such, priority is given as follows: Category A – Critical The applicant is experiencing one or more of the following: Experiencing acute social isolation with little or no contact with family/friends. This could include: Someone with very little or no contact with family/friends. Page 107 of 204
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73 Someone who is unable to access social activities within the community or they cannot be accessed by the applicant because of their circumstances i.e. too far away or require support to access which is not available. Applicant is housebound and unable to leave property due to mobility issues and/or cannot access upper floors of their home. Applicant is in hospital and cannot return home because their current home is unsuitable to meet their needs and cannot be reasonably adapted. There has been a history of falls which may or may not have resulted in hospitalisation. Category B – Urgent The Applicant is experiencing one or more of the following: Experiencing significant social isolation with only some contact with family/friends. This could include: Someone with limited contact with family or friends. Someone who is able to access social activities within the community, but requires support to do so and this is not always available Applicant requires support to get in and out of property but has restricted access within the property due to mobility issues i.e. unable to access upper floors of their home, without support/stair lift Applicant is in hospital and will be discharged; however there is a risk to them due to location/accessibility and it cannot be reasonably adapted to meet their long term needs. The applicant’s circumstances puts them in a high risk category for falls Category C – Moderate The applicant is experiencing one or more of the following: Experiencing minor social isolation, but has sufficient contact with family/friends, however would benefit from a move to sheltered housing. Page 108 of 204
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74 Applicant does not require support to get in/out and around property but circumstances indicate that they may experience difficulties within the next 12 months. Applicant could be at risk due to location/accessibility of their current property and it cannot be reasonably adapted to meet their long term needs. 4.4.1 No assessed sheltered housing needs (Priority D) If you are awarded sheltered priority D, this means that you do not have an assessed need for sheltered housing but are within the sheltered housing age‐ range and are looking to move to a sheltered property. Page 109 of 204
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75 4.5 Additional housing need In addition to the assessment of need for sheltered housing, we will also assess any additional housing needs you may have. If you have another housing need you will be awarded an additional level of priority. This combined with your sheltered priority is referred to as a ‘plus’ award. This will only be given to applicants with an assessed need for sheltered housing with an A, B or C sheltered priority. Full details of what may be additional housing need is set out at 4.6 – 4.8. Level of Priority Overall Need Priority A: Critical Need Priority A +: Critical Need and one or more other need (Priority A to C) Requires a sheltered property and: Critical health and social care, domestic abuse, harassment, insecure accommodation, leaving institutions or specialist accommodation, or below tolerable standard. + award: another of the above or one or more of the B or C awards below. Priority B: Urgent need Priority B +: Urgent Need and one or more other need (Priority B or C) Requires a sheltered property and: Urgent health and social care, social, community or family support, harassment, overcrowding, under‐occupying or relationship breakdown. + award: another of the above or one or more of the C awards below. Priority C: Moderate need Priority C+: Two or more moderate housing needs Requires a sheltered property and: Moderate health and social care, social, community or family support, insecure accommodation, leaving institutions or specialist accommodation, overcrowding, under‐occupying, take up or stay in employment. + award: another of the above. Page 110 of 204
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76 4.6 Critical housing needs The following housing needs attract an A priority. If you have one of these housing needs, this will be considered in deciding your final priority for sheltered housing and may result in a ‘plus’ award: Health and social care needs A: To be granted an A award by the Health and Social Care Panel, you will have critical health or social care needs, other than mobility needs, which are not met by your current housing situation and which impact on your well‐being. Please see the Common Allocation Policy for a full description for this award. Domestic abuse A: We use the Scottish Government’s definition of domestic abuse as gender‐based abuse which can be perpetrated by partners or ex‐partners and can include physical abuse, sexual abuse and mental and emotional abuse. If you give domestic abuse as the reason for applying for a house, we may seek information to support your case, including from Police Scotland, but will not contact the person that is responsible for the abuse. Harassment A: You are experiencing harassment that is specifically targeted at you, in or around your current accommodation and you are not safe in your current accommodation. Harassment can take many forms including intimidating, threatening or aggressive behaviour, both verbal and physical, and can involve attacks on property as well as people. Harassment is often premeditated and reoccurring. The A level priority will usually require a recommendation from Police Scotland that a move is required to ensure your safety. Insecure accommodation A: If you have a definite date, within two months, when you will lose your accommodation through no fault of your own. For example, you are losing accommodation which is linked to your employment or have been issued with legal documents to leave your private rented or owned accommodation within two months (such as a Notice to Leave or Mortgage Repossession papers). Leaving institutions or specialist accommodation A: You are leaving the armed forces, hospital or long‐term residential care and have a date to leave but have nowhere to live when you leave. Page 111 of 204
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77 Property below tolerable standard A: You are living in a property which is below tolerable standard according to the definition is set out in the Housing (Scotland) Act 1987 (as amended by the Housing (Scotland) Act 2001). Being below tolerable standard will include things such as not having a sink with a supply of both hot and cold water or not having an effective system for getting rid of waste water. The full definition is contained in Appendix 3 of the Common Allocation Policy. The local authority must confirm in writing that a house is below the tolerable standard for this to be applied. 4.7 Urgent housing needs (Priority B) The following housing needs attract a B priority. If you have one of these housing needs, this will be considered in your final priority for sheltered housing and may result in a ‘plus’ award: Health and social care needs B: To be granted a B award by the Health and Social Care Panel, you will have urgent health or social care needs, other than mobility needs, which are not met by your current housing and which are impacting on your well‐being. Social, community or family support B: You need to move to be closer to a family member to give or receive essential support to carry out day‐to‐day tasks and the support you give or receive is necessary to allow you or your family member to live independently. You would receive this award if it is not possible or reasonable for you to give or receive the support where you currently live and you are looking to move to within a reasonable distance of the person giving or needing the support. Harassment B: You are experiencing harassment that is specifically targeted at you, in or around your current accommodation, but you are safe in your current accommodation. Or you fear violence, and this fear is justified. Harassment can take many forms including intimidating, threatening or aggressive behaviour, both verbal and physical, and can involve attacks on property as well as people. Harassment is often premeditated and reoccurring. The B level priority will usually require a recommendation from Police Scotland that a move is required to ensure your safety. Overcrowding B: Your current home has two bedrooms fewer than the number you need. We will calculate the number of bedrooms you are short by comparing Page 112 of 204
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78 the number you have and the number we have assessed you as needing. If members of the household applying to live together are currently living in different properties, we will assess overcrowding against the home which comes closest to meeting the combined household’s needs. Under‐occupying B: You live in a social rented property and your current home has two or more bedrooms more than you need. We will calculate how many extra bedrooms you have by comparing the number in your current home and the number we have assessed you as needing. You will only receive this level of priority if you are looking to move to a property that has two or more fewer bedrooms than you currently have. Relationship breakdown B: If the relationship between you and a partner with whom you live has broken down, you are still living together and you wish to move to another property. The priority will only be awarded to the household wishing to move out of the current home. 4.8 Moderate housing needs (Priority C) The following housing needs attract a C priority. If you have one of these housing needs, this will be considered in your final priority for sheltered housing and may result in a ‘plus’ award: Health and Social Care needs C: To be granted a C award by the Health and Social Care Panel, you will have health or social care needs, other than mobility needs, which are not met by your current housing and are impacting on your well‐being. Social, community or family support C: You need to move to be closer to a family member to give or receive support to carry out day‐to‐day tasks and the support you give or receive is necessary to allow you or your family member to live independently. You would receive this award if it is difficult for you to give or receive the support where you currently live and you are looking to move to within a reasonable distance of the person giving or needing the support. Overcrowding C: Your current home has one bedroom fewer than the number you need. We will calculate the number of bedrooms you are short by comparing the number you have and the number we have assessed you as needing. If members of the household applying to live together are currently living in different properties, we will assess overcrowding against the home which comes closest to meeting the combined household’s needs. Page 113 of 204
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79 Under‐occupying C: You live in a social rented property and your current home has one bedroom more than you need. We will calculate how many extra bedrooms you have by comparing the number in your current home and the number we have assessed you as needing. You will only receive under occupation priority if you are looking to move to a smaller property. Take up or stay in employment C: If you need to move so you can keep your job or you have an offer of employment and need to move to take up the offer. We will only make this award if the move you are looking for will mean you live closer to your place of employment and/or to suitable public transport links. Insecure accommodation C: You have no safe and permanent home of your own and are living in accommodation you have no right to occupy. Leaving institutions or specialist accommodation C: You will be leaving the armed forces, hospital, long‐term residential care or prison and will have nowhere to live when you leave. Page 114 of 204
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80 5.0 How we allocate housing 5.1 How we allocate our properties When a sheltered property becomes available for re‐let, it will normally be offered to applicants on the sheltered housing list. We will always aim to make an offer to applicants who are looking for a property of that type and in that location. We will then take account of the overall level of priority. Where more than one applicant has the same priority, the first offer will be made to the applicant who has held that level of priority longest. There may also be instances where we will allocate a property out‐with our sheltered housing waiting list, as stated in section 4.12 of our Common Allocation Policy. This may be because we are unable to let a property adapted for wheelchair use from our sheltered waiting list, where an applicant’s particular need will be best met by sheltered housing, or in an emergency housing situation. In these cases, the allocation will be dealt with sensitively and we will ensure that the applicant would be best suited to a sheltered environment. 5.2 Nominations and referrals The council has nomination agreements with other social housing landlords which have housing in Renfrewshire, which includes sheltered housing. If you have joined the Council’s housing list and have agreed to be nominated to a housing association, you may be referred to a housing association landlord for an offer of housing. The Council and housing associations also have an agreement covering offers of housing to people who are statutorily homeless. These arrangements are in line with Section 5 of the Housing (Scotland) Act 2001. This means that an applicant that is statutorily homeless whom it is felt that would benefit from sheltered housing, may receive an offer of this type of housing. 5.3 Number of offers We aim to work with applicants to help them make the best choices. We make offers based on your housing needs and preferences after contacting you to confirm that the details we hold on your application form are accurate. This is Page 115 of 204
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81 good practice as it allows us to reduce inappropriate offers and ensures that your application details are as up‐to‐date and accurate as they can be. We may make up to two offers of housing. Offers will be made on the basis of what is considered to be reasonable for your household to occupy. In deciding what is reasonable, we will take account of your choices and preferences, balanced against the supply of suitable properties and the urgency of your need for housing. If you have been placed in priority band A or A+ you will have a very urgent need to be housed. In order to make you an offer as quickly as possible, we may need to make you an offer of housing in an adjoining area or of another property type to those you have chosen. We will consider such an offer to be a reasonable offer of housing. If you refuse a first reasonable offer of housing from one of us, that landlord may invite you to a housing information and advice interview to discuss your choices. We would not normally make any further offers until that interview has taken place. After receiving this housing advice, if you refuse a further reasonable offer from that landlord within the next 12 months they may suspend you from their list for up to 6 months. If you are suspended from one of our lists, the landlord concerned will not make you any more offers until that suspension is removed. Further information on suspensions is provided in Section 6 of the Common Allocation Policy. Page 116 of 204
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82 6.0 Appeals and complaints 6.1 Appeals We will always aim to give you an excellent service, but we recognise that you may disagree with some of our decisions and may wish to make an appeal. Each of the landlords operates its own appeals policy which is available on their website or from their office upon request. You can get information from your landlord on how to make an appeal. We may also offer interpreting and translation services if English is not your first language. We can also provide a British Sign Language interpreter if required. 6.2 Making a complaint If you are not satisfied with the service you have received from us, you can make a complaint. Each landlord has its own complaints policy and process. If you wish to make a complaint you should contact the landlord involved. They will also publish information on their website about their complaints process. Contact details are provided later in this document. If you make a complaint to a landlord but are not satisfied with the outcome, you can refer your case to the Scottish Public Services Ombudsman. Each of our complaints policies will explain each step of the process, including how you can appeal to the Scottish Public Services Ombudsman. The Ombudsman is a government‐based organisation which can review your case if you have already been through a landlord’s complaints procedures and you feel they have not dealt with your complaint fairly. If you feel that your landlord has done, or failed to do something that puts the interests of its tenants at risk, you can also refer your case to the Scottish Housing Regulator. The Scottish Housing Regulator’s website provides information about significant performance failures and what you should do and how to raise your concerns with them. You can find this information at: www.scottishhousingregulator.gov.uk Page 117 of 204
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83 7.0 Reviewing this policy We will keep this policy under review. If the monitoring of our performance suggests areas in which the policy needs to be improved, we may amend the policy if required. If any changes to be made are substantive, we will consult with tenants, applicants and other key stakeholders before making these changes. We will undertake a full review this policy every three years, or earlier where required. Page 118 of 204
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84 8.0 Partner Contact Details If you would like to contact Renfrewshire Council, Linstone Housing Association or Bridgewater Housing Association about any aspect of this policy, their details are provided below. Renfrewshire Council, Environment Housing and Infrastructure ‐ Paisley: Customer Service Centre, Renfrewshire House, Cotton Street, Paisley, PA1 1AN. Opening hours: Monday to Thursday 8.45am to 4.45pm and Friday 8.45am to 3.55pm. Telephone: 0300 300 0222 Email: Paisley.hps@renfrewshire.gov.uk Web: www.renfrewshire.gov.uk Johnstone: Customer Service Centre, Johnstone Town Hall, 25 Church Street, Johnstone, PA5 8FA. Opening hours: Monday to Thursday 8.45am to 4.45pm, Friday 8.45am to 3.55pm. Telephone: 0300 300 0222 Email: Johnstone.hps@renfrewshire.gov.uk Web: www.renfrewshire.gov.uk Renfrew: Customer Service Centre, 14 Renfield Street, Renfrew, PA4 8RN. Opening hours: Monday to Thursday 9.00am to 12.00pm and 2.00pm to 3.45pm, Friday 9.00am – 12.00pm and 2.00pm to 2.45pm. Telephone: 0300 300 0222 Email: Renfrew.hps@renfrewshire.gov.uk Web: www.renfrewshire.gov.uk Linstone Housing Association – Head office: 17 Bridge Street, Linwood, PA3 3DB. Opening hours: Monday, Tuesday, Thursday and Friday 9.00am – 4.30pm, Wednesday 1.30pm – 6.00pm. Telephone: 01505 382383 Email: general@linstone.co.uk Web: www.linstone.co.uk Bridgewater Housing Association – Head office: 1st Floor Bridgewater Shopping Centre, Erskine, PA8 7AA. Opening hours: Monday to Friday – 9.00am – 12.00pm and 1.00pm – 4.00pm. Telephone: 0141 812 2237 Email: admin@bridgewaterha.org.uk Web: www.bridgewaterha.org.uk Page 119 of 204
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 ___________________________________________________________________ Report by: Director of Environment, Housing and Infrastructure ___________________________________________________________________ Heading: Renfrewshire Common Housing Allocation Policy – Council Allocation Targets for 2025/26 ___________________________________________________________________ 1. Summary 1.1 Following approval by the Communities, Housing and Planning Policy Board in January 2019, the Renfrewshire Common Housing Allocation Policy was implemented by the Council on 1 May 2019. The policy was reviewed during 2024, and a separate report updates the Board on the outcome of that review. 1.2 Applicants are placed in one of five groups according to their circumstances and targets are set for the proportion of lets to each of the groups. These targets are set and reviewed annually by the Council. This report contains the targets proposed for 2025/26. 1.3 To assist in setting the allocation targets, analysis of the lets over the previous 12 months was carried out and is summarised in this report ___________________________________________________________________ 2. Recommendations 2.1 It is recommended that the Policy Board: i. Approve the Council’s allocation targets for 2025/26 as set out in section 4 of this report. ___________________________________________________________________ Item 5 CHPB110325 Page 121 of 204
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3. Background 3.1 Housing applicants are placed into one of the following five groups based on their circumstances. Depending on the group applicants are placed in, a level of priority (‘A’ to ‘D’) may also be awarded. Targets are set for the proportion of lets to each group and as properties become available for let applicants are selected from the five groups according to the agreed targets. Statutory Homeless Group Mobility Group (general and transfer applicants) General Applicants Group (not landlord’s own tenants) Transfer Applicants Group - with housing need Transfer Applicants Group - no housing need Statutory homeless A critical need B urgent need C moderate need D no need A critical need B urgent need C moderate need D no need A critical need B urgent need C moderate need Based on date of application 3.2 The Council and its four local housing association partners within the Common Housing Allocation Policy (Bridgewater, Linstone, Paisley and Williamsburgh) use the same groups but each landlord sets its own targets, taking account of the profile of its own Housing List and stock profile. ___________________________________________________________________ 4. Council Allocations Targets for 2025/26 4.1 The Council and other social landlords have a statutory duty to give reasonable preference to people in housing need (people who are statutorily homeless, living in unsatisfactory housing conditions and tenants of social landlords who are under occupying their current home). The targets set for each of the groups must take account of this duty. 4.2 The proposed targets for 2025/26 have been informed by analysis of the demand from those who are statutorily homeless, the Council’s housing list and lettings over the last few years. The current allocation policy has been in place since May 2019. A review of the policy was undertaken during 2024 and is the subject of a separate report to the Board. The key points to note from this analysis are: There were 4,964 applicants on the Council’s housing list at the end of the financial year 2023/24. The six-monthly figure for 2024/25 for applicants on the housing list was 5,271. The Council let 949 properties in 2023/24. The 6 monthly figure for 2024/25 was 604. Most lets are made through the Group system (514 lets, 76% in 2023/24). The 6 monthly figure for 2023/24 was 85%. Page 122 of 204
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The remaining 90 lets made out with the group system are: special lets, sheltered housing lets and lets associated with the approved housing regeneration programme. Within the Group system, 54% of lets went to statutory homeless applicants in 2023/24. The number of homeless lets at year end 2023/24 was 390 (up from 245 the previous year). 50.6% of group lets went to statutory homeless applicants in the first 6 months of 2024/25. Whilst this is below the target of 55%, this is due in the main to an above target percentage of lets going to mobility applicants, which reflects the type of properties which have been let. The number of homeless presentations at the end of 2023/24 was 1026. It is anticipated this will exceed 1100 by the end of March 2025 and it is expected the target of 55% will be met by the year end. Like all local authorities across Scotland, Renfrewshire is experiencing significant pressures in meeting demand for social housing. The Board have been advised throughout the year of pressures facing the service due to homelessness. Presentations continue to rise but to date the Service has dealt with the issues presented to it. Lets to Mobility applicants remain the same, at 10% of lets by the Council over the last three years. This figure is constrained by the suitability of available stock and a property-led approach is used to maximise opportunities to let suitable properties to applicants with mobility needs. Year-end figure for 2023/24 was 10% against a 10% target. The six- monthly figure for 2024/25 is 19.26%. Existing Council tenants are placed in one of two groups – Transfer Applicants with housing need who made up 11% of the applicants on the housing list at the six-month point and Transfer Applicants with no housing need who made up just over 9% of all applicants on the Council’s list at the six-month point. Applicants who are not currently Council tenants and are not homeless or have mobility needs, are placed within the General Applicants group. This is the largest group of applicants, currently representing around two-thirds of all applicants on the housing list. This group includes both people with housing need and with no housing need. The applicants with a housing need held in this group represent around 62% of all applicants on the housing list. 4.3 Taking account of the above information, and the duty to give reasonable preference to housing need, targets proposed for 2025/26 are set out in the table below: Group 23/24 24/25 Six-month 2025/26 Target Lets % Target Lets % Proposed target % Statutory Homeless 49% 55% 55% 50.58% 55% Page 123 of 204
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Group 23/24 24/25 Six-month 2025/26 Target Lets % Target Lets % Proposed target % Mobility 10% 10% 10% 19.26% 10% General Applicants (not landlord’s own tenant) 23% 24% 24% 21.79% 24% Transfer Applicants (with housing need) 15% 10% 10% 7.98% 10% Transfer Applicants (no housing need) 3% 1% 1% 0.39% 1% Total 100% 100% 100% 100.00% 100% 4.4 Summary of proposed targets: With the exception of the Mobility group lets, which have exceeded target, all of the other groups have been around their target figure and given the further increase in homeless applications again this year and associated pressures. We are confident that we will meet 55% of lets to homeless applicant by the year end and as such it would be fair and reasonable to retain the 55% target for the homeless group. Therefore, we intend to keep the targets as they are for the next year. ___________________________________________________________________ Implications of the Report 1. Financial – None. 2. HR & Organisational Development – None. 3. Community/Council Planning – Our Renfrewshire is thriving – Meeting the needs of housing applicants Building strong, safe and resilient communities – Creating strong communities in our approach to allocating homes 4. Legal – None. 5. Property/Assets – None. 6. Information Technology – None. 7. Equality & Human Rights – Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – None. Page 124 of 204
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9. Procurement – None. 10. Risk – None. 11. Privacy Impact – None. 12. COSLA Policy Position – None. 13. Climate Change – None. 14. Children’s Rights – None. _________________________________________________________ List of Background Papers The contact officer within the service is Ray Walkinshaw, Housing Regeneration and Development Manager, ray.walkinshaw@renfrewshire.gov.uk. Author: Ray Walkinshaw, Housing Regeneration and Development Manager 0141 487 2189 ray.walkinshaw@renfrewshire.gov.uk. Page 125 of 204
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 ___________________________________________________________________ Report by: Director of Environment, Housing and infrastructure ___________________________________________________________________ Heading: Renfrewshire Council Tenant Participation Strategy – Update ___________________________________________________________________ 1. Summary 1.1 This report provides the Policy Board with an update on the Council’s Tenant Participation Strategy Action Plan, which was approved by the Board on 25 October 2022. ___________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Note the progress made with regard to the Tenant Participation Strategy Action Plan as set out in Appendix 1. ___________________________________________________________________ 3. Background 3.1 The Tenant Participation Strategy 2022 – 2027 which was approved by the Policy Board at its meeting of 25 October 2022 sets out the range of opportunities available to tenants and residents to get involved and to influence decisions about the housing services we deliver. The strategy includes an Action Plan which sets out a range of priorities which were agreed with tenant representatives. 3.2 Tenant representatives worked closely with council officers to develop the strategy and continue to work with officers to monitor the progress of the Action Plan. Progress to date on the key priorities contained within the Action Plan is attached at Appendix 1 and section 4 of this report highlights some of the actions undertaken. Item 6 CHPB110325 Page 127 of 204
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4. Tenant Participation Strategy Progress 4.1 The Strategy covers a five-year period and attached at Appendix 1 is the Scorecard for the Action Plan highlighting what has been achieved since April 2024. The Scorecard was presented to the Tenant Scrutiny Panel for their comments as part of their role in monitoring the Strategy. Feedback from the Scrutiny Panel was positive, and they agreed on the actions for the forthcoming year, which are presented in this report. The Scorecard at Appendix 1 provides more detail of activities throughout the year. The Strategy will continue to be monitored and developed in consultation with our tenant representatives with an annual update provided to the Policy Board for noting. The following are some key highlights since its inception: 4.2 Consultative Forums Tenant Scrutiny Panel The Tenant Scrutiny Panel consists of volunteer council tenants who meet throughout the year to assess and influence the performance, service delivery, plans and activities of Renfrewshire Council’s Housing Service. The Panel also act as a sounding board on how the Service has performed against the Scottish Social Housing Charter and were involved in the design and content of the ‘2024 review for our tenants’ publication which was issued to all tenants in November 2024. Influential in developing the Tenant Participation Strategy, they continue to provide a positive assessment on progress of the Strategy so far. The Panel have a work programme that dictates their work throughout the year, over the past year they have looked at the Tenant Participation Strategy action plan, new build housing and have participated in fire safety sessions. They have also attended the Tenant Information Service (TIS) and Tenant Participation Advisory Service (TPAS) Annual Conferences. Tenant Quality Circles Tenant Quality Circles are volunteer council tenants who carry out inspections of Renfrewshire Council’s multi-storey blocks, sheltered housing complexes and council housing estates to ensure a quality standard is being achieved and maintained in every multi-story block, sheltered complex and housing estate. The volunteers help to identify any matters that could be changed, repaired, or upgraded to improve the quality of the buildings and their surrounding areas. This year saw nineteen inspections by all of the Quality Circles. The Estate Management Quality Circle has carried out inspections in seven areas, namely Thornbrae (Johnstone), Douglas Street and Well Street (both Paisley West End), Achray Drive (Foxbar), Grampian Avenue, Morven Avenue and Fairway Avenue (Glenburn). Given the size of some of these areas the Quality Circle have visited some of these areas more than once. Page 128 of 204
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They have tied in with the Housing Estates Manager (Council Housing) as part of their collaborative approach to inspections by issuing their inspection reports to help draw up work programmes. The High-Rise Quality Circle has been involved with the development of Scooter pods at Maxwellton Court as well as routine block inspections. The Sheltered Quality Circle has carried out inspections in 3 blocks and raised a number of issues that have been addressed. Some members of the Quality Circes now have access to digital tablets which allows them to complete inspections more efficiently for data collection and to take photographs of areas inspected. 4.3 Digital Participation The strategy was developed so that tenants and the Service could make best use of digital resources to maximise participation. Throughout the year the Tenants’ Scrutiny Panel has continued to meet online using the Microsoft TEAMS platform and the Panel has recently started hybrid meetings. The 2025-27 Rent Consultation process was conducted using an online survey and in total over 1,000 tenants participated. This was the second time the Service has made use of an online consultation for the rent consultation. Participation in the online survey was promoted by letter and using targeted emails from the Corporate Communications Team. More than 5,300 tenants have provided their email contact to receive updates from us. This channel is used to provide important information, including about preparing your home for winter weather and accessing council services over the festive period. It is also used to share rent consultation engagement opportunities and email communication is achieving a high engagement and click-through rate. 4.4 Communication We have worked closely with colleagues in our corporate Communications team to improve the ways we communicate with tenants. We will continue to collaborate with our Communications team throughout the lifetime of the strategy to develop improved channels of communication. During the year we informed tenants of service updates and our regulatory requirements, using: In November, The People’s News was rebranded, and a refreshed annual review was posted to all our tenants, providing details of our performance as a landlord and sharing information about the wide range of support and services for tenants to access. Page 129 of 204
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Housing services content on renfrewshire.gov.uk is being rewritten to support an improved user experience and ensure our tenants can find and access the information they are looking for. Council website to advise of our performance on the Scottish Social Housing Charter and the Scottish Housing Regulator’s Engagement Plan. 5,300 tenants have signed up to direct e-mailing for updates and information from the service. As noted in section 4.3 above, this year’s rent consultation process was extensive, with over 1,000 tenants responding. All tenants were advised of the online survey by letter, which was accompanied with background information setting out service priorities. Targeted e-mails advised over 5,300 tenants of the online survey which again was accompanied with service priorities and background information. In addition to tenant consultation, the Council Wide Forum received a presentation on Service priorities and the background to the rent increase proposals. 4.5 TARA Activity, Training and Events Re-registration for Tenant and Resident Associations took place in Autumn 2025. Four TARAs applied for and were accepted for re-registration. The Tenant Participation Development Officer continues to work with new groups which are interested to register. Tenant and Resident Association members attended the Tenants’ Information Service (TIS) Annual Conference and Tenant Participation Advisory Service (TPAS) Annual Conference this year. A new Tenants and Residents Association was established in Arkleston and Newmains with support from the Service Development Officer. Work is ongoing to develop associations elsewhere in the Council area. Following concerns raised by some of the TARAs that their banks were introducing monthly charges, the Service Development Officer with colleagues at Engage have held talks with local organisation Right Way Credit Union www.rwcu.co.uk which can offer an services that may be of interest to the TARAs. This is not to be considered financial advice, rather support in finding a ‘bank’ that will be able to help at a cheaper rate. 4.6 Tenant Surveys Over the past year we have carried out several tenant surveys: We commissioned our biennial Tenant Satisfaction Survey which was conducted by an independent market research firm - ‘Research Resource’ - by telephone, covering just over 1,200 households, representing around 11% of the Council’s tenanted stock. This survey results were reported to Board in August and has been informative to assist in service development. Page 130 of 204
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The Housing Estate Manager (Council Housing) has been working to see how the information gathered can help the effectiveness of the Neighbourhood Environmental Trainee Teams (NETTs). Rent consultation was carried out online to inform members of tenants’ views on rent increase proposals. For our ARC return we also seek tenants’ views on: Satisfaction with the repairs service Homeless services, temporary accommodation and housing advice Property condition We have also started work on a further survey of tenants in our new build properties in Ferguslie Park, to meet the funding requirements of the Scottish Government. 4.7 Consultation with Tenants and Residents in Regeneration Areas The Housing-Led Regeneration and other Newbuild areas have benefitted from a range of consultative initiatives. The Howwood Road Area and the Gallowhill Newbuild area have both had consultation events. Around 120 people attended at Howwood Road and over 30 households were represented at Gallowhill. The Howwood Road area has also seen several initiatives including a community litter pick, and a Regeneration Drop-in office has been established where every Tuesday and Thursday tenants and residents can pop in to find out more about the project. In addition, the Howwood Road Facebook page provides opportunities for residents to find out and comment on regeneration issues. Other regeneration areas benefit from Pop Up Advice surgeries and area walkabouts, where residents can discuss issues with staff. The Springbank/Mossvale area has a drop-in office open every Wednesday. 5. Tenant Participation Priorities for 2025/2026 5.1 For the forthcoming year the priorities, in addition to day-to-day tenant participation, will see further developments in expanding the ways in which tenants are involved in shaping housing services: 5.2 #Youdecide The rent consultation for 2025–2028 advised tenants of the participatory budgeting initiative (#Youdecide). Tenants will be involved in deciding how some funding is spent in council housing areas. The full details of this initiative will be developed and brought to the Policy Board for approval prior to implementation. Page 131 of 204
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Tenant Scrutiny Panel/Quality Circles During the forthcoming year the Tenant Scrutiny Panel will continue to work on issues from their work programme, including discussions on the voids process. Quality Circles will continue with inspections and the Estate Management Quality Circle will develop effective links with the Housing Estate Manager (Council Housing) to suggest improvements to areas. 5.3 Digital Participation and reaching out to other groups We will continue to make best use of digital platforms to improve participation. As indicated the use of digital tablets has been extended to the Quality Circles and the Council Wide Forum has the capacity to facilitate online participants. We will make use of e-mails to provide information to those tenants who have signed up to this and to others who may sign up over the year. The Service will continue to look at ways to engage with other tenants who may not usually be involved, such as younger tenants, disabled groups or tenants from ethnic communities Over the past year officers have attended the Digi-ren meetings to see if opportunities to involve others could arise. 5.4 Communication Working with colleagues in corporate communications we will review current tenant communication and marketing activity and participation opportunities and make recommendations project to improve the way in which we communicate with tenants. This will support increased tenant involvement in shaping our services, identifying any efficiencies and opportunities for improvement. We will continue to provide information through newsletters/brochures to provide tenants with news and information, including information we are required to provide, such as the Tenants’ report on the Charter. 5.5 Council Wide Forum We held a Council wide Forum in Autumn 2024 and will hold another Council Wide Forum in the forthcoming year, which will provide tenants with service information and consult them on service priorities. __________________________________________________________________ Implications of the Report 1. Financial - none arising directly from this report. 2. HR & Organisational Development – None. 3. Community/Council Planning - Page 132 of 204
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Our Renfrewshire is thriving – effective tenant participation gives tenants the opportunity to influence decisions about housing services and gives the Council stronger links with local communities. 4. Legal – None. 5. Property/Assets – None. 6. Information Technology - to support tenants the new strategy will be aligned to the Council’s Digital Strategy. 7. Equality & Human Rights - the Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – None. 9. Procurement – Where external consultants may be required to support tenant participation activities, these will be commissioned in line with the Council’s requirements on the procurement of services. 10. Risk – None. 11. Privacy Impact – None. 12. Climate Risk – N/A. 13. Children’s Rights – N/A. 14. COSLA Policy Position - N/A. ___________________________________________________________________ List of Background Papers (a) Report to the Communities and Housing Policy Board, 25 October 2022, Renfrewshire Council Tenant Participation Strategy’ (b) Report to the Communities and Housing Policy Board, 17 January 2023, ‘Housing Customer Engagement Annual Report 2021/22’ (c) Report to communities and Housing Policy Board, 12 March 2024, Tenant Participation Strategy Update ___________________________________________________________________ Author: Ray Walkinshaw, Housing Regeneration and Development Manager Email: ray.walkinshaw@renfrewshire.gov.uk Page 133 of 204
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1 Tenant Participation Strategy Action Plan Scorecard for 2024/25 Page 134 of 204
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2 Priority To ensure tenants and residents are well informed What have we achieved We reported the outcome of our biennial Tenants’ Satisfaction Survey to the Communities and Housing Policy Board at its meeting on 20 August 2024. Enhanced Communication and Tenant Engagement To improve transparency and enhance communication with our tenants, we launched a rebrand of The People’s News in October 2024. This revamped publication – 2024 review for our tenants – provides a comprehensive overview of service performance, highlights key achievements, and outlines ongoing efforts to enhance service delivery. The Annual Review serves as a valuable resource for tenants, providing detailed information on available services and support options, including assistance with bill payments, energy advice, and winter preparedness guidance. More than 5,300 tenants have provided their email contact to receive information and updates from us. We use this channel to provide important information, including about preparing your home for winter weather and accessing council services over the festive period. It is also used to share rent consultation engagement opportunities and email communication is achieving a high engagement and click-through rate. Housing services content on renfrewshire.gov.uk is being rewritten to support an improved user experience and ensure our tenants can find and access the information they are looking for. In collaboration with tenants, we published Renfrewshire Council's Tenants' Report on the Charter, ensuring transparency and accountability in service delivery. A dedicated tenant presentation on the ARC Return for 2024 and Assurance Statement was provided to tenants in September 2024 where tenant representatives could comment on our performance and the Assurance Statement. Page 135 of 204
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Type document title here 3 In February 2025, we presented the outcomes of our annual Rent Consultation to the Council, which received a response rate of over 1,000 tenants. This valuable feedback directly informs our decision-making processes and ensures that our services continue to meet the evolving needs and expectations of our tenants. Priority We will develop our digital participation opportunities and embed digital engagement across Renfrewshire What have we achieved We have met the Tenants’ Scrutiny Panel and continue to meet with tenants’ groups online using the MS Teams platform. With the support of the Digital Participation Officer tenants and residents have received equipment to work with the service online. New members of the Tenants’ Scrutiny Panel received training and resources to participate online. Our rent consultation for 2025/2028 was carried out online survey to reach a wider audience. We received over 1,100 responses to the survey which included valuable service feedback as well as views on the proposed rent increases. With the support of the Digital Participation Officer, we are developing electronic resources to enable our Quality Circle tenant inspectors (piloting with the Estate Management group) to use tablets to complete the inspection forms. At the October 2024 Council Wide Forum arrangements were put in place to enable tenant representative to join the meeting remotely if they chose, and we will continue to offer this option. We continue to encourage and support Tenants’ and Residents’ Associations to submit their annual registration and supporting information electronically, whilst offering the option to submit information by post or in person. Page 136 of 204
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Type document title here 4 Priority To listen to tenants and consider their views before decisions are reached and promote real opportunities to participate and influence housing services. What have we achieved We again conducted our biennial tenant satisfaction survey to help us better understand what tenants enjoy about living in their home and what housing services they think need improved. The survey was conducted by an independent market research firm - ‘Research Resource’ - by telephone, covering just over 1,200 households, representing around 11% of the Council’s tenanted stock. We consulted on the amount our tenants will pay over the next three years, between April 2025 and March 2028. To maximise participation all our tenants were written to encourage them to take part in the rent consultation for 2025 to2028. The letter contained a QR code and website address and contact details to request the consultation in a different form. The consultation was predominantly completed online with over 1,100 responses. The Service continues to carry out tenant satisfaction surveys for key services areas and undertake service improvements were identified from feedback, for example: Standard of temporary accommodation, this survey is carried out at point of service by our Homeless Services team and our return for this survey is consistently over 95% satisfaction. Satisfaction with Housing Advice, all applicants are asked their views on the standard of customer service, the most recent survey had a 97% satisfaction rate. Repairs satisfaction, our method of collection for this survey has changed to text surveys to ensure an immediate response and maximum participation, the most recent survey saw satisfaction at 76.6%. Quality of home satisfaction. This survey is carried out at point of service by housing staff when a tenant moves into a new home. Owners’ survey, this survey is carried out by post each year to gauge satisfaction with the service provided by Owners Services. Page 137 of 204
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Type document title here 5 The Tenant Scrutiny Panel provided feedback on the revisions to the Renfrewshire Common Housing Allocation Policy. Priority Increasing Tenant Participation Opportunities What have we achieved In each edition of The People’s News (now rebranded to reinvigorate interest) we promote the benefits of tenant participation which attracts some interest from tenants who not been involved before. We encourage prospective tenant volunteers who are interested in join to come along to a “taster” meeting/event under no obligation. A number of these tenants attended the Council Wide Forum in October and participate in the Sheltered Housing Quality Circle. These new members will help refresh this group and support existing members. At the October 2024 Council Wide Forum arrangements were put in place to enable tenant representatives to join the meeting remotely if they wanted, and we will continue to offer this option. To assist tenants without their own transport, we can provide transport to and from all our tenant participation meetings and events, including: Council Wide Forum, Quality Circles (High Rise, Sheltered and Estate Management). The Neighbourhood Housing Forums (including the small projects budget) are an established part of Renfrewshire Council’s tenant participation framework but over recent years have become outpaced by the ability to communicate more directly with tenants’ and residents’ associations using technology. We are evaluating various options to replace the current setup, including a “#youdecide” participatory budgeting model. In a change to annual rent consultation, we consulted on the amount our tenants will pay over the next three years, between April 2025 and March 2028. All our tenants were written to encourage them to take part in the rent consultation for 2025 to 2028. The letter contained a QR code and website address and contact details to request the consultation in a different form. The consultation was predominantly completed online with over 1,000 responses. Page 138 of 204
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Type document title here 6 We again conducted our biennial tenant satisfaction survey to help us better understand what tenants enjoy about living in their home and what housing services they think need improved. The survey was conducted by an independent market research firm - ‘Research Resource’ - by telephone, covering just over 1,200 households, representing around 11% of the Council’s tenanted stock. Priority Local Tenants’ and Residents’ Associations (TARAs) What have we achieved As part of our support to TARAs each association was offered a ‘health check’ as part of the TARA registration process. This check identified areas where each association required additional support and training requirements. We continue to work with local residents within areas where there is council housing to help setup tenants’ and residents’ associations: A new association has been set up in the Arkleston and Newmains area of Renfrew Working in collaboration with Engage, discussions are ongoing with residents in the Kirklandneuk area to setup and association We are assisting tenants within the George Street area of Paisley to setup a new association to represent their area We are working with colleagues within the regeneration team to ascertain the demand for an association with in the Howwood Road regeneration area In collaboration with regeneration colleagues, we are working in the Howwood Rd area are gauging interest from residents to develop a TARA within the regeneration area. The Tenants’ Scrutiny Panel have been progressing a scrutiny exercise looking at Constitutional matters and the Registration Scheme for Tenants’ and Residents’ Associations and how TARAs are supported. We have been liaising with the Rightway Credit Union to assist TARAs to offer banking services, this is in response to some associations advising that their banks were now incurring monthly charges to their accounts. Page 139 of 204
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Type document title here 7 Priority Council wide Tenants’ Forum and the role of the local Neighbourhood Forums What have we achieved The Council Wide Forum in October 2024 was an in-person event but arrangements were in place for tenants to join the meeting remotely if desired. The meeting attracted some new tenant representatives. To assist tenants without their own transport, we can provide transport to and from all our tenant participation meetings and events, including: Council Wide Forum, Quality Circles (High Rise, Sheltered and Estate Management). At the Forum, participants were consulted on the Annual Return on the Charter 2023/2024, Annual Assurance Statement 2024 and Single Voids Team pilot. Tenant representatives provided valuable insight and feedback, particularly on the voids item, including: Discussion with tenant representatives asked why during the Voids process do carpets and fittings need to be removed. Tenant representative suggested that if there could be a ‘trusted trader’ leaflet for tenants who cannot decorate properties themselves. It was agreed that the Tenant Scrutiny Panel would work with staff on the recommendations of the Single Voids Project. Feedback from the tenant representatives on the Forum was that it was a very positive and informative meeting. Priority Tenant Scrutiny Panel What have we achieved The Tenant Scrutiny Panel (TSP) continues to meet monthly online with the option to meet on a hybrid basis as necessary. Page 140 of 204
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Type document title here 8 The Panel continues working on their scrutiny exercise looking at Constitutional matters and the Registration Scheme for Tenants’ and Residents’ Associations and how TARAs are supported. The Panel has been researching how this process is conducted by other landlords to help inform their recommendations. Along with the work on their scrutiny exercise, during the past year the Panel has acted as a ‘sounding board’ for a variety of housing matters and has been involved in the design and content of the rebranded “2024 review for our tenants” Tenants Report on the Scottish Social Housing Charter. Agenda items throughout the year have included: Review of the Tenant Participation Strategy action plan Tenant Information Service (TIS) Annual Conference and the Tenant Participation Advisory Service Annual Conference Newbuild Housing Fire safety sessions Priority Expand the Quality Circles What have we achieved A new Estate Management Quality Circle was established in January 2024 which attracted some new volunteer tenant inspectors. An intensive programme of inspections was developed for the new Estate Management Quality Circle (EMQC) which was replicated with the High-Rise Quality Circle (HRQC) where there are monthly inspections for each group and quarterly inspection for the Sheltered Housing Quality Circle (SHQC). The EMQC and HRQC conduct 12 inspections each per year, with the SHQC conducting 4 inspections per year. The HRQC and SHQC also having 4 meetings each per year with officers to discuss feedback on their inspection reports. The Quality Circles have established links with the Housing Estate Manager (Council Housing) which assist in identifying areas for improvement. Page 141 of 204
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Type document title here 9 In its first year the EMQC has conducted inspections in the following areas: Thornbrae, Johnstone, Foxbar, Glenburn and the west end of Paisley. The HRQC continues its monthly inspections, with on average each of the 14 multi-storey blocks being visited by the tenant inspectors twice annually. Also, the SHQC continues to conduct quarterly inspections with on average all the sheltered complexes being visited by the tenant inspectors every 12 months. All QC inspections only look at the communal areas of the multi-storey block, sheltered complex or tenement building. The EMQC inspections are performed in conjunction with the Housing Officer for the area and Estates Manager, to provide local knowledge while onsite and to ensure a joined-up approach to resolving any issues highlighted by the tenant inspectors. To enable all interested tenants to take part, our Development Officer drives the Health and Wellbeing Services’ Strengthening Opportunities for Older People in Renfrewshire (SOOPIR) Bus. This enables tenant inspectors to be transported door-to-door, and we can accommodate volunteers who require walking aids, wheelchairs or mobility scooters this enables full inclusion. Feedback from the tenant inspectors has been overwhelmingly positive as they are pleased to be out visiting various areas and to have the opportunity to observe first-hand the impact the Quality Circles have, and efforts being made to improve various areas and property types. Feedback from staff is that they appreciate the balanced yet positive comments. With the support of the Digital Participation Officer, we are developing electronic resources to enable our Quality Circle tenant inspectors (piloting with the Estate Management group) to use tablets to complete the inspection forms. This will enable volunteers make their comments, raise issues and provide feedback while also including photographs in a more efficient approach. The information from several tenant inspectors can more easily be collated in to reports which are then circulated to colleagues for comment and action as appropriate. The introduction of technology will provide opportunities to look at the data for trends across various locations and property types which make service improvement that improve tenant satisfaction. Page 142 of 204
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Type document title here 10 Priority Participation in regeneration areas What have we achieved We have used a range of consultation methods in each of the Housing-Led Regeneration and Renewal areas, adapting to the needs and requirements of each community as required and in line with the timeline of the delivery of investment within each area, including: o Groups using social media to promote activity and to keep involved, o Regular community drop-ins where staff can provide information to residents, o Newsletters, and o Neighbourhood Renewal groups have started in 2 areas to capture the views of local people affected by the proposals. Howwood Rd - Consultation Event Over 120 tenants and residents attended the event when over 70 households represented (42 Council Tenants, 24 Private Owners and 5 Other Representatives (neighbouring community and Elected Members). Gallowhill - New Build Consultation Event Around 50 tenants and residents attended the event, representing over 30 households, including: Council Tenants, Private Owners and Private Tenants and Elected Members. A variety of work is being progressed in other areas identified for regeneration: Drop-in surgeries have been established: Springbank (every Wednesday) and Howwood Rd (Tuesday and Thursday) Several regeneration areas benefit from Pop Up Advice surgeries and area walkabouts, where residents can discuss issues with staff. Staff and members of the community at Howwood Rd also took part in a community litter pick Howwood Rd Facebook Page Page 143 of 204
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Type document title here 11 Priority To provide resources and support to empower tenants and residents to influence decisions about housing services What have we achieved We continue to fund tenant participation activities through an identified budget for tenant participation which facilitates: o Support for TARAs through the provision of grant funding. o Support for tenant participation activity, with Housing staff regularly attending TARA meetings to provide advice and support. o Training and development for tenants’ groups, tenant representatives have attended external tenant participation events that provide opportunities to exchange good practice and network with other tenants, including the Tenant Information Service (TIS) Annual Conference and the Tenant Participation Advisory Service Annual Conference. o Membership to independent organisations such as The Tenant Participation Advisory Service (TPAS) and the Tenants’ Information Service (TIS). Tenant representatives have represented the Council. Page 144 of 204
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12 Environment, Housing & Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR Page 145 of 204
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 ___________________________________________________________________ Report by: Director of Environment, Housing, and Infrastructure ___________________________________________________________________ Heading: Housing Landlord Compliance ___________________________________________________________________ 1. Summary 1.1 All social landlords must ensure they meet all duties in relation to tenant and resident safety and have an effective system in place to ensure compliance with statutory, legislative and regulatory responsibilities. 1.2 This report presents the Housing Landlord Compliance Strategy 2025-2028, which sets out the strategic approach to compliance across the six key areas of compliance relating to Council Housing assets (gas safety, electrical safety, fire safety, lift safety, asbestos management and water safety). 1.3 The report also presents the first two of six policies associated with the Strategy – the Gas and Carbon Monoxide Safety Policy and the Electrical Safety Policy – which describe how Renfrewshire Council will meet the statutory, contractual, and regulatory requirements in relation to gas safety and electrical safety relating to our housing assets. 1.4 Details of an independent external review of the strategy and policies by the Social Housing Safety Network Scotland are included within the report. ___________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Approves the Housing Landlord Compliance Strategy 2025-2028, set out at Appendix 1 of this report; 2.2 Approves the Gas and Carbon Monoxide Safety Policy, set out at Appendix 2 of this report. Item 7 CHPB110325 Page 147 of 204
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2.3 Approves the Electrical Safety Policy, set out at Appendix 3 of this report. 3. Background 3.1 In October 2019, the Scottish Housing Regulator wrote to all registered social landlords to stress that “Social landlords must ensure that they meet all duties on tenant and resident safety and that they obtain appropriate assurance about their compliance with all relevant safety requirements”. 3.2 In 2020, the Director of Communities, Housing and Planning commissioned an external consultancy, Savills, to undertake a high-level review of the management and delivery of landlord compliance obligations within Housing Services. The review identified recommendations for improvement in relation to evidence, validation, and assurance across the six main areas of compliance; gas safety, electrical safety, fire safety, lift safety, asbestos management and water safety. 3.3 A key recommendation from this review was for a Landlord Compliance Strategy and a suite of landlord specific compliance policies for the six areas to be developed. 3.4 The strategy and associated policies were completed in 2021 and are subject to three yearly review. An internal review of both the electrical and gas safety policies was completed which was followed up with an independent external review, the feedback from which has been Incorporated into the strategy and policies. The remaining four policies will be reviewed in 2025 and brought to future meetings of the Communities and Housing Policy Board for approval as each of the reviews are completed. 3.5 The independent external review has been undertaken by Ryan Hodgson of the Social Housing Safety Network Scotland, who provided feedback in January 2025. Mr Hodgson is suitably qualified to conduct such a review and is the appointed policy and procedure specialist for The Network providing policy reviews, feedback and up-dates, re-writes, development and support for a number of other social housing providers across Scotland. The following strategy and policies were submitted to the network to be reviewed: Housing Landlord Compliance Strategy Electrical Safety Policy Gas and Carbon Monoxide Safety Policy To summarise the feedback received, the Social Housing Safety Network has stated: From the documents received, which relate to two of the “big 6” compliance areas (electrical safety and gas safety) we can provide the following observations and opinions: Page 148 of 204
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The four-tiered structure of the documents reviewed (strategy/policy/management plan/guidance) is geared for the size and complexity of the organisation in terms of stock structure workstreams and assets. Each layer of documentation contains further levels of cascaded detail in relation to each workstream and to satisfy the level of detail required from Governance and management levels down to detailed day to day operational management. The documents reviewed were generally well written and contained good useful levels of operational detail. The feedback given to Renfrewshire Council included areas for consideration whereby additional detail could be added to further strengthen the existing documents. Some areas of the policy, management plan and guidance were replicated throughout the documents and suggestions were made to potentially remove some of the repetition to make the documents more streamlined and succinct. Due to the internal delivery of work at Renfrewshire Council it is advised to consider stating this within the scope to enable the reader to differentiate responsibilities between oversight and delivery of the “Big 6” compliance work. 4. Housing Landlord Compliance Strategy and Policies 4.1 The overarching Housing Landlord Compliance Strategy is set out in Appendix 1 of this report. The purpose of the strategy is to have an effective system in place to ensure compliance with statutory, legislative and regulatory responsibilities. The strategy outlines the framework in place including suitable resources, policies, procedures and processes, data management and control protocols, performance management and quality assurance. 4.2 The Gas and Carbon Monoxide Safety Policy is set out in Appendix 2 of this report, outlining how the commitment to gas and carbon monoxide safety will be met and how assurance of compliance will be provided to the duty holder. The policy sets out the scope, processes, data management and performance monitoring. Performance on gas compliance is already reported to the Scottish Housing Regulator and to the Policy Board in our twice yearly ARC performance reports. In addition to this, it is proposed that a more detailed report will be brought to the Communities and Housing Policy Board bi- annually in May and October. 4.3 The Electrical Safety Policy is set out in Appendix 3 of this report, outlining how the commitment to electrical safety will be met and how assurance of compliance will be provided to the duty holder. The policy outlines the scope, processes, data management and performance monitoring. Performance on electrical compliance is already reported to the Scottish Housing Regulator and to the Policy Board in our twice yearly ARC performance reports. Page 149 of 204
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In addition to this, it is proposed that a more detailed report will be brought to the Communities and Housing Policy Board bi-annually in May and October. 4.4 The Annual Assurance Statement for 2024 noted that policy board members would be supported with training on landlord compliance matters. A briefing session took place on 11th February for policy board members, which provided an overview of the six main areas of compliance in relation to tenant and resident safety in social housing (gas, electrical, water, fire, lifts and asbestos). The session was led by Vicki Cutler, CFIOSH, MIIRSM, MIFSM, CMgr FCMI, CIHM who is a sector leader in health and safety, particularly tenant and resident safety, Vicki has over 20 years experience in social housing and has worked with many social landlords across the UK, and co-founded the Social Housing Safety Network Scotland of which Renfrewshire Council are members. 4.5 The following policies will be reviewed in 2025 and brought to future Communities and Housing Policy Board meetings. Fire Safety Policy Asbestos Safety Policy Lift Safety Policy Water Safety Policy ___________________________________________________________________ Implications of the Report 1. Financial – Employee costs associated with the Housing Landlord Compliance team and maintenance costs associated with carrying out statutory and regulatory compliance works are included within the Housing Revenue Account (HRA) approved budget each year. 2. HR & Organisational Development – None. 3. Community/Council Planning – Our Renfrewshire is safe – ensuring tenants have a safe place to live. To manage risk to for staff, contractors or members of the public within council housing properties. 4. Legal – None. 5. Property/Assets – Ensuring assets are protected from risk. 6. Information Technology – None. 7. Equality & Human Rights (a) The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. Page 150 of 204
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No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – The strategy and policies align with the Council’s Corporate Health and Safety Policy. 9. Procurement – None. 10. Risk - None. The absence of policies could put the Council at risk of failing to comply with statutory duties for landlord compliance and could be reputationally damaging. 11. Privacy Impact – None. 12. COSLA Policy Position – None. 13. Climate Risk – None. 14. Children’s Rights – No negative impacts on children’s rights have been identified arising from the recommendations contained in the report. ___________________________________________________________________ List of Background Papers Appendix 1 – Housing Landlord Compliance Strategy 2025- 2028 Appendix 2 – Housing Gas & Carbon Monoxide Safety Policy Appendix 3 – Housing Electrical Safety Policy ___________________________________________________________________ Author: Karen Sillars, Housing Asset & Investment Manager Email: karen.sillars@renfrewshire.gov.uk Page 151 of 204
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1 Housing Landlord Compliance Strategy 2025 - 2028 Page 152 of 204
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Housing Landlord Compliance Strategy 2025 - 2028 2 Table of Contents 1. Purpose and Scope ............................................................................ 3 2. Framework ......................................................................................... 3 3. Resources ........................................................................................... 4 4. Housing Landlord Compliance Policies ............................................ 4 5. Procedures and Processes ................................................................. 5 6. Data Management and Control Protocols ......................................... 5 7. Performance Management ................................................................ 6 8. Quality Assurance .............................................................................. 7 Page 153 of 204
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Housing Landlord Compliance Strategy 2025 - 2028 3 1. Purpose and Scope 1.1 The purpose and scope of this Housing Landlord Compliance Strategy is to: Establish and maintain an effective system to plan and deliver housing landlord compliance activities, to manage risk to our customers, staff, contractors and third parties in residential premises owned or managed by Renfrewshire Council. Ensure compliance with the statutory, legislative and regulatory responsibilities of Renfrewshire Council as a landlord and employer and for which the Director of Environment, Housing and Infrastructure is the ‘Duty Holder’ and to provide reasonable assurance to officers, elected members and all relevant stakeholders that this is the case. 1.2 This strategy, its supporting housing landlord compliance policies and subsequent management plans are applicable to: All domestic properties within the Housing Revenue Account All non-domestic properties within the Housing Revenue Account (Offices, Shops, Lockups, Laundrettes) 1.3 Where properties are leased from, and managed on behalf of, third party property owners, statutory responsibility will be detailed within the terms of the lease / management agreement. Where the statutory responsibility lies with the property owner, Housing Services must check that the appropriate certifications and any other relevant Housing Landlord Compliance documentation is in place and be given assurance that they are safe in advance of occupation and use. 2. Framework 2.1 This strategy is based upon an interdependent framework, comprising of: Resources A suite of Housing Landlord Compliance Policies Procedures and Processes (within the Management Plans and Operational Guidance) to deliver each Housing Landlord Compliance Policy Data and Management Control Protocols Performance Management (Monitoring and Reporting) Quality Assurance Page 154 of 204
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Housing Landlord Compliance Strategy 2025 - 2028 4 Fig 1 3. Resources 3.1 The Director of Environment, Housing and Infrastructure and the Head of Housing Services will ensure that the organisation’s internal staffing structure and any external resources engaged on Housing Services behalf, includes the appropriate people, skills and levels of competence to meet the Housing Landlord Compliance obligations and requirements. 4. Housing Landlord Compliance Policies 4.1 A suite of Housing Landlord Compliance Policies will be maintained and regularly reviewed to ensure that statutory, legislative and regulatory requirements are met. 4.2 The ‘Big Six’ Compliance Policies will be developed and appended to the Housing Landlord Compliance Strategy, as follows: Appendix 1 – Gas Safety Policy Appendix 2 – Electrical Safety Policy Appendix 3 – Asbestos Management Policy Appendix 4 – Fire Safety Policy Strategy and Resourcing Policies Procedures and Processes Data Management / Control Performance Management Quality Assurance Page 155 of 204
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Housing Landlord Compliance Strategy 2025 - 2028 5 Appendix 5 – Water Safety Policy Appendix 6 – Lift Safety Policy 4.3 Additional Housing Landlord Compliance Policies will be developed in line with new legislative requirements and recommended practice. 4.4 All of the Housing Landlord Compliance Policies will include: (i) A Statement of Intent (commitments) (ii) An outline of the relevant statutory, legislative and regulatory standards and obligations involved (iii) Objectives (iv) Details of the specific high-level key performance indicators (KPIs) to be used to monitor and report upon the status of service delivery. 5. Procedures and Processes 5.1 A Management Plan will be in place for each area of Housing Landlord Compliance, incorporating procedures and processes to ensure consistency of approach in the delivery of Housing Landlord Compliance responsibilities. 5.2 These procedures will provide clear guidance on Housing Services’ approach to: (i) Delivery (ii) Roles and Responsibilities (iii) Performance Standards (iv) Controls (v) Performance Reporting (vi) Assurance. 5.3 Process maps will detail the key end-to-end processes mapped-out in a simple, logical, and easy to interpret format. 5.4 Housing will monitor the implementation of the Management Plans through a series of performance reports. 6. Data Management and Control Protocols 6.1 Housing’s core database (OHMS or any future replacement database) will contain all asset information and the appropriate asset hierarchy to enable effective management of all housing landlord compliance areas. 6.2 The core database and associated databases (e.g EDM) will contain all key asset and property data including the key attributes that require management to ensure Page 156 of 204
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Housing Landlord Compliance Strategy 2025 - 2028 6 that Renfrewshire is compliant for every asset e.g. gas supply, lifts, fire risk assessments etc. 6.3 A consistent hierarchy will be established between the core database and all other databases (including, if operated, spreadsheets) to ensure that all records are aligned to the master and updates are managed accordingly via agreed, written protocols. 6.4 All amendments to the core database (addition of new assets, demolition, sale and disposal of assets, changes to the type of tenure etc.) will be effectively managed and documented in line with the approved data protocols. This is to ensure that all changes are fully reflected within the specific datasets, which establish the total landlord requirement for each of the housing landlord compliance activity/risk areas. 7. Performance Management 7.1 Housing Landlord Compliance Policies and Management Plans will ensure visibility of performance reporting and the status of delivery of Renfrewshire Council’s housing landlord compliance obligations and requirements – with such performance reporting allowing the monitoring and scrutiny of (and, if necessary and required, challenge to) service delivery at the appropriate levels. 7.2 Reports on the status of housing landlord compliance activities will be at appropriate frequencies and to the following key audiences within Renfrewshire Council in accordance with our internal governance framework as detailed below: Fig 2 Head of Housing Services Director of Environment, Housing and Infrastructure Housing Services Senior Management Team (SMT) Corporate Management Team (CMT) Audit and Risk Scrutiny Committee Communities and Housing Policy Board KPI Report Quarterly Quarterly Bi-annually Bi-annually Bi-annually Bi-annually (May and October) Page 157 of 204
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Housing Landlord Compliance Strategy 2025 - 2028 7 8. Quality Assurance 8.1 Appropriate Independent External Audit (IEA) arrangements will be established to test the quality of Renfrewshire Council’s housing landlord compliance service delivery outputs across all areas of activity. The scope of external audit will include reviewing the policies to ensure compliance with existing legislation and testing of the management plan to ensure the organisation is operating as it has set out within the documentation. This is to provide the Director of Environment, Housing and Infrastructure as duty holder, with reasonable assurance that activities and risks are being managed effectively and, in a manner, consistent with this strategy and its associated policies and procedures/processes (Management Plans). 8.2 An Internal Audit Programme (IAP) will also test areas of housing landlord compliance following approval of the Management Plans – and a ‘rolling’ IAP will be established based on the level of risk. The frequencies will be decided by Internal Audit and will be subject to review based upon an ongoing assessment and reconsideration of risk (being varied, for example, in response to a particular incident or series of incidents should they occur). 8.3 This quality assurance process will have a clear and explicit linkage to Renfrewshire Council’s Corporate Risk Register. 8.4 An overall compliance report will be prepared annually for Communities and Housing Policy Board and Audit, Risk and Scrutiny Board confirming the outcomes of both internal and external quality assurance checks as they relate to Housing Landlord Compliance. This reporting will include any changes and improvements made to Housing Services’ approach based on these outcomes, including any proposed revisions to/updating of this Housing Landlord Compliance Strategy and its associated supporting policies. Page 158 of 204
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8 Environment, Housing and Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR Page 159 of 204
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1 Housing Landlord Compliance Gas and Carbon Monoxide Safety Policy Page 160 of 204
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Gas and Carbon Monoxide Safety Policy 2 Table of Contents 1. Introduction ....................................................................................... 4 2. Statement of Intent ............................................................................ 4 3. Policy .................................................................................................. 6 3.2 Process: ................................................................................................. 6 3.3 Delivery: ................................................................................................. 6 3.4 Additional Safety Measures: Smoke, Heat and CO Detection ............... 8 3.5 Contractors Competency: ..................................................................... 8 3.6 Internal Competency: ............................................................................ 9 3.7 Data: ...................................................................................................... 9 3.8 Assurance: ........................................................................................... 10 3.9 Communication: ................................................................................ 11 4. Implementation ............................................................................... 11 5. Consultation .................................................................................... 11 6. Equality Impact Analysis (EIA) .......................................................... 11 7. Monitoring Performance .................................................................. 12 8. Policy Review ................................................................................... 13 9. Amendment Log/Version Control .................................................... 13 Page 161 of 204
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Gas and Carbon Monoxide Safety Policy 3 10. APPENDIX A ...................................................................................... 14 Page 162 of 204
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Gas and Carbon Monoxide Safety Policy 4 1. Introduction 1.1 At the time of policy approval Renfrewshire Council owns and manages in the region of 12,200 residential properties for let. Approximately 89% of these properties have gas appliances installed. 1.2 Communal gas boiler systems, electric heating and hot water systems, renewable energy systems (air or ground source heat pumps) or communal biomass systems, serve the remainder. Renfrewshire has a responsibility to maintain all installations and appliances owned by it, to the required statutory, legislative and regulatory standards. 1.3 This policy explains how the safety and maintenance requirements for gas appliances and installations (and those of other fuel types covered by this policy) within the housing stock will be met. Individual gas safety and carbon monoxide procedures and processes are contained in the associated gas and carbon monoxide safety management plan. 1.4 It will also cover how Renfrewshire Council’s Director of Environment, Housing and Infrastructure as Duty Holder, will receive assurance of statutory, legislative and regulatory compliance. 2. Statement of Intent 2.1 This Policy covers domestic appliances and communal and district heating systems including Gas-Fired, Solid Fuel (including biomass), Oil-Fired, Air and Ground Source Heat Pumps, Solar Thermal hot water. It also covers properties with a gas supply or a readily available gas supply (but no gas appliances) and other activities that are undertaken at the same time as servicing / inspection of the above appliances. 2.2 Maintenance of other forms of Electric-only Heating will be covered within the Electrical Safety Management Plan. 2.3 Renfrewshire will comply with all current and relevant legislation and specifically as detailed in the following: Health and Safety at Work Act (HASAWA) 1974, The Housing (Scotland) Act 1987, 2001, 2010 & 2014 The Gas Safety (Installation and Use) Regulations 1998 (GSIUR) and Gas Safety (installation and use) (amendment) Regulation 2018 Gas Safety (Management) Regulations 1996, Page 163 of 204
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Gas and Carbon Monoxide Safety Policy 5 Approved Code of Practice L56 (Fifth Edition) ‘Safety in the Installation and Use of Gas Systems and Appliances’ 2018 British Standards, Building (Scotland) Regulations. HETAS guidance (solid fuel systems). HASAWA 1974 and Housing (Scotland) Act 2010 may be applied. L122 Approved Code of Practice (ACOP) – Pressure Systems Safety Regulations. The Gas Industry Unsafe Situations Procedures (GIUSP). Safety in the Installation and use of Gas Systems and Appliances. IGEM/ G/ 11 The current Gas Industry Unsafe Situations Procedures (GIUSP). L80: A Guide to the Gas Safety (Management) Regulations 1996. 2.4 Renfrewshire Council also acknowledges its further obligations under the Acts, regulations and guidance noted in Appendix A. 2.5 In addition, as a landlord and provider of social housing, Renfrewshire Council must meet the requirements of the Scottish Housing Regulator’s (SHR) regulatory standards. 2.6 It is our duty under HASAWA 1974, as an employer to ensure, so far as reasonably practicable, the health, safety and wellbeing at work of all employees. This duty also extends to others such as tenants, visitors to our buildings, members of the public and contractors who could be put at risk through any work activity within our premises. Failure to properly discharge our statutory, legal or regulatory responsibilities may also result in: Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974. Prosecution under Corporate Manslaughter and Corporate Homicide Act 2007. Possible fines and imprisonment. Civil claims. Page 164 of 204
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Gas and Carbon Monoxide Safety Policy 6 SHR’s scrutiny and potential determination of a breach of Regulatory Standards and serious detriment having been caused/potentially caused. Reputational damage. Loss of confidence by stakeholders in the organisation. 3. Policy 3.1 In order to comply with statutory, legislative and regulatory standards and obligations, and to ensure the safety of our customers, tenants, residents, employees, contractors and other visitors to our properties, Renfrewshire will: 3.2 Process: Provide clear lines of responsibility for all appliances and heating systems within the scope of this policy supported by written guidance in the Gas and Carbon Monoxide Safety Management Plan. Ensure that a clear and consistent process including front-line engagement and enforcement is in place to obtain access to properties to conduct the safety checks and works, which shall include legal action when required. Assess available data for relevant information about the customer to help gain access (disability, vulnerability, local connections, etc.). Maintain a process for dealing with gas safety and carbon monoxide unsafe situations in accordance with the Gas Safety Regulations (IGEM/G/11 Edition 2 – Gas industry unsafe situations procedure with amendments July 2022 and June 204) and associated fuel types. 3.3 Delivery: Target that all domestic properties with gas appliances, gas supplies, solid fuel or oil-fired appliances have a valid landlord gas safety record (LGSR/CP12) and/or solid fuel (HETAS) or oil safety (OFTEC) certificate. Inspect all properties with air source, ground source and solar thermal heating/hot water annually and obtain appropriate documentation. Page 165 of 204
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Gas and Carbon Monoxide Safety Policy 7 All other properties with potential to have a gas supply will be subject to an annual check to confirm that no gas supply has been installed. This will not include properties in blocks with no gas infrastructure (e.g. blocks which are confirmed as 100% electric or biomass heating). Landlords do not have a legal responsibility for carrying out a safety check or maintenance to gas appliances owned by the tenant/s. However, at the time of the annual safety check, Renfrewshire Council will also check all tenant owned gas appliances, chimneys or flues that a tenant’s own appliance uses for safety. This will be done by means of: o A visual risk assessment check in line with Gas Safety (Installation and Use) 2018 - Regulation 26(9) and in line with GIUSP and Technical Bulletin TB055. o Application of the relevant Environment, Housing and Infrastructure Gas Safety Procedures. This is in order to comply with other legislation such as HASAWA 1974 and Housing (Scotland) Act 2010, and to ensure any works completed by the tenant that may have been undertaken since the last safety check are identified. Any safety critical faults found on a tenant-owned appliance will result in the appliance being isolated and disconnected from the gas supply and the tenant informed. Renfrewshire will not be liable for repairs to tenant owned appliances. Ensure, where required, that communal/district systems have a Written Scheme of Examination. Target that all communal/district systems are inspected and serviced in accordance with manufacturer’s requirements and the Written Scheme, but in any event at intervals of not more than 6 months and have a valid Landlord Gas Safety Record (LGSR). Disconnect and cap-off the gas supply at the meter and make safe upon a property becoming void. When the property is then re-let, the gas supply is reconnected and a new gas safety inspection will take place, with the issue of a new gas safety certificate (LGSR). If a property is void for more than a 12-month period a service/inspection visit will be made on or before the anniversary date to ascertain that the gas supply is still capped and disconnected (unless the gas has been terminated at the highway outside the property by the transporter and we are in receipt of a disconnection certificate). Page 166 of 204
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Gas and Carbon Monoxide Safety Policy 8 Prioritise defects and remedial works arising from gas safety checks and apply a timescale for action, as detailed within the Gas and Carbon Monoxide Safety Management Plan. 3.4 Additional Safety Measures: Smoke, Heat and CO Detection Install carbon monoxide Detectors in all properties where required – as detailed within the Gas and Carbon Monoxide Management Plan – and test these on an annual basis in conjunction with the annual safety inspection visits and record this test on the Landlord Gas Safety Record (or other applicable record/certification). Test smoke and heat alarms, where fitted, in conjunction with the annual safety inspection visits and record this test on the Landlord Gas Safety Record (or other applicable record/certification). Ensure there is an ongoing programme for life cycle replacement of all carbon monoxide detectors and smoke and heat alarms to meet current Scottish Government standards. Neither install, nor give permission for tenants to install, gas fires, wood burning stoves or open fires. Any unauthorised installations will be required to be removed by Renfrewshire Council’s appointed contractor at the tenant’s own expense. Other tenant alterations should be subject to prior notification, agreement and appropriate landlord’s permission from Housing to proceed before they are undertaken – as is required by the tenancy Agreement. Permission will not be unreasonably withheld. 3.5 Contractors Competency: Only engage with suitably qualified contractors to undertake work on gas installations, in accordance with the obligations of the Construction (Design and Management) Regulations 2015 Regulation 4 (6) – Gas Safe registered companies and Gas Safe registered engineers, with the appropriate Nationally Accredited Certification Scheme (ACS) to undertake any gas-related works. Page 167 of 204
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Gas and Carbon Monoxide Safety Policy 9 Ensure that contractors working with solid fuel appliances are competent to do so and hold current HETAS qualification and registrations, and those engaged in respect to oil-fired appliances are similarly OFTEC registered. Ensure that contractors working with air/ground source heat pumps hold BPEC Level 3 Award in the Installation and Maintenance of Heat Pump Systems or equivalent. Ensure that contractors working with solar/thermal systems hold BPEC Level 3 Award in the Installation and Maintenance of Solar Thermal Hot Water Systems. Ensure that contractors working with solar PV systems hold BPEC Solar PV Installation and Maintenance or equivalent. Carry out an assessment of all contractor competencies annually or at change of contract /contractor, as detailed within the Gas and Carbon Monoxide Safety Management Plan. 3.6 Internal Competency: Maintain a Skills/Training Matrix, through the Individual Development Plan (IDP) process, to ensure that all staff undertaking key roles within the scope of this policy have appropriate training. 3.7 Data: Maintain an up-to-date master database of all properties that have a gas supply including those that may not have a live gas supply but can be readily connected to the gas grid. Maintain an up-to-date master database of all properties that are served by a communal solid fuel (including biomass) heating system. Maintain an up-to-date master database of all properties with air source heat pumps ground source heat pumps, solar/thermal heating/hot water. For each relevant property, record and maintain up to date data confirming which of the appliances within the scope of this policy exist and do not exist and the organisation’s associated responsibility. Page 168 of 204
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Gas and Carbon Monoxide Safety Policy 10 Where a requirement exists, hold data and certification relating to at a minimum the last two safety checks and the next due date. Note that Building Services as a Gas Safe registered company are required to keep the records for 6 years. Where a requirement does not exist hold appropriate evidence. Maintain current and up to date records of remedial works for the entire portfolio, which will detail all recommendations from the safety checks. These records will include (i) Address and risk profile of property, (ii) Detail of the work item required, (iii) Priority and target completion dates/s, (iv) Person responsible, (v) Date of when the work was completed and (vi) Who it was signed-off by, (vii) Evidence of completion. 3.8 Assurance: Ensure that all persons involved with the installation, inspection, servicing and maintenance of Gas, Solid Fuel, Oil and Renewable Technology systems are competent to do so. This would include evidence and confirmation of persons being properly trained and accredited in accordance with this policy. Where necessary, operate a Permit to Work system when safety- critical work is being carried out near to appliances and flues by engineers that are not Gas Safe registered/HETAS or OFTEC approved. Carry out works-based assurance activity – including checks on certification and post-inspection of on-site works – to the level stated within the Gas and Carbon Monoxide Safety Management Plan. A proportion of such checks will be carried out by an Independent 3rd Party. Set a timetable for the review of the Gas and Carbon Monoxide Safety Policy and the associated management plan. Page 169 of 204
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Gas and Carbon Monoxide Safety Policy 11 3.9 Communication: Encourage customers, through the provision of publicity information on the importance of gas and other heating safety, to allow access to carry out safety checks and maintenance works. 4. Implementation 4.1 This policy will be effective from the date of approval by the Communities and Housing Policy Board. 4.2 Staff will be made aware of the policy through appropriate training and a copy will be available on the intranet. The policy will also be uploaded to the Renfrewshire Council website. 4.3 This policy should also be read in conjunction with the Housing Landlord Compliance Strategy and the associated Gas and Carbon Monoxide Safety Management Plan. 4.4 Appropriate training will be provided for all those staff involved with the operational delivery and implementation of the Housing Landlord Compliance requirements and obligations in respect to Gas and Carbon Monoxide Safety detailed within this Policy. 5. Consultation 5.1 This Policy is based on statutory, legislative and regulatory requirements and, as such, consultation with customers has not taken place. There has been consultation with internal teams within Renfrewshire Council. 6. Equality Impact Analysis (EIA) 6.1 We believe all people should be treated with dignity and respect regardless of their Age, Disability, Gender Gender reassignment, Page 170 of 204
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Gas and Carbon Monoxide Safety Policy 12 Race, Religion and belief, Pregnancy and maternity Marriage and civil partnership Sexual orientation or by association with someone with any of these characteristics or perception of having any of these characteristics. 6.2 An Equalities Impact Assessment was undertaken to identify the likely or actual effects of this policy. This includes identifying where there will be a positive impact and further opportunities to further promote equality. Where there are any potential negative impacts identified, we have identified actions required to eliminate or mitigate these negative impacts. (see the full EIA document for full details) 7. Monitoring Performance 7.1 The following KPIs will be subject to reporting: Number of times in current reporting year Renfrewshire failed to meet statutory obligation to complete a gas safety check within 12 months of a gas appliance being fitted or last checked (Charter Indicator 11) % of properties (against the stated total landlord requirement) with a valid LGSR within the past 12 months. % of properties (against the stated total landlord requirement) with other heating types covered by this Policy with a valid certificate within the relevant period. % of Communal/District Boilers (against the stated total landlord requirement) with valid certification within the relevant period. 7.2 Commentary will be provided for any properties out of date, to include the date they became overdue, days overdue and their position within the access legal process to bring them back into a compliant position. Additional context commentary will also include information on the proportion of activities within the reporting period that were undertaken before and after their due date. 7.3 A detailed Performance Indicator suite will be defined within the associated Gas and Carbon Monoxide Safety Management Plan. 7.4 The following Quality Assurance (QA) activity will be undertaken and reported in line with the Gas and Carbon Monoxide Safety Management Plan: Internal audit. Strategic review. 3rd Party assurance. Page 171 of 204
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Gas and Carbon Monoxide Safety Policy 13 8. Policy Review 8.1 The Policy will be reviewed every 36 months or earlier if deemed necessary though the Performance Monitoring process. 9. Amendment Log/Version Control 9.1 Revision Detail/Record: Date of Revision: Record of Amendments: Reason for Revision: 25/11/24 Changes recorded in tracked document held on file Updated legislation and changes to council department names, updates to processes 4/02/25 Changes recorded and held on file Feedback from SHSN – minor changes. Page 172 of 204
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Gas and Carbon Monoxide Safety Policy 14 10. APPENDIX A List of further legislation and regulations Management of Health and Safety at Work Regulations 1999 Equality Act 2010 The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (2013) (RIDDOR) Scottish Social Housing Charter (SHQS) Pressure Systems Safety Regulations 200 The Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEARR) Construction, (Design and Managemen) Regulations 2015 The Workplace (Health, Safety and Welfare) Regulations 1992 Guidance leaflet INDG285 (rev 3): A Guide to Landlord's Duties Technical bulletins and industry safety alerts (Gas safe) The Corporate Manslaughter and Corporate Homicide Act 2007 The Association of Independent Chimney Sweeps’ Code of Practise Control of Substances Hazardous to Health Regulations 2002 Control of Asbestos Regulations (CAR) 2012 Provision and Use of Work Equipment Regulations 1998 The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (2013) (RIDDOR) HETAS guidance (solid fuel systems) L122 Approved Code of Practice (ACOP) – Pressure Systems Safety Regulations The Gas Industry Unsafe Situations Procedures (GIUSP) Scottish Social Housing Charter (SHQS) Pressure Systems Safety Regulations 2000 The Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEARR) Construction, (Design and Management) Regulations 2015 The Workplace (Health, Safety and Welfare) Regulations 1992 Technical bulletins and industry safety alerts (Gas safe) The Corporate Manslaughter and Corporate Homicide Act 2007 L80: A Guide to the Gas Safety (Management) Regulations 1996 The Association of Independent Chimney Sweeps’ Code of Practise Control of Substances Hazardous to Health Regulations 2002 Control of Asbestos Regulations (CAR) 2012 Provision and Use of Work Equipment Regulations 1998 Page 173 of 204
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1 Housing Landlord Compliance Electrical Safety Policy Page 175 of 204
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Electrical Safety Policy 2 Contents 1. Introduction ....................................................................................... 4 2. Statement of Intent ............................................................................ 4 2.3.1 Testing of Fixed Wiring Systems ........................................................ 4 2.3.2 Portable Appliance Testing................................................................ 4 2.3.3 Powered Doors, Gates and Barriers ................................................... 5 2.3.4 Lightning Protection Systems ............................................................ 5 3. Policy .................................................................................................. 5 3.2 Process ............................................................................................... 5 3.3 Delivery .............................................................................................. 6 3.3.1 Fixed Wire Testing .............................................................................. 6 3.3.2 Portable Appliance Testing ............................................................... 7 3.3.3 Automated Doors, Gates and Barriers ............................................... 7 3.3.4 Lightning Protection Systems ............................................................ 7 3.3.5 Solar PV .............................................................................................. 8 3.4 Additional Safety Measures ............................................................... 8 3.5 Contractors Competency ................................................................... 8 3.6 Internal Competency ......................................................................... 8 Page 176 of 204
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Electrical Safety Policy 3 3.7 Data .................................................................................................... 9 3.8 Assurance ........................................................................................... 9 3.9 Communication ................................................................................. 9 4. Implementation ................................................................................. 9 5. Consultation .................................................................................... 10 6. Equality Analysis (EA) ....................................................................... 10 7. Monitoring Performance .................................................................. 10 8. Policy Review ................................................................................... 12 9. Amendment Log .............................................................................. 12 10. APPENDIX A ...................................................................................... 13 Page 177 of 204
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Electrical Safety Policy 4 1. Introduction 1.1 At the time of Policy approval Renfrewshire Council (Renfrewshire) owns and manages in the region of 12,200 residential properties for let. 1.2 Electrical installations and equipment within housing stock and communal areas managed by Renfrewshire need to be kept safe and regularly inspected and maintained. 1.3 This policy explains how Renfrewshire’s commitment to electrical safety will be met. It will be supported by an Electrical Safety Management Plan providing more detailed guidance and procedures. 1.4 It will also cover how Renfrewshire Council’s Director of Environment, Housing and Infrastructure as Duty Holder, will receive assurance of statutory legislative and regulatory compliance. 2. Statement of Intent 2.1 The key objective of this policy is to describe how Renfrewshire will meet the statutory, contractual and regulatory requirements in relation to electrical safety. 2.2 The scope of this policy includes:- fixed wire testing portable appliance testing automated doors, gates and barriers lightning protection systems. Solar PV 2.3 Renfrewshire will comply with all current and relevant legislation; specifically, as detailed in the following; 2.3.1 Testing of Fixed Wiring Systems The IET 18th Edition of the Wiring Regulations BS7671:2018+A2:2022 The Electricity at Work Regulations 1989 (EAWR) Building (Scotland) Regulations. 2.3.2 Portable Appliance Testing Section 2.2 of the Health & Safety at Work Act 1974 (HSWA) requires employers as far as is reasonably practicable to “provide and maintain plant and systems of work that are safe and without risk to health. Plant covers any machinery, equipment or appliances including portable appliances.” Page 178 of 204
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Electrical Safety Policy 5 2.3.3 Powered Doors, Gates and Barriers The Health and Safety at Work Act (1974) sections 3 and 4 place a duty to ensure the health and safety of users, so far as is reasonably practicable; Supply of Machinery (Safety) Regulations 2008 and BSEN 12453:2001 2.3.4 Lightning Protection Systems Detailed in BS EN 62305:3:2011: ‘Protection against Lightning – Physical damage to structures and life hazard’ and its subsequent amendments. Section 7 and E7 of the British Standard (BS EN 62305:3:2011) sets out the requirements for maintenance and inspections of lightning protection systems. 2.4 Renfrewshire Council also acknowledges its further obligations under the Acts, regulations and guidance noted in Appendix A. 2.5 In addition, Landlords and providers of Social Housing must meet the requirements of the Scottish Housing Regulator’s (SHR) Regulatory Standards. 2.6 It is essential to ensure customers, tenants, residents, employees, contractors and visitors remain safe in Renfrewshire premises (both individual homes and offices). Failure to properly discharge our legal responsibilities may result in: Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974 Prosecution under the Corporate Manslaughter and Corporate Homicide Act 2007 SHR’s scrutiny and potential determination of a breach of Regulatory Standards and serious detriment having been caused/potentially caused. Reputational damage Loss of confidence by stakeholders in the organisation 3. Policy 3.1 In order to comply with regulations, standards and guidance, and to ensure the safety of its customers, tenants, residents, employees, contractors and other visitors to our properties, Renfrewshire will: 3.2 Process I. Provide clear lines of responsibility for the management of fixed wiring systems; portable appliance testing; powered doors, gates and barriers; Page 179 of 204
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Electrical Safety Policy 6 lightning protection systems; and photovoltaic systems supported by written guidance in the Electrical Safety Management Plan. II. Ensure that a clear and consistent process including front-line engagement and enforcement is in place to obtain access to properties to undertake electrical safety checks, which shall include legal action when required. III. Assess available data for relevant information about the customer to help gain access (disability, vulnerability, local connections, etc.) IV. Maintain a process for dealing with defects in line with standards and guidance. 3.3 Delivery 3.3.1 Fixed Wire Testing I. Ensure all communal areas hold a valid Electrical Installation Condition Report (EICR) within the cycle specified by the competent person undertaking the test but, in any event, at intervals not exceeding 5 years. II. Ensure inspections and testing of fixed wiring systems within domestic properties takes place on a 5 year cycle (or sooner if recommended by the competent person undertaking the test). Hold a satisfactory EICR for all properties. III. Ensure all domestic electrical installations are tested and certified prior to letting. IV. If a property remains unoccupied for a period exceeding 12 months following its last test, a further EICR will be completed prior to occupation. Further EICRs will also be considered for properties unoccupied for less than 12 months should a risk of deterioration or damage to the fixed wiring electrics be identified. V. In addition to checking all installations maintained by Renfrewshire, inspect any electrical work carried out by the tenant at the same time. Any works found to be unsafe, or not complying with regulations will be disconnected and made safe appropriately at the time of inspection. VI. Certain tenant-own works will be allowed to be left in situ, such as light fixings and switches which have been appropriately installed and deemed safe for continued use by the competent person completing the inspection. Page 180 of 204
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Electrical Safety Policy 7 VII. Prioritise remedial works arising from fixed wire testing and apply a timescale for action, as detailed within the Electrical Safety Management Plan. VIII. All C1 (immediately dangerous) works will be made safe at the time of the inspection and testing. IX. All C1, C2 and FI (further investigation) works identified at the time of inspection and testing, should be completed in line with the ‘Urgent’ response repairs timescale. (30 days). X. A property will only be considered compliant once evidence and certification is provided that all C1 and C2 works are resolved. 3.3.2 Portable Appliance Testing I. Risk assess all appliances provided by Renfrewshire Housing which are used by employees, residents, customers, and visitors. II. Undertake Portable Appliance Testing (PAT) at a frequency arising from the risk assessed schedule as per the Code of Practice for In-service Inspection and Testing of Electrical Equipment. III. Renfrewshire will retain appropriate documentation. IV. Establish a cycle of subsequent re-testing at the time of the first test. 3.3.3 Automated Doors, Gates and Barriers I. Detail the frequency of inspections and procedures within the Electrical Safety Management Plan, but as a minimum this will be on an annual basis. II. Renfrewshire will retain appropriate documentation. 3.3.4 Lightning Protection Systems I. Carry out inspection and testing on an 11-month rolling basis to ensure that inspection and testing under different climatic conditions. II. Renfrewshire will retain appropriate documentation. Page 181 of 204
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Electrical Safety Policy 8 3.3.5 Solar PV I. Check systems annually in accordance with the Electrical Safety Management Plan. II. Renfrewshire will retain appropriate documentation. 3.4 Additional Safety Measures I. Require that tenant installations should be subject to prior agreement before works are undertaken. II. Any unauthorised installations deemed to be unsafe will be disconnected and remedial works, where required, will be carried out at the tenant’s own expense and by Renfrewshire’s appointed contractor. 3.5 Contractors Competency I. Only engage with suitably qualified electrical contractors to undertake work on electrical installations. (The National Inspection Council Electrical Installation Contractors (NICEIC) or equivalent.) II. Expect that contractors shall demonstrate that all engineers engaged in work for Renfrewshire shall meet the required standard of training. III. Only engage with suitably qualified and competent lightning protection systems specialist contractors to undertake work on lightning protection systems and shall be a member of ATLAS (The Association of Technical Lightning & Access Specialists). IV. Require a Microgeneration Certification Scheme (MCS) accreditation for those engaged with solar photovoltaic systems. V. Carry out an assessment of all contractor competencies as detailed within the Electrical Safety Management Plan. Our in-house service provider, Building Services, who carry out the majority of our domestic EICRs are responsible for ensuring that staff have appropriate training. 3.6 Internal Competency I. Maintain a skills/training matrix, through the Individual Development Plan (IDP) process, to ensure that all staff undertaking key roles within the scope of this policy have appropriate training. Page 182 of 204
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Electrical Safety Policy 9 3.7 Data I. Maintain up to date records of all properties where they have a responsibility to provide electrical safety checks and maintenance, including testing of fixed wiring systems, portable appliances, powered doors, gates and barriers, lightning protection systems and photovoltaic systems. II. Where a requirement exists hold data and certification relating to the last two EICRs and record the next due date III. Maintain current and up to date records of remedial works for all properties which will detail all recommendations from the fixed wire testing. IV. The records will include; address and risk profile of the property, detail of the work item required, priority and target completion, person responsible, when the work was completed, who it was signed off by and evidence of completion 3.8 Assurance I. Ensure that all persons involved with the installation, inspection and servicing of electrical systems and appliances are properly trained and accredited. II. Carry out works-based assurance activities including checks on certification and post-inspection of onsite works to the level stated within the Electrical Safety Management Plan. A proportion of such checks will be carried out by an independent party. III. Set a timetable for the review of the Electrical Safety Policy and the associated Electrical Safety Management Plan. 3.9 Communication I. Encourage customers, through the provision of publicity information, to allow access to carry out EICRs, other safety checks and inspections and remedial works. 4. Implementation 4.1 The policy and any revisions will be effective from the date of approval by Communities and Housing Policy Board. Page 183 of 204
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Electrical Safety Policy 10 4.2 Staff will be made aware of the policy through appropriate training and a copy will be available on Renfrewshire’s intranet. The policy will be uploaded to the Renfrewshire Council web site. 4.3 This policy should also be read in conjunction with the Housing Landlord Compliance Strategy and Electrical Safety Management Plan. 4.4 Appropriate training will be provided for all those staff involved with the operational delivery and implementation of the Housing Landlord Compliance requirements and obligations in respect of Electrical Safety detailed within this Policy. 5. Consultation 5.1 This policy is based on statutory, legislative and regulatory requirements and, therefore, consultation with customers has not taken place. There has been consultation with Internal Teams within Renfrewshire. 6. Equality Analysis (EA) 6.1 We believe all people should be treated with dignity and respect regardless of their Age, Disability, Gender Gender reassignment, Race, Religion and belief, Pregnancy and maternity Marriage and civil partnership Sexual orientation by association with someone with any of these characteristics or perception of having any of these characteristics. 6.2 An Equalities Impact Assessment was undertaken to identify the likely or actual effects of this policy. This includes identifying where there will be a positive impact and further opportunities to further promote equality. Where there are any potential negative impacts identified, we have identified actions required to eliminate or mitigate these negative impacts. 7. Monitoring Performance 7.1 The following Key Performance Indicators (KPIs) will be reported: Page 184 of 204
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Electrical Safety Policy 11 % of Domestic Properties having a valid Electrical Installation Condition Report (EICR) within the cycle No of domestic properties with outstanding C1 or C2 works % of Portable Appliance Testing (PAT) completed within required date % of automated doors risk assessed /serviced within required date % of automated gates and barriers risk assessed /serviced within required date % of Lightning Conductors inspected and tested within required date. % of Communal Areas / Commercial Properties having a valid Electrical Installation Condition Report (EICR) within the cycle No of Communal Areas/Commercial Properties with outstanding C1 and C2 works 7.2 Satisfactory reports shall mean that all immediately and/or potentially dangerous faults have been resolved. 7.3 Commentary will be provided for any properties out of date to include the date they became overdue, days overdue, and their position within the access legal process to bring them back into a compliant position. 7.4 Commentary will also be provided if any properties have outstanding overdue actions. 7.5 Additional context commentary will also include information on the proportion of activities within the reporting period that were undertaken before and after their due date. 7.6 A detailed Performance Indicator (PI) suite will be defined within the Management Plan. 7.7 The following assurance activity will be undertaken and reported in line with the Management Plan: Internal audit Strategic review 3rd Party Assurance Page 185 of 204
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Electrical Safety Policy 12 8. Policy Review 8.1 The policy will be reviewed every 36 months or earlier if deemed necessary though the performance monitoring process. 9. Amendment Log Date of revision: Record of amendments: Reason for revision: 11.11.24 Changes recorded and held on file Updated legislation, changes in Council Department names, updates to processes. 4.02.25 Changes recorded and held on file Feedback from SHSN – minor changes Page 186 of 204
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Electrical Safety Policy 13 10. APPENDIX A List of further legislation and regulations The Health and Safety at Work etc. Act 1974, The Housing (Scotland) Act 2010 and The Housing (Scotland) Act 2014. The Management of Health and Safety at Work Regulations 1999 Guidance note 3 (inspection and testing) The Electrical Equipment (Safety) Regulations 2016 The Scottish Social Housing Charter The Tolerable Standard Building Standards (Scotland) Regulations 2014 Corporate Manslaughter and Corporate Homicide Act 2007. Scottish Government - Building Standards. Technical Handbook 2009 Domestic Environment Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR 2013) The Workplace (Health, Safety & Welfare) Regulations 1992 Health and Safety (Safety Signs and Signals) Regulations 1996 Provision and Use of Work Equipment Regulations 1998 Construction, (Design and Management) Regulations 2015 Personal Protective Equipment Regulations 1992 The Code of Practice for In-Service Inspection and Testing of Electrical Equipment (ISITEE) INDG236: ‘Maintaining portable electrical equipment in offices and other low risk environments’ ‘Landlords’ Guide to Electrical Safety Scotland 2017’. HSR25 The Electricity at Work Regulations 1989, Guidance on the regulations. IET Guidance Notes 1-8 Electricity at work – Safe working practices HSG85 Keeping electrical switchgear safe HSG230 Maintaining portable and transporting electrical equipment HSG107 Avoiding dangers from underground services HSG47 The IET Code of Practice for in service inspection and testing 2013 Page 187 of 204
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15 Environment, Housing and Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR Page 188 of 204
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 ___________________________________________________________________ Report by: Director of Environment, Housing & Infrastructure ___________________________________________________________________ Heading: Creating a smokefree generation and tackling youth vaping – Enforcement of the Environmental Protection (Single-Use Vapes) (Scotland) Regulations 2024 ___________________________________________________________________ 1. Summary 1.1 In late 2023, the Department of Health & Social Care (DHSC) completed an open consultation on the proposed actions the UK Government and devolved administrations were considering to tackle smoking and youth vaping. The Renfrewshire Council response was homologated at this Board on 16 January 2024. 1.2 This consultation exercise gathered views on proposals to protect future generations from the harms of tobacco, by creating the first “smokefree” generation. The consultation also proposed measures to tackle the growing problem of the use of Nicotine Vapour Products (NVPs, e-cigarettes or “vapes”) by young persons. These measures included the restriction of flavours, the regulation of point-of-sale displays, a restriction of the sale/supply of single-use vapes, or the extension of controls to non-nicotine vapes. 1.3 On 18 September 2024, the Scottish Parliament approved the first of a suite of planned legislative controls in this area. The Environmental Protection (Single-Use Vapes) (Scotland) Regulations 2024 (SUV Regulations) will prohibit the sale and supply of single-use vapes in Scotland. These Regulations were made under the Environmental Protection Act 1990, which permits the introduction of regulations thereunder by devolved Parliaments. 1.4 Vapes are considered re-usable if they are both refillable and rechargeable. If products are only one or the other, they will be considered single-use vapes, and therefore prohibited for sale or supply by these Regulations. Item 8 CHPB110325 Page 189 of 204
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1.5 Draft Amendment Regulations (Injurious Articles Regulations), proposed to come into force on 31 March 2025, will align the commencement date with the rest of the UK; meaning that the controls are implemented across the UK from 1 June 2025. 1.6 The SUV Regulations do not impose a statutory duty on the Local Authority; instead offering that the Local Authority “may” enforce the provisions within their area. In addition, it is for the Local Authority to determine which service is best placed to take forward these provisions in their area. It is also important to note that there is no funding package currently offered to support these new and additional duties. 1.7 It is proposed that the legislation is adopted and delegated to Officers in Climate & Public Protection; primarily to be utilised by Officers in the Trading Standards & Licensing team. These powers will supplement those already available to the Team and will likely only require to be utilised where all other attempts to secure compliance have failed. ___________________________________________________________________ 2. Recommendations 2.1 It is recommended that the Board: (a) notes the progress made to date towards a Smokefree Future, and a ban on the sale or supply of single-use vaping products, (b) agrees to adopt the powers included in the Environmental Protection (Single-Use Vapes)(Scotland) Regulations 2024 (as amended), and notes that since the Regulations have been introduced under the Environmental Protection Act 1990, implementation of the Regulations is already delegated to the relevant officers within in the Scheme of Delegated Functions, (c) notes that a number of future papers are expected on this subject, as increasing legislative controls are proposed. _________________________________________________________ 3. Background 3.1 Smoking is the single-most preventable cause of ill health, disability, and death in the UK. It is responsible for around 80,000 deaths a year, including 8,300 deaths per year in Scotland. No other consumer product kills up to two- thirds of its users. In 2022, the Office for National Statistics reported that 6.4 million people in the UK were active smokers. This represented 12.9% of the UK population, and 13.9% of the population of Scotland. 3.2 While existing legislative controls have reduced the uptake of tobacco use in younger persons, the use of Nicotine Vapour Products (NVPs, e-cigarettes or “vapes”) has grown at a concerning rate. Action on Smoking and Health (ASH) report that the number of children using vapes has tripled in the past three years, and that 20.5% of children in Great Britain had tried vaping in 2023. Page 190 of 204
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3.3 In Renfrewshire, there are around 290 businesses currently registered for the sale of tobacco, or NVPs, or both. Businesses must register with Scottish Government to sell these products, and compliance with this requirement along with other regulatory controls is enforced by officers in Trading Standards. 3.4 In late 2023, the Department of Health & Social Care (DHSC) completed an open consultation on the on the proposed actions the UK Government and devolved administrations were considering to tackle smoking and youth vaping. This consultation sought views on proposals to protect future generations from the harms of tobacco, by creating the first “smokefree” generation. To progress this; legislation will be passed to ensure that people born on or after 1 January 2009 will never legally be able to be sold tobacco products. In effect, this raises the smoking age by a year - each year - until this restriction applies to the whole population. The Tobacco & Vapes Bill is at Committee Stage in the House of Commons and any future consultation responses will be brought to this Board for approval. Enforcement of the age restriction is likely to be a statutory duty; again intended for deployment to Trading Standards. 3.5 In September 2024, the Scottish Parliament approved the first of a suite of planned legislative controls in this area. The Environmental Protection (Single-Use Vapes) (Scotland) Regulations 2024 (SUV Regulations) will prohibit the sale and supply of single-use vapes in Scotland. Vapes are considered re-usable if they are both refillable and rechargeable. If products are only one or the other, they will be considered single-use vapes, and therefore prohibited for sale or supply by these Regulations. 3.6 Single-use vapes are an inefficient use of critical resources (such as lithium batteries), and are often discarded as litter or thrown into general waste. Littering spoils our communities, introduces harmful substances into the soil, rivers and streams, and causes harm to biodiversity. When single-use vapes are thrown into general waste they often end up in landfill or are incinerated, which means critical resources are lost. Lithium batteries can also cause fires, which risk the safety of waste management workers, firefighters and the public. 3.7 Draft Amendment Regulations (Injurious Articles Regulations); proposed to come into force on 31 March 2025, seek to afford Enforcement Officers a power to issue Fixed Penalty Notices for breaches of the SUV Regulations. A further paper will be brought to Board to outline these new powers in due course; should the proposal to adopt the SUV Regulations be accepted. 3.8 Officers in Public Protection adopt a graduated approach to enforcement of their statutory functions – referring both to the formal Integrated Enforcement Policy, and the informal “Four E’s” approach utilised during the pandemic. This model sees enforcers Engaging with traders, Explaining the requirements, Encouraging compliance and finally, Enforcing only where required. This model tends to achieve a high rate of compliance, balanced also with the best use of available resources. Page 191 of 204
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3.9 The fast-changing landscape in this sector is likely to place a significant burden both on retailers and our enforcement officers. Specifically, retailers and officers will need to work together to understand and implement the changes, as well as responding to consultations on proposals for increasing controls on NVPs (for instance, flavouring bans, or new registration requirements). This will be very challenging to resource effectively if no funding package is provided by Scottish Government. 3.10 Reports on progress will be brought to this Board as part of the Service Update report, to allow for effective oversight. ___________________________________________________________________ Implications of the Report 1. Financial – unknown at the current time. 2. HR & Organisational Development – unknown at the current time. 3. Community/Council Planning – • Our Renfrewshire is thriving – regulation of this sector will ensure that retailers maintain high standards, are effectively regulated and will reduce the negative impacts on legitimate businesses from non-compliant retailers. • Our Renfrewshire is well – the proposal for a smokefree future will reduce preventable deaths in Renfrewshire by around 650 per year. There will also be a significant reduction in demand for associated health services. • Creating a sustainable Renfrewshire for all to enjoy – the potential for a ban, restriction of these products and/or requirement to recycle single-use vaping products supports the circular economy; placing an emphasis on minimising waste and maximising reuse, recycling and recovery of resources rather than treating them as waste. 4. Legal – this legislation is introduced under the Environmental Protection Act 1990 which is already delegated to Officers within Climate & Public Protection in the Scheme of Delegated Functions. These Regulations do not impose a statutory duty to enforce; however the environmental and public health issues are of such concern that it would be beneficial to adopt these powers, while noting the resourcing constraints. 5. Property/Assets – None. 6. Information Technology – None. 7. Equality & Human Rights – (a) The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. Page 192 of 204
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If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – None. 9. Procurement – None. 10. Risk – None. 11. Privacy Impact – None. 12. COSLA Policy Position – N/A. 13. Climate Risk – The proposals offer an opportunity to significantly reduce the climate risk posed by these products. These single-use products use lithium parts, highlighted by environmental campaigners as a ‘critical material’ in the transition to net zero. Within a Renfrewshire context, one of the five Plan for Net Zero themes is circular economy, placing an emphasis on ‘minimising waste and maximising reuse, recycling and recovery of resources rather than treating them as waste.’ 14. Children’s Rights – None. _________________________________________________________ List of Background Papers (a) Background Papers – Report to Communities & Housing Policy Board on 16 January 2024 titled Creating a smokefree generation and tackling youth vaping – a consultation by the Department of Health & Social Care ___________________________________________________________________ Author: Faye Wilson, Serious Organised Crime & Trading Standards Manager Email: faye.wilson@renfrewshire.gov.uk Page 193 of 204
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 ___________________________________________________________________ Report by: Director of Environment, Housing and Infrastructure ___________________________________________________________________ Heading: Consultation on the Regulation of non-surgical cosmetic procedures ___________________________________________________________________ 1. Summary 1.1 The number of non-surgical cosmetic procedures being carried out across Scotland and throughout the UK has risen considerably over recent years. 1.2 Non-surgical cosmetic procedures are a range of procedures carried out with the intention of enhancing or altering a person’s physical appearance without surgical interventions. For the purposes of this report, these are defined to include procedures that penetrate the skin, either through a needle or blade, or that involve penetrating chemicals, radiation, sound, or light. Examples include: microneedling, laser tattoo removal, Botox, dermal fillers, buttock, breast, and nose augmentation, etc. 1.3 With the growth of this industry, there are increasing concerns regarding safety and the risk of harm from non-surgical cosmetic procedures. Although not exclusively, there are concerns regarding procedures being undertaken out with traditional healthcare settings. 1.4 A public consultation was launched by the Scottish Government on 20 December 2024 and closed on 14 February 2025. It seeks to establish how best to further regulate non-surgical cosmetic procedures to reduce the potential for harm to those choosing to take up such procedures. They are proposing a model of regulation which protects the public while being proportionate and seek to provide a framework where potential clients can undergo procedures with confidence and where responsible, suitably trained, and qualified providers can continue offering them. Item 9 CHPB110325 Page 195 of 204
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___________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 notes the consultation proposals, and agree to homologate the response, as detailed within Appendix A, and 2.2 notes that a further report will be brought to a future meeting of this Policy Board, when the legal requirements have been established with an update on implications for the Council and the Service. ______________________________________________________ 3. Background 3.1 Over recent years, there has been a rise in the number of people undergoing non-surgical cosmetic treatments throughout Scotland and the UK. 3.2 Independent healthcare clinics in Scotland are regulated by Healthcare Improvement Scotland (HIS) and any non-surgical cosmetic procedures taking place in these settings are subject to certain hygiene and safety standards. However, the sector is not yet fully regulated, meaning that anyone can perform procedures, without the need for any formal training or qualifications. 3.3 Whilst there are many reputable practitioners, a significant number of businesses operate in non-healthcare settings with procedures being undertaken by poorly trained, untrained, or unqualified staff. In addition, there are concerns regarding the use of uncontrolled, unapproved and unlicensed products for these procedures which presents a significant risk of injury or harm to members of the public. 3.4 This consultation proposes an approach to introduce more regulation to this sector and considers the existing regimes of: HIS regulation of independent healthcare; regulation of healthcare professionals, licensing and regulation of medicines and medical devices; and licensing of procedures including tattooing and ear piercing by local authorities. 3.5 The existing regimes are a mix of devolved and reserved matters. The regulation of medicines and medical devices and the regulation of certain professions are reserved to the UK government and as such these proposals cannot make any changes to them. HIS regulation of independent healthcare services and the existing licencing regime for tattooing and skin piercing are devolved to the Scottish Government, but while it may be possible to change the existing regimes, the proposal outlines the importance to ensure that no changes are made that undermine the effectiveness and proportionality of the existing schemes as they already apply. Page 196 of 204
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3.6 The main proposals in this consultation are that: private non-surgical cosmetic procedures should only take place in either an independent clinic or other healthcare setting regulated by Healthcare Improvement Scotland, or in a business premises that is licenced by a local authority. The type of treatments undertaken by a business will determine the competent regulatory body. 3.7 Wherever a procedure takes place, it is proposed to establish standards, unless these are already established by virtue of the existing HIS regime for training and qualifications, insurance and indemnity, premises hygiene and equipment and materials such as disposable needles and consumable products used in the procedures. 3.8 The consultation lists 3 groups of procedures with the least invasive lower risk procedures (group 1) being proposed for premises and practitioners licensed by the local authority. Higher risk procedures in group 2, would be required to be delivered by or under the supervision of a health care professional in an HIS regulated premises and the most invasive, highest risk procedures in group 3, will also be reserved for HIS regulated settings, and carried out by an appropriate healthcare professional. It should be noted that group 1 procedures could also be carried out in these HIS regulated settings. 3.9 The proposed model builds on existing provision for tattoo parlours and skin piercing establishments which are subject to licencing under the Civic Government (Scotland) Act 1982 (licencing of skin piercing and tattooing) order 2006. The existing order does not specify that both premises and practitioners’ licences are required for these procedures and practice currently varies between local authorities. Some require premises only licences and some require premises and practitioner licences. Within Renfrewshire the person operating the business holds the licence. 3.10 It is proposed that the practitioner licence will list the procedures the practitioner is qualified to undertake. In obtaining the licence the practitioner will be required to demonstrate that they have met an agreed standard of training, commensurate with the procedure being carried out. It would also be a condition of the licence that practitioners either hold appropriate insurance or that any procedures they undertake are insured through the premises they are operating in. 3.11 The consultation also considers age restrictions for these types of procedure. It is proposed that there is an age limit determined by procedure or placing conditions which ensure that age restrictions are put in place and all procedures within the restricted age group are defined as class 3. 3.12 The proposed regulation of non-surgical cosmetic procedures are generally supported by Officers, however, it is recognised that no additional resource is proposed to deliver its implementation. This is likely to have an impact on Officer workload, in addition to specialised training in this regulatory sector being required. Page 197 of 204
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3.13 The consultation response on behalf of Renfrewshire Council is attached in Appendix A. __________________________________________________________________ Implications of the Report 1. Financial – None. 2. HR & Organisational Development – The new legislation will require to be enforced by Environmental Health staff. Whilst recognised as an important role in the wider public health remit, this will create additional work for officers. In addition, officers will require additional professional training. 3. Community/Council Planning – Our Renfrewshire is thriving – Environmental Health staff aim to support businesses with any changes to minimise effects on economic growth. Our Renfrewshire is well – This consultation supports Renfrewshire Council’s aim to support the wellness and resilience of our citizens by working to ensure that our citizens are not at significant harm or risk. 4. Legal- None. 5. Property/Assets – None. 6. Information Technology – None. 7. Equality & Human Rights – (a) The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report because for example it is for noting only. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – None. 9. Procurement – None. 10. Risk – None. 11. Privacy Impact – None. 12. COSLA Policy Position – None. Page 198 of 204
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13. Children’s Rights- None. 14. Climate Risk – None. _________________________________________________________ List of Background Papers (a) Background Paper Regulation of non-surgical cosmetic procedures - Scottish Government consultations - Citizen Space The foregoing background papers will be retained within (Environment, Housing and Infrastructure) for inspection by the public for the prescribed period of four years from the date of the meeting. The contact officer within the service is (Gwyneth Heaney, Senior Manager, Climate & Public Protection, Environment, Housing and Infrastructure. Tel: 0141 487 1205 Email: gwyneth.heaney@renfrewshire.gov.uk) (b) The inclusion of background papers is based on a legislative requirement. Background papers are those which the officer responsible for the report considers contain information upon which the report was based and which that officer has relied upon to a material extent in preparing the report. The only things which are exempted are published works and documents which contain exempt information or confidential information. The officer responsible for the report must prepare a list of background papers. That list and a copy of all the documents on the list then requires to be kept open for inspection by the public for a period of four years from the date of the meeting. ___________________________________________________________________ Author: Robert Marshall, Environmental Health Manager (Business Regulation) Email: colin.hunter@renfrewshire.gov.uk Page 199 of 204
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Response ID ANON-W21S-ZPA3-B Submitted to Regulation of non-surgical cosmetic procedures Submitted on 2025-01-23 15:23:01 Questions about the grouping of procedures 1 Proposed Group 1 procedures Group 1 Procedures - Microneedling: Should be undertaken in either a licensed premises or in a HIS regulated setting (Group 1) Group 1 Procedures - Chemical peels that only affect the outermost level of skin: Should be undertaken in either a licensed premises or in a HIS regulated setting (Group 1) Group 1 Procedures - IPL/LED therapy: Should be undertaken in either a licensed premises or in a HIS regulated setting (Group 1) Group 1 Procedures - Use of lasers for tattoo removal: Should be undertaken in either a licensed premises or in a HIS regulated setting (Group 1) Group 1 Procedures - Laser hair removal: Should be undertaken in either a licensed premises or in a HIS regulated setting (Group 1) 2 Proposed Group 2 procedures Group 2 procedures - Mesotherapy (injection of certain drugs, or other products into the middle layer of the skin): Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Injections of toxins (e.g. Botox®) for cosmetic purposes: Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Injections of drugs for cosmetic purposes: Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Injections of semi permanent dermal fillers in small quantities (<2ml - e.g. to reduce wrinkles, or plump lips): Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Any other injections of a product, even if it is not a drug or toxin, for lifestyle or cosmetic purposes. (not including tattooing which is already licenced): Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Medium depth peels (that penetrate and destroy the outer layer of skin fully and penetrate into the next layer or upper dermis): Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Photo rejuvenation: Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Radiofrequency treatments: Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - HIFU (high frequency ultrasound): Should only be undertaken in a HIS regulated setting (Group 2) Group 2 procedures - Cryolipolisis (the use of cold to destroy pockets of fat under the skin): Should only be undertaken in a HIS regulated setting (Group 2) 3 Proposed Group 3 Procedures Group 3 procedures - Platelet rich plasma, biotherapy or injections of any products derived from the patient’s blood: Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Injection microsclerotherapy (use of injections to treat visible spider veins): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Injection lipolysis or injections of fat dissolving agents: Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Dermal micro coring (removal of small amounts of skin to reduce visible signs of aging): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Appendix 1 Page 200 of 204
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Group 3 procedures - Hay fever injections: Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Any procedure involving intravenous fluids or drawing and processing bloods for cosmetic or lifestyle purposes, for instance provision of intra venous vitamins and minerals, or intra venous blood oxygenation.: Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Use of dermal fillers for the purpose of augmentation of e.g. the breasts and buttocks: Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Deeper chemical peels such as phenol peels: Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - All laser treatments not specified above, including lasers which target the deeper layers of the dermis.: Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Carboxytherapy (the injection of CO2 under the skin to promote collagen production): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Cellulite subcision (making small incisions to reduce appearance of cellulite): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Electrocautery (removal of skin tags through electricity): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Cryotherapy and cryocautery (use of extreme cold to remove e.g. skin tags): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - Thread lifting and cogs (placement of dissolvable material under skin to tighten appearance and promote collagen): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) Group 3 procedures - All group 1 or 2 procedures where procedures are carried out in an intimate area (except hair removal and not including procedures such as tattooing and skin piercing which are already licenced): Should be undertaken in a HIS regulated setting by an appropriate healthcare professional (Group 3) 4 Please provide any comments you have in relation to the grouping of procedures and the level of regulation required: Please give us your views: Renfrewshire Council agrees with the groupings as set out in the consultation. Questions about the proposed licensing regime 5 Do you support or oppose the proposal that the practitioner of a Group 1 procedure operating in a licensed premises should also require a licence? Strongly support 6 Do you support or oppose the proposal that the practitioner of a Group 1 procedure operating in a HIS regulated setting should not require a licence? Neutral 7 Please provide any comments about the answers you have given to questions 5 and 6 about the proposals for the establishment of licensing arrangements for Group 1 procedures: Please give us your views: 8 To what extent do you agree or disagree that the Scottish Government should establish: Standards for Licenced premises - Standards of hygiene and health and safety for licensed premises?: Strongly Agree Standards for Licenced premises - Standards of training and qualification for licensed practitioners?: Strongly Agree Standards for Licenced premises - Mandatory insurance and indemnity to compensate clients who suffer harm as a result of negligence or malpractice?: Strongly Agree 9 To what extent do you agree or disagree that local authority officers should have powers of inspection and enforcement, including: Page 201 of 204
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Enforcement & Inspection powers for Local Authorities - The removing of a licence from premises or practitioners who cannot demonstrate compliance with standards established by the Scottish Government?: Strongly Agree Enforcement & Inspection powers for Local Authorities - Barring individuals from holding a licence if they are associated with serious or repeated non-compliance with the standards established by the Scottish Government?: Strongly Agree 10 Which of the following statements do you agree with in relation to whether a vehicle can receive a licence as a premises? (Pick one) Vehicles should be eligible for a licence in all local authorities Questions about the restriction of procedures to a HIS regulated setting 11 To what extent do you agree or disagree that the Scottish Government should establish: Standards of training and insurance for non-healthcare professionals - Standards of training and qualification for non-healthcare and healthcare professionals undertaking procedures in HIS regulated services?: Strongly Agree Standards of training and insurance for non-healthcare professionals - Mandatory insurance and indemnity to compensate clients who suffer harm as a result of negligence or malpractice?: Strongly Agree 12 Do you agree or disagree that the healthcare professional supervising a group 2 procedure should: Supervising healthcare professional - Conduct the / any initial consultation(s) with the client?: Agree Supervising healthcare professional - Prescribe any medications (e.g. Botox TM, lidocaine) required during the procedure, or required for the management of any complications that arise?: Agree Supervising healthcare professional - Remain available on site for the duration of any procedure?: Agree Supervising healthcare professional - Be responsible for ensuring the practitioner is suitably trained for the procedure?: Agree Supervising healthcare professional - Be responsible for ensuring the procedure will be undertaken safely?: Agree Supervising healthcare professional - Be themselves suitably trained and qualified in the procedure being undertaken?: Agree 13 Thinking about the healthcare professional undertaking a group 3 procedure, which statement below do you agree with: These procedures should be undertaken by a suitably trained and qualified healthcare professional working within their scope of practice, but not otherwise be limited. 14 If your answer to the last question was that these procedures should only be undertaken by certain healthcare professionals, please tick all the healthcare professionals to which they should apply: 15 Do you agree or disagree that the following settings should be required to register with Healthcare Improvement Scotland if they are offering non-surgical cosmetic procedures? Healthcare settings - HIS registration - GP practices: Agree Healthcare settings - HIS registration - Dental practices: Agree Healthcare settings - HIS registration - Community pharmacies: Agree 16 Do you agree or disagree that Healthcare Improvement Scotland should have powers of inspection, including powers of entry and inspection of unregistered settings where there is reason to believe registration is required? Agree Page 202 of 204
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Questions about age restrictions 17 Which of the following statements is closest to your view? (please select only one option) There should be a lower age limit under which clients should not be allowed to undertake an NSCPs (different ages are considered in Question 18) 18 Regardless of your answer to question 17, if an age limit is to be put in place please indicate for each procedure group what you think is the appropriate age to be set for the procedures in that group. Preferred Age Limit - Procedure Group 1: Limited to clients aged 18 and over Preferred Age Limit - Procedure Group 2: Limited to clients aged 18 and over Preferred Age Limit - Procedure Group 3: Limited to clients aged 18 and over 19 Do you agree or disagree that procedures on intimate areas should only be available to clients of 18 years of age and over? Agree Questions about equalities, Fairer Scotland duty, impact on island communities and UNCRC 20 What are your views on how, if at all, the introduction of licensing and regulation of the non‑surgical cosmetics sector in Scotland might affect anyone based on their protected characteristics? Please give us your views.: Renfrewshire Council do not believe that the introduction of licencing and regulation will have any detrimental effect on anyone based on their protected characteristics. 21 What are your views on how the introduction of licensing and regulation of the non‑surgical cosmetics sector in Scotland might affect people differently based on their financial situation? Please give us your views.: Renfrewshire council do not believe that the introduction of licensing and regulation of the non‑surgical cosmetics sector in Scotland will affect people differently based on their financial situation. 22 What are your views on how the introduction of licensing and regulation of the non‑surgical cosmetics sector in Scotland might affect access to safe, high‑quality services in island communities? Please give us your views.: 23 What are your views on how the introduction of licensing and regulation of the non‑surgical cosmetics sector in Scotland and the potential of age restrictions might affect respecting, protecting and fulfilling the rights of children and young people as set out in the UN Convention on the Rights of the Child? Please give us your views.: Renfrewshire Council do not believe that the introduction of licensing and regulation of this sector will affect respecting, protecting and fulfilling the rights of children and young people as set out in the UN Convention on the Rights of the Child. About you 24 What is your name? Name: Robert Marshall 25 Are you responding as an individual or an organisation? Organisation 26 What is your organisation? Organisation: Renfrewshire Council Page 203 of 204
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27 Further information about your organisation's response Please add any additional context: It is recognised that the introduction of licensing and regulation of the non‑surgical cosmetics sector in Scotland may add additional burdens to local authorities. The impact in this regard must be considered and sufficient resource made available. Any licensing scheme should ensure consistency throughout Scotland with training and guidance being made available to officers. In addition, any licensing fees should ensure cost recovery for the services involved is achieved. 28 Further information about your connection to the non-surgical cosmetic procedures sector I am not involved in the non-surgical cosmetics sector 29 The Scottish Government would like your permission to publish your consultation response. Please indicate your publishing preference: Publish response only (without name) 30 Do you consent to Scottish Government contacting you again in relation to this consultation exercise? Yes 31 What is your email address? Email: robert.marshall@renfrewshire.gov.uk 32 I confirm that I have read the privacy policy and consent to the data I provide being used as set out in the policy. I consent Evaluation 33 Please help us improve our consultations by answering the questions below. (Responses to the evaluation will not be published.) Matrix 1 - How satisfied were you with this consultation?: Very satisfied Please enter comments here.: Matrix 1 - How would you rate your satisfaction with using this platform (Citizen Space) to respond to this consultation?: Very satisfied Please enter comments here.: Page 204 of 204