Corporate Plan 2019-2022 - Restated - August 2020

Welcome

In late March 2020, the UK and Scottish Governments escalated the national response to the Coronavirus (COVID-19) pandemic and introduced measures to limit the spread of virus.  These measures had a significant and immediate impact on social landlords’ delivery of services to tenants, people who are homeless, and others who use their services.

On 18 March we announced that, recognising the unprecedented circumstances that social landlords are facing as a consequence of the pandemic, we were aligning our regulatory approach to these new circumstances.  We have moved our focus to monitor the impact of the pandemic on social landlords, helped to establish the Social Housing Resilience Group, as a forum to coordinate the sector’s response to the pandemic, and supported landlords with Coronavirus-related advice.

Given the profound impact on tenants, people who are homeless and on social landlords of the national response to the pandemic, and the adjustments we have made to our regulatory approach, we have reviewed our plans for the period to March 2022.  This Plan supersedes the Plan we published in April 2019.

In this restated Corporate Plan we set out what we will do and how we will use our resources in the period to March 2022. We remain committed to safeguarding and promoting the interests of tenants, people who are homeless, and others who use services provided by social landlords.  We believe that our approach to regulation and the priorities we set in this Plan can support social landlords to respond to, and recover from, the pandemic. 

We will continue working closely with all our stakeholders to support the recovery in social housing and deliver shared goals. And we look forward to working with all of our people in SHR to deliver this plan.

George Walker, Chair and Michael Cameron, Chief Executive 

Our objective, priorities & vision

Our Statutory Objective

To safeguard and promote the interests of current and future tenants of social landlords, people who are or may become homeless, and people who use housing services provided by registered social landlords (RSLs) and local authorities.

Tenants and our other stakeholders helped us form our priorities that we will focus on over the next three years. 

We will achieve our objective & priorities by:

• promoting a strong tenant voice
• supporting landlords to do the right things for their tenants, people who are homeless and other service users
• taking effective, proportionate action where we need to protect tenants and others

Our work will help to maintain lenders’ and funders’ confidence in social housing. 

Our priorities 

• Governance and Financial Health in RSLs 
• Embedding our regulatory Framework 
• Tenant and Resident Safety 
• Value for money 
• Affordable rents and homelessness 

Our vision 

Well-run social landlords delivering what tenants, people who are homeless, Gypsy/Travellers and others who use social housing services need and want, and at a price they can afford to pay.

What we will do 2019-22

Embed our new Regulatory Framework

Our new Regulatory Framework and associated statutory guidance went live on 1 April 2019.  During 2019/20, we had focussed on supporting landlords to embed the new Framework. From March 2020 that shifted in response to the pandemic. 

2019/20

• Implement new Framework
• Publish engagement plans for all landlords
• Support landlords to submit their first Annual Assurance Statements
• Provide feedback on first Annual Assurance Statements

2020/21

•  Start to publish a regulatory status for all RSLs
• Align our regulatory approach to respond to the impact of the Coronavirus pandemic

2021/22 (Subject to easing of pandemic-related restrictions)

• Start to assess equalities duties
• Thematic work and advisory guidance
• Start visits to RSLs and Local Authorities to inform risk assessments

We will regulate against our priorities by:

• Supporting the recovery in social housing from the impact of Coronavirus
• Empowering tenants and others
• Getting assurance from landlords
• Taking action when we need to
• Carrying out thematic work
• Promoting equality & human rights

Supporting the recovery in social housing from the impact of Coronavirus

We will align our regulatory approach to the Coronavirus (COVID-19) pandemic and the national response to it by:

• postponing the publication of updated Engagement Plans planned for 31 March 2020 for all landlords other than for the most critical cases;
• postponing all but the most critical regulatory engagements to allow landlords and us to focus on the most serious existing risks or those that emerge from the current pandemic;
• extending the timescales for all landlords to submit the Annual Return on the Charter and for RSLs to submit the Five Year Financial Projections, Audited Financial Statement and Loan Portfolio Returns:
• providing Coronavirus-related advice and updates to social landlords; and
• keeping our regulatory approach under review as the situation develops and adjusting it as necessary.

We will support the work of the Scottish Government and the Social Housing Resilience Group in their coordination of the national response to the pandemic by:

• monitoring and reporting on the impact of the Coronavirus pandemic on social landlords, through a monthly data return from landlords and the publication of a monthly dashboard;
• using the information from the monthly returns to identify emerging issues and serious risks to tenants, people who are homeless and other service users; and
• continuing to work closely with the Scottish Government and the Social Housing Resilience Group to keep our response to the impact of the pandemic relevant and appropriate.

Empowering tenants and others 

We will help to empower tenants, people who are homeless, Gypsy/Travellers and others by:

• publishing the landlord performance data we gather in open, useful and accessible ways;
• providing tenants, people who are homeless, Gypsy/Travellers and others with tools to use the data we publish to help them better understand, compare and challenge their landlord’s performance, and we will continue to develop these tools;
• continuing to provide an effective way for tenants to raise concerns about landlord significant performance failures; and
• promoting to landlords the importance of involving tenants and others who use their services in the scrutiny of their performance to inform their self-assurance.

We will be keeping a strong focus on people who are homeless by:

• engaging and working with groups that represent and support people who are homeless; and
• talking openly about the things that people who are homeless tell us are important.

We will promote a strong tenant voice by:

• engaging with our National Panel of Tenants & Service Users to better understand their priorities and experiences;
• working with our tenant advisors to bring the tenant perspective to our work;
• engaging with the regional networks of Registered Tenant Organisations;
• engaging and working with tenant advocacy groups; and
• talking openly about the things that tenants tell us are important.

We will be keeping a strong focus on Gypsy/Travellers by:

• monitoring landlords’ achievement of the minimum standards for sites;
• engaging and working with groups that represent and support; and
• talking openly about the things that Gypsy/Travellers tell us are important.

Getting Assurance 

We will get assurance by:

• using Annual Assurance Statements from all RSLs and local authorities to inform our assessment of risk in each landlord;
• monitoring, assessing and reporting on RSL and local authority performance on:
  • the Scottish Social Housing Charter
  • discharging their statutory duties to provide timely and sustainable access to social housing to people who are homeless
  • standards relating to quality and safety of homes and Gypsy/Traveller sites;
• monitoring, assessing and reporting on RSL financial health and governance;
• carrying out visits to RSLs and local authorities driven by and to inform our assessment from 2021/22 when conditions allow; and
• maintaining a focus on our priorities through our risk assessment, including on rent affordability and value for money.

We will promote and support effective landlord self-assurance by:

• publishing statutory & advisory guidance to assist RSLs and local authorities to build capacity and drive improvement;
• collaborating with stakeholders to develop a toolkit to support landlord self-assurance and compliance with regulatory requirements; and
• working with others, including Fire & Rescue Scotland, HSE, OSCR, Audit Scotland, SPSO, Care Inspectorate and the Scottish Government.

We will be transparent by:

• publishing proportionate engagement plans for every RSL and local authority;
• publishing our regulatory judgement in engagement plans for all RSLs, starting with those that we are currently intervening in; and
• engaging with current and potential investors in social housing and making it clear if we consider that an RSL is not a suitable partner for investors.

Taking action where we need to 

We will act effectively and proportionately by:

• engaging with landlords where we see risks to the interests of tenants, homeless people, Gypsy/Travellers and others who use social housing services;
• using our statutory powers to protect those interests when we judge that to be appropriate and necessary;
• responding effectively when tenants raise concerns about significant performance failures;
• being open to, and responding to, people who bring concerns about landlords to us, including whistleblowers; and
• engage with investors and our other stakeholders to protect the interests of tenants.

We will encourage landlords to:

• promote a culture in which governing body members and staff can constructively challenge the performance of their landlord;
• engage with us early when they face challenges; and
• work constructively with us when we need to engage with them.

Our powers include:

• requesting information;
• making inquiries;
• setting a performance improvement target (for one or more landlords);
• requiring a performance improvement plan;
• serving an enforcement notice;
• appointing a manager; and
• appointing a governing body member to an RSL.

If an RSL or local authority is able and willing to investigate and resolve any issues, and it engages with us effectively, we won’t normally need to use our statutory powers.

Carrying out thematic work 

We use thematic work to look in depth at specific areas of RSL and local authorities work.  This helps us raise awareness of our priorities, emerging issues, lessons from serious casework and other things that tenants and service users tell us matter most.  Thematic work also informs our advisory guidance and risk assessments and lets us share positive practice. 

• Subject to easing of pandemic-related restrictions, from 2021/22 we will develop a programme of thematic work with a clear focus on our priorities:
• homelessness
• affordable rents
• value for money
• tenant & resident safety
• embedding our Regulatory Framework
• governance & financial health in RSLs

Promoting equalities and human rights 

We will:

• work with stakeholders to develop a framework for equality and human rights in social housing to support landlords to effectively embed equality and human rights in how they run their organisations and deliver services;
• require RSLs and local authorities to confirm through their Annual Assurance Statement that they meet the requirements around equality and human rights, or what they are doing to improve;
• seek assurance that landlords are giving due regard to equality and human rights in their decision-making through our engagements with individual landlords;
• use our thematic work to assess and report on landlords’ work to achieve the equalities outcome in the Scottish Social Housing Charter and to meet their legal duties in relation to equality and human rights; and
• refresh our own equalities statement.

How we will work

Our core values, principles and how we will communicate

• Independent 
• Accountable 
• Proportionate 
• Effective governance and financial stewardship 
• Engaged 
• Risk based 
• Evidence based judgement 
• Open and transparent 
• Effective and efficient 

We are committed to the better regulation principles enshrined in the Scottish Regulators’ Strategic Code of Practice. 

We will:

• Support our staff to work remotely and in new ways, while helping them to maintain a good work / life balance.
• Be visible & accessible, including using virtual platforms when necessary
• Be clear on what we require of RSLs and local authorities
• Refresh our How we work publications
• Continue to enhance our new website & use social media platforms effectively
• Look for opportunities to work collaboratively with others
• Share & promote good practice
• Provide a secure way for landlords to submit information to us
• Make the data we collect as freely accessible to others as possible
• Continue to publish annual summaries of our work plans
• Continue to learn lessons from all our work and from how we work during the pandemic

Our public body duties

We will be an effective public body, and we will model good governance and financial stewardship.

Our duties as a Scottish public body include:

• Equalities
• Whistleblowing 
• Records Management and Information Security
• Climate Change and Biodiversity
• Freedom of Information 
• Business Continuity  
• SPSO Complaints Handling and Reporting 
• Procurement 
• Data Protection 
• Health and Safety
• Digital and Cyber Resilience 
• Public Service Reform 
• Corporate Parenting 

Our resources

We will use our resources effectively & efficiently to deliver our regulatory priorities and public body duties.

Our revenue budget 

• staff costs 82%
• IT 7%
• other 7%
• office costs 7%

Our people:

• our chair supported by our Non-Executive Directors
• our 46 employees
• our Tenant Advisors
• the independent members of our Advisory Appeal Panel

We will also look to our:

• National Panel of almost 500 tenants and service users
• RTO Liaison Group
• Selection list of potential statutory managers

We continue to be grateful and seek the input of volunteer statutory governing body members (mostly drawn from the social housing sector) who work to strengthen governance and protect the interests of tenants.

Through risk-based regulation, we prioritise our resources and plan how to engage with RSLs & local authorities through further scrutiny, engagement or use of our powers.

How we will know if we have been effective

• We do the right things and we do them well, and so we safeguard and promote the interests of tenants, people who are homeless, Gypsy/Travellers and factored owners. 
• We respond effectively when the interests of tenants, people who are homeless, Gypsy/Travellers and factored owners are at risk.
• We manage any landlord failures to ensure tenants and service users do not suffer serious detriment, for example, losing their status as social housing tenants.
• We are open, transparent and accountable on our approach and performance.
• We influence others to focus on our priorities.
• Our stakeholders have confidence in how we regulate.