Policies

1. Introduction

1.1. This policy sets out Caring Circle Homes Ltd approach to managing the alteration of properties and installation of equipment to suit the changing needs of our customer. This includes the ongoing maintenance, servicing and renewal of any associated equipment or building fabric that may be needed.

1.2. The policy covers communal areas and customer’s homes and ensures that a reasonably practical approach is taken to assessing requests and by considering a range of funding options.

1.3. Caring Circle Homes ltd will comply with the requirements of the Home Standard and Tenancy Standard (proposed to be relaunched as the Safety and Quality Standard from April 2024). This requires Caring Circle Homes Ltd to clearly communicate how we will deal with requests and co-operate with partners to provide a service.

2. Purpose

2.1. The purpose of the policy is to ensure that customers are able where possible to remain at their home, where the physical environment can be adapted to meet their needs and to therefore improve the likelihood of achieving an independent life within their homes.

3. Legal and regulatory responsibilities

3.1. The Regulator of Social Housing’s The Safety and Quality Standard will come into effect from April 2024, with the following guidance on Adaptations:

• Registered providers must clearly communicate to tenants and relevant organisations how they will assist tenants seeking housing adaptations services.

• Registered providers must co-operate with tenants, appropriate local authority departments and other relevant organisations so that a housing adaptations service is provided to tenants.

4. Context

4.1. Caring Circle Homes Ltd is a provider of specialist supported housing tenancies and works in partnership with Care Providers and Commissioning Authorities to provide accommodation for customers with significant personal care needs. In most cases the properties have been refurbished with that end use in mind and should be generally accessible and usable. A potential customer’s needs are assessed by Adult Social Care or the NHS with the Care Provider prior to offering a tenancy to understand any additional adaptations that may be needed. This can also be reviewed at any point during the tenancy as circumstances change.

4.2. The costs for any adaptations can be funded from various sources, including a combination of

• Disabled Facilities Grants (DFG) from the Local Authority – this is the primary source of funding for larger works

• Caring Circle Homes Ltd investment from the repairs and maintenance budget

• Private Funding from the customer or their representatives

• Care Provider funding

4.3. Funding applications should be supported by an Occupational Therapist report in most cases, to ensure that the planned alterations or supplied equipment, will address all areas of need for the long term. Decisions on funding provided by Caring circle Homes Ltd and on permission for alterations and installations will be made openly and transparently with customers and all other parties involved. It is recognised that over time, a customer’s needs may change and new or further adaptations may be required or equipment may need to be changed or upgraded. The responsibility for decision in Caring Circle Homes Ltd is the Head of Property and Assets with the support of the Maintenance Surveyor.

4.4. There may be occasions where adaptations requests or the supply and maintenance of equipment cannot be met. Typical reasons for this would be

• When the customer is actively seeking re-housing elsewhere

• When the adaptation is not structurally practicable

• A Care Provider is exiting the property imminently.

• Superior Landlord consent cannot be gained.

• Budget availability to fund the changes and the associated servicing and maintenance

• When the property is under-occupied and extensive/costly adaptations are requested

• When the adaptation results in the loss of rooms or considerable space within the property (communal area or individual dwelling elsewhere), that is incompatible with the other customers e.g. a through floor lift.

• When a request is made to provide a level access shower for resident mobility issues above the ground floor without measures in place to ensure the resident can access and egress the upper floors unaided.

• Where a suitable alternative property exists elsewhere, and an offer can be made.

• Future letting potential may be impacted negatively

4.5. Minor Adaptions - Where minor adaptions are needed to support a customer to remain in their home and/or improve their independence, Caring Circle Homes Ltd will arrange for the work to be carried out through our contracted maintenance partner, providing the cost does not exceed £300+VAT per customer per year. Examples of minor adaptions are the installation of a grab rail or hold open device for a door.

4.6. Adaptation Register - All equipment and adaptations work completed to a property will be recorded on a register as part of the property details and updated during void and Stock Condition surveys, including future servicing and maintenance responsibility. This information will also be used to ensure any future allocations are made to applicants requiring such adaptations where possible and will inform the maintenance and servicing regimes in line with legislation and good practice and set out whose liability that is to oversee and manage.

4.7. Maintenance and Servicing arrangements - We will work closely via the Internal Maintenance Service and Partnering Contractor to complete equipment and adaptations servicing in line with statutory requirements and manufacturers guidance.

5. Policy review

5.1. This policy will be reviewed every 3 years.

1 Introduction

1.1 Caring Circle Homes has a responsibility to ensure compliance with legislative duties in relation to asbestos, in particular a duty to manage Asbestos Containing Materials (ACMs) in its properties. This policy sets out how Caring Circle Homes responsibilities to customers, visitors, staff, contractors and other stakeholders will be achieved.

1.2 Detailed interpretation and the means by which Caring Circle Homes Ltd will deliver practical implementation of the Policy will be set out in Caring Circle Homes Asbestos Management Plan (AMP).

2 Purpose

2.1 The overall aim of this policy is to ensure that Caring Circle Homes meets its obligations under the Control of Asbestos Regulations 2012, specifically the ‘duty to manage asbestos’ requirements of Regulation 4. Caring Circle Homes Ltd will also ensure that any ACMs identified within its properties, or properties for which Caring circle homes ltd   have responsibility, are managed in accordance with the Control of Asbestos Regulations 2012 (CAR12) and all other associated and relevant legislation.

3 Scope

3.1 This policy applies to all buildings and associated structures either owned, leased, occupied or managed by Caring Circle Homes Ltd. It also relates to work commissioned and/or managed by Caring Circle Homes Ltd.

4 Legal and Regulatory Responsibilities (not exhaustive)

• Control of Asbestos Regulations 2012 (CAR12)

• Health and Safety at Work etc. Act 1974 (HASWA)

• Health and Safety at Work Regulations 1999

Details of other relevant legislation, codes of practice and subject matter guidance will be held within the AMP.

5 Policy Statement

5.1 In recognition of its duties under CAR12 and HASWA, Caring Circle Homes Ltd undertakes to protect all persons on its premises or as otherwise affected by its undertaking, from harmful exposure to asbestos; by identifying it and maintaining it in a safe condition and by adopting safe ways of working to prevent exposure, so far as is reasonably practicable.

5.2 Specifically, Caring Circle Homes Ltd will:

• Ensure that all material identified as likely to contain asbestos is managed in accordance with relevant legislation.

• Not undertake (directly, or via external contractors/agents), or contract out any work to a property owned, leased, occupied, or those it manages without adequate information on the nature, condition, and extent of any ACM likely to be disturbed;

• Compile and maintain an up-to-date record of the location, condition, extent, and nature of any ACMs in its portfolio;

• Ensure that it contracts with competent asbestos surveyors and/or companies who will possess the expertise to undertake management surveys, refurbishment and demolition surveys and monitoring (re-inspection) surveys

• Ensure that any ACM removal/abatement work will be undertaken by an approved, accredited, and competent contractor. This to include any minor asbestos related tasks approved and endorsed to be undertaken directly by any Caring Circle Homes Ltd contractors specifically assessed as competent to do so.

6 Key Outcomes

6.1 The AMP should be regarded as the key, strategic asbestos compliance document. As such it will interpret this asbestos policy together with associated published guidance to set out strategically how Caring Circle Homes Ltd will:

• Keep and maintain an up-to-date record (Asbestos Register) of the location, condition, maintenance, and removal of all ACMs;

• Repair, seal or remove ACMs if there is a risk of exposure due to their individual condition or location;

• Implement a robust, prioritised re-inspection procedure and program for identified ACMs;

• Maintain ACMs in a good state of repair and regularly monitor condition (in line with the Declared Caring Circle Homes Ltd re-inspection protocols);

• Inform anyone whose action is liable to or may disturb (or issue instruction for work which may disturb) ACMs, about their location, nature, extent, and condition. This will include ‘suspected’, as well as tested and identified ACMs. Persons concerned may necessarily include Caring Circle Homes Ltd staff, Care Providers all contractors (and sub-contractors), consultants/technical representatives (incl. CDM roles), external bodies managing works in our homes, (e.g. Local Authority Aids and Adaptations), and customers;

• Have arrangements and procedures in place for the appointment and management of specialist Asbestos Surveying Consultants (ASC) and Asbestos Removal Contractors (ARC). This includes third party sample audit/QC via appropriate specialists;

• Inform relevant staff of the contents of the AMP at regular intervals;

• Identify relevant management procedures and the roles and responsibilities of Caring Circle Homes Ltd;

• Inform and assist staff to understand and apply these ‘operational’ task-oriented processes practically;

• Review the AMP at regular intervals, upon process changes or the occurrence of a significant incident.

6.2 Contractors (and their sub-contractors) employed by Caring Circle Homes Ltd will be required to provide risk assessments and method statements (RAMS) prior to working in areas containing ACMs (or presumed to contain ACMs pending survey). These RAMS must be approved by Caring Circle Homes Ltd. of Property and Assets or a suitably qualified deputy, prior to any work commencing.

6.3 Customers and/or Care Providers will be provided with information as detailed within the AMP as required.

7 Roles and Responsibilities

7.1 Details of the roles and responsibilities of Caring Circle Homes Ltd staff, external contractors and other stakeholders relevant in respect of asbestos compliance are held within the AMP. The following list summarises some of the primary roles:

• The Chief Executive Officer is the principal duty holder in terms of achieving compliance with Health and Safety legislation and the Control of Asbestos Regulations 2012 through safe management and prevention of risk

• The Head of Property and Assets is responsible for the management and review of the asbestos policy across Caring Circle Homes Ltd and to oversee practical implementation and coordination of the asbestos policy (via the AMP and other necessary procedures)

• Heads of Service have responsibility for ensuring that this AMP and associated asbestos policy is implemented within their individual directorates/service areas. They will also ensure that adequate resources are available to meet the requirements of this asbestos management plan.

7.2 Achievement of these responsibilities will be delivered by delegation to suitably qualified and experienced employees who will have responsibility for the operational application and service delivery of this management plan and its associated procedures.

7.3 In accordance with the Health and Safety at Work Act 1974, all Caring Circle Homes Ltd employees and contractors working for Caring Circle Homes Ltd shall have regard to the health and safety of themselves and others who may be affected by any of their undertakings with respect to ACMs and they shall co-operate in the implementation of this policy.

7.4 Unless specifically trained and authorised to do so, no Caring Circle Homes Ltd employee may conduct work on and ACM; this includes the taking of samples.

8 Linked Documents

8.1 This policy is linked to the following documents and should be read in conjunction:

• Health and Safety Policy

8.2 Operation of this policy will be supported by an internal Asbestos Management Plan that provides a more detailed description of the processes to be followed by Caring Circle Homes Ltd employees and contractors.

9 Policy Review

9.1 This policy will be reviewed every two years.

1. Introduction

1.1. Caring Circle Homes Ltd acknowledges and accepts responsibility under the Landlord and Tenant Act and associated legislation and guidance, to ensure all tenanted properties meet or exceed the requirements of what is considered to be a decent home, which includes a requirement to ensure there are no category 1 damp hazards.

1.2. In addition, as a result of the implementation of Awaab’s Law, from October 2025 all social landlords will be required to address damp and mould hazards that present a significant risk of harm to tenants within fixed timescales. From the same point in time, they will also have to address all emergency repairs (whether they relate to damp and mould or not), as soon as possible and within a timescale of no longer than 24 hours.

2. Purpose

2.1. This policy outlines Caring Circle Homes commitment and procedures aimed at preventing damp, mould and other HHSRS issues in social housing and protecting tenant health to ensure compliance with Awaab’s Law.

3. Scope

3.1. This policy applies to all properties managed by Caring Circle Homes including communal areas.

4. Legal and Regulatory Responsibilities

4.1. There are 5 main legal standards that relate to damp and mould in rented homes:

• The Housing Act 2004 – this states that properties must be free from hazards at the most dangerous ‘category 1’ level, as assessed using the Housing Health and Safety Rating System (HHSRS)

• The Environmental Protection Act 1990 – this gives tenants and local councils powers to take legal action where homes contain a ‘statutory nuisance’, which includes where they are in such a state as to be prejudicial to health

• The Landlord and Tenant Act 1985, with new provisions added by the Homes (fitness for human habitation) Act 2018 – this requires that properties are free of hazards, including damp and mould, which are so serious that the dwelling is not reasonably suitable for occupation in that condition

• Decent Homes Standard – to meet the Decent Homes Standard (DHS), social housing must be free from dangerous ‘category 1’ hazards. However, the DHS also states that social housing must be in a reasonable state of repair and provide a reasonable degree of thermal comfort. Either disrepair or inadequate thermal comfort, or both, may result in damp and mould

• Awaab’s Law – to be introduced in October 2025. To meet Awaab’s Law issues need to be investigated and resolved within fixed timescales and better communication with tenants is required throughout the repair process.

5. Caring Circles Homes Ltd's approach to preventing and identifying Damp and Mould

5.1. Caring Circle Homes Ltd is dedicated to providing safe, healthy living environments for all tenants. In accordance with Awaab’s Law, we have proactive measures and controls in place to prevent and address damp and mould issues in our properties, which include:

5.2. Inspection and Maintenance

• Routine Inspections: Caring Circle Homes Ltd conducts monthly Housing Officer visits to all properties. During these visits Housing Officers will liaise with the care provider, to identify potential damp and mould issues

• Maintenance Requests: Caring Circle Homes Ltd will respond promptly to tenant reports of damp and mould. Initial make safe and triage work will be attended within 14 days

5.3. Tenant Responsibilities

Tenants, with support from care providers, are required to report any signs of damp (including leaks) or mould immediately

• Tenants, with support from care providers, must use the ventilation and heating system provided in their homes to manage humidity, reducing the risk of condensation within their homes

• Tenants, with support from care providers, are to keep their home clean and free of unreasonable clutter, to ensure circulation of heat and air. This is necessary to prevent condensation occurring in stagnant areas

5.4. Preventative Measures

• Ventilation: Caring Circle Homes Ltd will install and maintain proper ventilation systems in kitchens and bathrooms

• Insulation: Caring Circle Homes Ltd will ensure all properties are adequately insulated to prevent condensation, where feasible

• Leaks: Caring Circle Homes Ltd will ensure all leaks are repaired within appropriate timescales, allowing for sufficient drying periods

• Education: Caring Circle Homes Ltd will provide tenants with information on preventing damp and mould, including proper ventilation, heating practices, biofilms and cleaning and reporting procedures

5.5. Remediation

• Triage: Upon receiving a report of damp or mould, Caring Circle Homes Ltd will conduct an initial assessment to determine the cause and extent of the issue

• Investigation: Caring Circle Homes Ltd will develop and implement a remediation plan within 14 days of the initial report. This may include repairs to leaks, improvements to ventilation, and mould removal.

• Remediation: Caring Circle Homes Ltd will ensure delivery of the repairs needed within the timescales set out in Caring Circle Homes Ltd Repairs and Maintenance Policy

• Review: Caring Circle Homes Ltd will conduct a review of the works completed to ensure the issue has been resolved and take additional actions if necessary

5.6. Communication

• Reporting: Caring Circle Homes Ltd will maintain clear and accessible channels for tenants to report damp and mould issues

• Updates: Caring Circle Homes Ltd will keep tenants informed of inspection schedules, findings, and remediation plans

5.7. Support

• Caring Circle Homes Ltd will provide support to tenants affected by damp and mould, including temporary relocation if necessary

6. Caring Circle Homes Ltd's approach to remediating Emergency Hazards

6.1. There will be circumstances where a resident reports a hazard in their home that warrants an emergency repair. Hazards that pose significant and imminent danger to residents will require faster action and will be treated as an emergency by Caring Circle Homes Ltd.

6.2. Caring Circle Homes Ltd Repairs and Maintenance Policy includes details of hazards that are likely to meet the definition of emergency repairs. Caring Circle Homes Ltd target timeframe for remediating emergency repairs is 24 hours.

7. Record Keeping and Monitoring

7.1. Caring Circle Homes Ltd will maintain detailed records of all inspections, reports, communications with customers and remediation actions related to damp, mould and other emergency hazards.

7.2. Caring Circle Homes Ltd will ensure these records are accessible for review by the appropriate authorities to demonstrate compliance with Awaab’s Law.

8. Linked Documents

8.1. This policy is linked to the following documents and should be read in conjunction:

• Repairs and Maintenance Policy

8.2. Operation of this policy will be supported by an internal Awaab’s Law Procedure that provides a more detailed description of the processes to be followed by Caring Circle Homes Ltd employees and contractors.

9. Policy review

9.1. This policy will be reviewed annually until the full scope of Awaab’s Law has been implemented.

1. Introduction

1.1. Caring Circle Homes Ltd is committed to respecting the privacy and information rights of individuals and processing personal data in accordance the Data Protection Act 2018 (the Act) and the UK General Data Protection Regulation (GDPR). The Information Commissioner’s Office (ICO) is the supervisory authority for data protection in the UK: it issues guidance on data protection and we will follow this guidance.

1.2. As part of our work we are required to collect and use certain types of information about individuals who come into contact with our organisation. This personal information must be handled properly irrespective of how it is collected, recorded and used – whether on paper, on a computer, or recorded on other material.

1.3. This policy sets out responsibilities and our practices for complying with the law including our responsibilities about the collection, use and disclosure of data and customer’s rights to access their personal data.

2. Legal and Regulatory Responsibilities (not exhaustive)

• The Data Protection Act 2018 (which brings the GDPR into UK law)

• UK General Data Protection Regulations (GDPR)

3. Scope

3.1. This policy covers all our business activity including:

• Tenants and applicants for housing

• Employees and applicants for employment

• Board and committee members

• Clients and grant recipients

• Contractors, external agents, support providers and consultants

4. Definitions

4.1. Data controller is the person who (either alone or jointly in common with other persons) determines the purposes for which and the manner in which any personal data are to be processed.

4.2. Data subjects are individuals for whom personal data is collected; we call them individuals in this policy.

4.3. Lawful basis is the basis on which data can be processed as described in the GDPR. There are 6 available lawful bases as follows:

• Consent

• Contract

• Legal obligation

• Vital interests

• Public task

• Legitimate interests

4.4. Personal data is information that identifies a living individual either by that data alone, or in conjunction with other data held.

4.5. Processor is someone who is responsible for processing personal data on behalf of the controller.

4.6. Special category data is data that needs more protection because it is sensitive.

5. Policy Principles

5.1. We take data protection seriously and are committed to handling the personal information we hold sensitively, appropriately and legally. We fully adhere to the Principles of Data Protection, as detailed in the Act:

1. Lawfulness, fairness and transparency – data collection must be fair, for a legal purpose and we must be open and transparent about how the data will be used

2. Purpose limitation – data is collected for specific, explicit and legitimate purpose

3. Data minimisation – data is adequate, relevant and limited to what is necessary

4. Accuracy – data is accurate and where necessary data is kept up to date

5. Storage limitation – data is not kept for longer than is necessary

6. Integrity and confidentiality – appropriate security of personal data

7. Accountability – taking responsibility for what we do with personal data, having measures in place that show that we comply with the law

5.2. All customers will be made aware of their rights. Board Members, employees and potential employees will be made aware of their responsibilities under the Act and the rights of our customers and individuals using our services. They will be required to lead by example in demonstrating good conduct and ensuring compliance with legal requirements, rules, and procedures.

5.3. We will make sure our partners also understand our stance and their obligations by publishing this policy and (where appropriate) by including clauses in our contracts to make this clear.

6. Collecting and Processing of Personal Data

6.1. We will provide privacy information to individuals when we collect data from them. When we obtain personal data for the first time and when any new data is collected, we will explain:

• Why the personal data is required and held

• The purposes for which the data may be used

• Who may have access to the data

6.2. We will ensure personal data we collect, and process is:

• Adequate – sufficient to meet our purpose

• Relevant – has a link to our purpose

• Limited to what is necessary – we will not hold more than we need

6.3. We will ensure that the "lawful basis” for collecting and processing personal information is identified and recorded.

6.4. As a provider of supported housing we need to collect and hold more sensitive personal data (described as “special category” information within the Act) to provide our services, to help customers access care services they need or to deal with neighbour disputes. We will always seek clear consent for this and explain why we need it and who we will share the information with, see also our privacy statement. We have stricter access requirements to this information within Caring Circle Homes Ltd.

6.5. We will take reasonable steps to ensure that personal data is kept up to date and to encourage individuals to let us know of any changes. We cannot be held responsible for any errors or inaccuracies in personal data being held and processed where we have not been provided with up-to-date information.

7. Security of Personal Data

7.1. We are committed to retaining personal data securely in whatever format it is stored. We recognise and respect an individuals’ rights to privacy and their expectation that personal data will be handled sensitively and in accordance with the law.

7.2. We will take appropriate steps to keep our computer systems secure and to protect personal data from unauthorised access, disclosure and/or loss. This includes:

• Firewalls and Internet gateway

• Secure configuration of hardware and software

• Access controls

• Anti-virus and anti-malware software

• Backing up data regularly

• Using secure arrangements when transferring data

• Monitor security messages from software and access control logs

• Training staff in safe use of IT and protecting data

7.3. We will give staff and, where relevant, Board Members advice on the necessary physical security arrangements to be adopted appropriate to the level of confidentiality required for the personal data concerned. We will also provide guidance on keeping data secure and for dealing with disclosure requests.

7.4. Where other organisations are contracted to carry out work on our behalf, we will make expectations clear on their role in protecting personal data, such as tenant contact details provided to repairs and maintenance contractors.

7.5. Where we will be carrying out a project that involves the processing of personal data and where there is a high risk to individuals, we will carry out a Data Protection Impact Assessment in line with ICO guidelines.

8. Data Breaches

8.1. All staff and Board Members are required to report any data security breaches or suspected breaches, relating to unauthorised access to or disclosure of personal data, immediately using the data breach procedure.

8.2. We will take all reasonable steps to ensure that any organisation with whom we share data notifies us of any data breach, where this relates to or may relate to personal data which we have shared with them.

8.3. All data breaches will be taken seriously, will be investigated and lessons learned will be shared to reduce the chances of a future breach. Data breaches may be reported to the ICO where required to do so as set out in their data breach guidance.

9. Disclosure of Information and Data Sharing

9.1. We do not share data with colleagues or others that it is not necessary or relevant for them to hold to carry out their work. However, in order for us to operate effectively there will be some instances when personal data will need to be disclosed and/or discussed with other appropriate colleagues or individuals. In such instances this disclosure, whether it is written or verbal, will be appropriate and reasonable for business purposes, on a need-to-know basis only and in line with data protection legislation and, where possible, in accordance with ICO guidance.

9.2. Personal data relating to individuals will be considered confidential and will only be passed to other organisations with the express written consent of the individual concerned unless they are directly related to our responsibilities and legitimate interests as a landlord (e.g. tenant contact details provided to enable a contractor to carry out repairs or improvement works or to obtain customer views on our services) or where there are exceptional circumstances, see below. Where we seek consent to share data we will explain why and to whom that data may be disclosed.

9.3. However, in some circumstances and in order for us to provide our services more effectively we may enter into information sharing protocols with other organisations. All data sharing protocols will be reviewed regularly to ensure that they remain relevant and up to date.

9.4. Only in exceptional circumstances will we share personal data about an individual without their consent. Such exceptional circumstances include the following:

• Where the health and safety of an individual may be at risk if the information was not shared

• Where it is needed to carry out our duties as a landlord

• In connection with legal proceedings

• To comply with the law

• Where there is clear evidence of fraud

10. Retaining and Disposing of Data

10.1. All personal data that is held will be relevant for the purpose for which it is required and will be kept securely. It will be retained for the period set out in our Records Retention Policy, and for no longer except where a contract requires otherwise.

10.2. We will regularly review data we hold and erase or anonymise it to comply with our document retention guidelines. Where personal data is no longer required, it will be destroyed in a secure manner.

11. Access to Information

11.1. Individuals may request a copy of information held about them by us (data subject access request) and can seek to have it amended or erased if it is inaccurate or no longer required. An individual is entitled to ask for confirmation that we are processing their data and ask for a copy of it together with supplementary information. An individual is not entitled to information relating to other people (unless their data also relates to other individuals).

11.2. We will respond to any subject access requests as quickly as possible, but within the required period, i.e. within one month of receipt of the request.

11.3. Where it is not possible to complete a request the individual will be informed in writing, with a full explanation. We will follow ICO guidance in meeting requests, circumstances where a request may not be met include the following:

• Where the request is manifestly unfounded

• Where the request is excessive

• Where the request would mean disclosing information about another individual who has not given their consent and it would not be reasonable to disclose

11.4. Individuals have the right to request inaccurate data be rectified or completed if it is incomplete. We will make any changes within one month of receipt of the request or in line with the ICO guidelines. If we are satisfied that our data is accurate, we may not comply with a request or there may be other reasons we cannot comply. We would explain these clearly to the individual.

11.5. In certain circumstances individuals also have the following rights and we will ensure appropriate arrangements are put in place to exercise these:

• Right to erasure – right to have personal data erased

• Right to restrict processing – right to restrict or suppress personal data

• Right to data portability – right to obtain and reuse personal data for their own purposes

• Right to object – right to object to their data being used in certain circumstances

• Rights related to automated decision making – we do not use automated decision making

11.6. Individuals have the right to receive a copy of information held about them free of charge. However, we reserve the right to make a reasonable charge for responding to requests which are excessive or repetitive.

12. Raising Concerns

12.1. Board Members, employees, our customers and the general public are an important part of our compliance with the principles of data protection. They are encouraged to raise any concerns they may have in respect of data protection. A number of different channels for communication are available, including via senior officers, auditors, Board Members and via the Whistleblowing Policy. Our customers and members of the public may also use our complaints procedure for this purpose where appropriate. All allegations of data breaches, or poor data practice, will be investigated.

13. Responsibilities

13.1. Caring Circle Homes Ltd Data Protection Officer (DPO) Farha Khan has overall responsibility for Data Protection within Caring Circle Homes Ltd, and for ensuring that we comply with ICO requirements including documentation and payment of the data protection fee.

13.2. The responsibility for data protection is shared by all Caring Circle Homes Ltd staff. Each senior manager will have responsibility for their area of operation. They are encouraged to raise any concerns if breach of the policy is suspected.

13.3. Line managers are responsible for ensuring newly appointed employees are aware of this policy and their responsibilities relating to their role.

14. Monitoring and Review

14.1. Caring Circle Homes Ltd will carry out audits and review the personal data we collect and update our records accordingly.

14.2. We will record data access requests and monitor responses.

14.3. We will investigate all concerns raised and reports of any data breaches, record the outcome of these investigations and lessons learned. The outcomes will be reported to the Board.

14.4. This policy will be reviewed every three years.

1. Introduction

1.1. Caring Circle Homes Ltd is responsible for the maintenance and repairs to its homes and other buildings, all of which will contain electrical installations and appliances. The Landlord and Tenant Act 1985 and the Housing Act 2004 place duties on landlords to ensure that these electrical installations are safe at the start of any tenancy and are maintained in a safe condition throughout the tenancy.

1.2. Caring Circle Homes Ltd is also responsible for maintaining electrical installations and equipment in non-domestic (communal) areas of buildings, offices and other premises that Caring Circle Homes Ltd owns and manages.

1.3. This policy sets out Caring Circle Homes Ltd's planned cyclical approach of servicing and inspecting electrical installations and ensuring that all contractors are competent.

2. Purpose

2.1. Caring Circle Homes Ltd must establish a policy which meets the requirements for electrical safety under various legislation detailed in section 4.

2.2. In addition to this, the policy must provide assurance to Caring Circle Homes Ltd that measures are in place to ensure compliance with these regulations and to identify, manage and/or mitigate risks associated with electrical installations and electrical portable appliances.

2.3. Caring Circle Homes Ltd must also ensure compliance with electrical safety legislation is formally reported at Executive and Board level, including the details of any non-compliance and planned corrective actions.

3. Scope

3.1. This policy applies to all buildings and associated structures either owned, leased, occupied or managed by Caring Circle Homes Ltd.

3.2. The policy is relevant to all Caring Circle Homes Ltd employees, tenants, contractors and other persons or other stakeholders who may work on, occupy, visit, or use its premises, or who may be affected by its activities or services.

3.3. The policy is also relevant for maintaining a safe working environment for all employees, tenants and other visitors within all Caring Circle Homes Ltd properties.

4. Legal and Regulatory Responsibilities

4.1. Core Legislation

• Landlord and Tenant Act 1985;

• Electricity at Work Regulations 1989

• Electrical Equipment (Safety) Regulations 1994

• Homes (Fitness for Human Habitation) Act 2018

4.2. Other Legislation

This policy also operates in the context of the following legislation:

• Health and Safety at Work Act 1974

• The Management of Health and Safety at Work Regulations 1999

• The Workplace (Health Safety & Welfare) Regulations 1992

• Management of Houses in Multiple Occupation (England) Regulations 2006

• Regulatory Reform (Fire Safety) Order 2005

• The Building Regulations for England and Wales (Part P)

• The Housing Act 2004

• The Occupiers’ Liability Act 1984

• Provision and Use of Work Equipment Regulations 1998

• RIDDOR 2013

5. Codes of Practice

5.1. The principle codes of practice applicable to this policy are as follows.

• IET Wiring Regulations British Standard 7671:2018

• INDG236: ‘Maintaining portable electrical equipment in offices and other low risk environments’

• Electrical Safety Council: ‘Landlords’ Guide to Electrical Safety 2009’

6. Compliance Requirements

6.1. In order to be compliant with legislation and codes of practice, all electrical installations are required to be periodically inspected and tested.

6.2. The intervals between inspections are not absolutely set within any regulations; however, best practice guidance from the Electrical Safety Council and from BS7671:2018 states that electrical installations should be tested at intervals of no longer than 5 years from the previous inspection and/or on change of tenancy. Any deviation from these intervals should be at the recommendation of a competent NICEIC qualified (or equivalent) person and should be backed up by sound engineering evidence to support the recommendation.

6.3. All electrical installations should be inspected and tested prior to the commencement of any new tenancies (void properties), mutual exchanges and transfers, and a satisfactory EICR should be issued to the tenant prior to them moving in.

6.4. The Electrical Equipment (Safety) Regulations 1994 requires Landlords to ensure that any electrical appliances provided as part of a tenancy are safe when first supplied.

6.5. The Electricity at Work Regulations 1989 places duties on employers that all electrical installations and appliances within the workplace are safe and that only competent persons work on the electrical installations, systems and equipment.

7. Caring Circle Homes Ltd Approach

7.1. Caring Circle homes ltd acknowledges and accepts its responsibilities with regard to electrical safety under the Landlord and Tenant Act 1985, the Housing Act 2004, the Electricity at Work Regulations 1989, the Electrical Equipment (Safety) Regulations 1994 and the Homes (Fitness for Human Habitation) Act 2018.

7.2. In order to meet these requirements, Caring circle Homes Ltd will:

• Hold accurate records against each property it owns or manages that identify when the electrical installation was last inspected and tested, and listing all electrical portable appliances that the organisation owns held at each property together with details of Portable Appliance Tests (PATs) undertaken;

• Ensure that all domestic properties owned or managed by the organisation have a valid Electrical Installation Condition Report (EICR) that is no older than 5 years from the date of the previous EICR;

• Ensure that all non-domestic and ‘other’ properties, such as management agreements and community buildings, owned or managed by the organisation have a valid Electrical Installation Condition Report (EICR) that is no older than 5 years from the date of the previous EICR;

• Ensure that all electrical installations shall be in a satisfactory condition following completion of an electrical installation inspection and test;

• Ensure that electrical installation inspection and tests are carried out prior to the commencement of any new tenancies (void properties), mutual exchanges and transfers and that a satisfactory EICR is issued to the tenant prior to them moving in;

• Ensure that only suitably competent NICEIC electrical contractors and engineers (or equivalent) undertake electrical works for the organisation;

• Carry out electrical installation inspection and tests and issue new satisfactory EICRs when completing planned component replacement works within domestic properties. In the case of a rewire Caring Circle Homes Ltd will receive an installation certificate and following minor works, a minor works certificate;

• Test and/or replace as necessary hard wired smoke alarms, CO alarms and heat detectors (where fitted) which are not covered as part of the annual gas safety check visit (i.e. the property does not have gas) on an annual basis;

• Ensure that all electrical portable appliances owned and/or provided by the organisation are tested periodically in accordance with the testing guidance set out in ‘The Code of Practice for In-Service Inspection and Testing of Electrical Equipment’ (ISITEE);

• Ensure that robust processes and controls are in place to manage the completion of follow up works identified during inspection and testing of electrical installations and electrical portable appliances;

• Ensure that robust processes and controls are in place to ensure that all electrical works are properly notified and approved under Part P of the Building Regulations for England and Wales where this is required;

• Ensure that robust processes and controls are in place to manage works to void and occupied properties that may affect existing electrical installations;

• Have a robust process in place to gain access to properties where tenant vulnerability issues are known or identified whilst ensuring the organisation can gain timely access to any property in order to be compliant with this policy and safeguard the wellbeing of the tenant;

• Establish and maintain a plan of all continuous improvement activity undertaken with regards to electrical safety.

8. Inspection Testing Programmes

8.1. Caring Circle Homes Ltd will carry out a programme of electrical installation inspection and testing to all domestic properties. This inspection and test will be carried out at intervals of no more than 5 years and will include the issuing of a new satisfactory Electrical Installation Condition Report (EICR). This inspection and test is driven from the anniversary date of the most recent EICR, which may have been carried out at the start of a new tenancy or following planned component replacement works.

8.2. Caring Circle Homes Ltd will carry out a programme of electrical installation inspection and testing to common areas of non-domestic properties and any ‘other’ properties where there is a landlord’s electrical

installation (and where Caring Circle Homes Ltd has the legal obligation to do so). This inspection and test will be carried out at intervals of no more than 5 years and will include the issuing of a new satisfactory Electrical Installation Condition Report (EICR). This inspection and test is driven from the anniversary date of the most recent EICR, which may have been carried out following planned component replacement works.

8.3. Caring Circle Homes Ltd will carry out a programme of portable appliance testing (PAT) to all electrical portable appliances owned and/or provided by the organisation every 2 years. These appliances will be tested in accordance with the testing guidance set out in ‘The Code of Practice for In-Service Inspection and Testing of Electrical Equipment’ (ISITEE).

9. Key Roles and Responsibilities

9.1. Caring Circle Homes Ltd’s Board will be responsible for approval of the policy and its implementation and monitoring performance.

9.2. The Chief Executive Officer will be responsible for the implementation of this policy and responsible for the delegation of its full implementation and delivery to the Head of Property and Assets and their authorised deputy.

9.3. The Head of Property and Assets will be responsible for the implementation of this policy along with any associated procedures, and responsible for the day-to-day management of the same, supported by their authorised deputy.

9.4. The Maintenance and Compliance Manager will be responsible for the day-to-day management of this policy and any associated procedures in the event that the Head of Property and Assets is unavailable.

9.5. Caring Circle Homes Ltd’s Surveyors will be responsible for completing PATs on all Caring Circle Homes Ltd owned equipment in common parts of the buildings it manages. These individuals will be suitably trained and aware of their duties under current legislation and this policy.

10. Performance Reporting

10.1. Robust key performance indicator (KPI) measures will be established and maintained to ensure Caring Circle Homes Ltd can report on performance in relation to electrical safety, and these will be reported to the Executive and Caring Circle Homes Ltd’s Board monthly.

10.2. As a minimum, these KPI measures will include the percentage of all unexpired EICR certificates held by Caring Circle Homes Ltd and the percentage of all unexpired PATs held by Caring Circle Homes Ltd, both as a proportion of the total number of properties, it owns or manages plus any non-domestic premises, with a target of 100% completion at all reporting dates.

11. Record Keeping

11.1. Caring Circle Homes Ltd will establish and maintain accurate records of all completed Electrical Installation Condition Reports (EICRs), Minor Electrical Works Certificates (MEW) and Building Regulation Part P notifications associated with remedial works from these reports and Electrical Installation Certificates and keep these for a period of not less than 7 years.

12. Linked Documents

12.1. This policy is linked to the following documents and should be read in conjunction:

• Health and Safety Policy

13. Policy Review

13.1. This policy will be reviewed every two years.

1. Introduction

1.1. Caring Circle Homes Ltd recognises, accepts and promotes its duties to provide a healthy and safe environment, as far as reasonably practicable, for our residents, contractors, and visitors to the properties.

1.2. The policies and procedures put in place by Caring Circle Homes Ltd can have a significant impact upon the safety of its residents, officers and contractors. Caring Circle Homes Ltd is committed to reducing the risk of fire in its housing stock to the lowest reasonably practicable levels.

1.3. This policy and procedure aims to clarify Caring Circle Homes Ltd's approach to fire safety management. This policy will not address fire safety in all scenarios and in all property types but will set a decision framework for addressing fire safety requirements at individual properties.

1.4. Fire safety in individual properties will ultimately be dictated by the Fire Risk Assessment, and application of the relevant guidance current at the time of the assessment.

2. Purpose

2.1. The purpose of this policy is to demonstrate how Caring Circle Homes Ltd will fulfil its obligations under the fire safety statutory regulations.

2.2. This policy and procedure will ensure Caring Circle Homes Ltd continues to keep all stakeholders, including residents, staff, stakeholders (including care providers) and contractors, safe and informed of their responsibilities.

3. Scope

3.1. The scope of this policy focuses on Caring Circle Homes Ltd's entire property portfolio and describes Caring Circle Homes Ltd arrangements for satisfying its fire safety compliance under relevant legislation. Caring Circle Homes Ltd understands its obligations as “the Responsible Person” as defined by the Regulatory Reform (Fire Safety) Order 2005.

3.2. Caring Circle Homes Ltd portfolio includes the following property types:

• Houses

• HMO-type shared housing.

• Low-rise flat blocks not exceeding 11m

• Bungalows

• Bedsits

• Office premises

3.3. Caring Circle Homes Ltd aims to take any fire precautions as described by the fire risk assessments within its stock that will, so far as is reasonably practicable, preserve and protect life in the event of a fire and take reasonable measures to prevent fires from occurring.

3.4. It is to be noted that under the definitions set under The Fire Safety (England) Regulations 2022, and based on the measurement method outlined in Building Regulations Approved Document B2 (Volume 2 Fire safety in dwellings) Appendix D, none of the Caring circle homes ltd properties are classified as exceeding 11m in height and therefore by extension none exceed 18m.

4. Legal and Regulatory Responsibilities

4.1. Caring Circle Homes Ltd's responsibility in respect of fire safety is governed by the following statutory requirements:

• Health & Safety at Work Act 1974 (HASAW)

• Management of Health & Safety at Work Regulations 1999

• Regulatory Reform (Fire Safety) Order 2005 – applicable to commercial properties and the communal parts of housing stock

• Fire Safety Act 2021

• Building Safety Act 2022

• Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022

• Specialised Housing Guidance - National Fire Chiefs Council

• Housing Act 2004 – fire safety

• Regulator of Social Housing’s Home Standard

• PAS 79-1:2020 Fire risk assessment. Premises other than housing. Code of practice

• PAS 79-2:2020 Fire risk assessment. Housing. Code of practice

• Workplace (Health, Safety and Welfare) Regulations 1992

• Health and Safety (Safety Signs and Signals) Regulations 1996

• Smoke-free (Premises and Enforcement) Regulations 2006

• Control of Substances Hazardous to Health Regulations (COSHH) 2002

4.2. Caring Circle Homes Ltd will ensure that consultants and staff members adhere to the relevant guidance documents and that these are given consideration in the fire risk assessment of its purpose-built andconverted housing stock, and any office premises within its portfolio.

5. Our Approach

5.1. Prevention

5.1.1. Caring Circle Homes Ltd will complete and maintain suitable and sufficient Type 3 Fire Risk Assessments in line with PAS 79 (Fire Risk Assessment - Guidance and a recommended methodology).

5.1.2. Caring Circle Homes Ltd will ensure that only suitably competent fire risk assessors or fire safety engineers undertake fire safety assessments or works for Caring Circle Homes Ltd.

5.1.3. Caring Circle Homes Ltd will ensure that all fire risk assessments are reviewed no later than the review date set by the fire risk assessment and that this review is carried out by a competent fire risk assessor.

5.1.4. Caring Circle Homes Ltd will ensure that the fire risk assessment to a building is reviewed following a fire, change in building use, change in working practices that may affect fire safety, following refurbishment works to the building or if required following an independent fire safety audit and that this review is carried out by a competent fire risk assessor.

5.1.5. Caring Circle Homes Ltd will ensure that all fire risk assessments are undertaken every 12, 24 or 36 months dependant on the level of risk set out in the NFCC Specialist Housing Guidance.

5.1.6. Caring circle homes ltd will maintain accurate building records in relation to fire safety, setting out the requirements for servicing, maintenance and repair of fire prevention, detection and firefighting equipment. These include but are not limited to: fire alarm systems, emergency lighting, smoke/heat detectors, hose reels, dry and wet risers, auto window/door openers, fire extinguishers, fire blankets, sprinkler systems and any other equipment relating to fire safety.

5.1.7. Caring Circle Homes Ltd will provide relevant fire safety information and ensure adequate training has been given to persons occupying or working in Caring Circle Homes Ltd locations.

5.1.8. Caring Circle Homes Ltd will ensure all fire safety, electrical and mechanical equipment within Caring Circle Homes Ltd properties are regularly maintained, and records kept in line with relevant legislation and HSE guidance. This includes cyclical servicing and inspections of gas and electrical installations within flats.

5.1.9. Caring Circle Homes Ltd will ensure that all private landlords provide a current gas safety servicing certificate, taking enforcement action where necessary under the terms of their lease.

5.1.10. Caring Circle Homes Ltd will ensure that private landlords responsible for the maintenance of the properties provide a copy of a valid satisfactory electrical installation condition report (EICR) without C1 or C2 works being required. An EICR is an inspection undertaken by a competent electrician, to assess an electrical installations condition and safety, listing deficiencies to be addressed. C1 deficiencies pose an immediate threat to health and safety, typically being addressed before electrician leaves site; C2 deficiencies pose a potential risk to health and safety and are typically addressed within 30 days.

5.1.11. Caring Circle Homes Ltd will ensure that where any hot works, such as soldering, take place in Caring Circle Homes Ltd properties, the necessary Risk Assessment Method Statement (RAMS) and hot work permits are completed and provided by contractors. Where work has commenced without necessary documentation being provided, operatives will be told to stop work.

5.1.12. Caring Circle Homes Ltd will prohibit smoking within its properties or near any entrances, ensuring signage is clear, and will work with tenants to ensure all restrictions are adhered to.

5.1.13. Caring Circle Homes Ltd will prohibit the storage of belongings in common areas, including but not limited to furniture, rubbish, flammable liquids, bicycles and scooters.

5.2. Protection

5.2.1. Caring Circle Homes Ltd will provide and maintain a fully automatic fire alarm system, where appropriate, to detect fire.

5.2.2. Caring Circle Homes Ltd will ensure that robust processes are in place to implement all mandatory fire precaution measures identified by fire risk assessments. Actions will be classified as high, medium or low risk. These recommendations will be reflected in an annual programme of works to be completed within a reasonable time scale (high risk 0-3 months, medium risk 0-6 months and low risk 0-12 months). Caring Circle Homes Ltd will also give due consideration to all nonmandatory recommendations.

5.2.3. Caring Circle Homes Ltd will delegate any statutory compliance inspections to Care Providers (CPs) where they are competent to complete them. These may include but are not limited to emergency lighting flick tests, function checks to manual call points, release checks for any hold open devices, fire alarm panel function checks and fire door assemblies.

5.2.4. Caring Circle Homes Ltd will provide and maintain emergency lighting, where appropriate, which will operate in the event of a circuit or sub-circuit failure, to facilitate safe evacuation and effective fire response.

5.2.5. Caring Circle Homes Ltd will provide and maintain primary compartmentation to limit the spread of fire through buildings and secondary compartmentation to protect escape routes, and ensure that this is adequately maintained in line with the fire risk assessment.

5.2.6. Caring Circle Homes Ltd will provide firefighting equipment in higher-risk areas, where appropriate, to enable trained staff and contractors to secure their means of escape if required.

5.2.7. Where firefighting equipment is provided, Caring Circle Homes Ltd will ensure its staff and the CP will ensure that their staff on site have received appropriate training in its use, and that communication is clear to ensure that untrained people do not attempt to use the equipment.

5.2.8. Caring Circle Homes Ltd will implement a programme of regular property inspections to all of its properties with a fire risk assessment in place, to verify that all required management procedures (evacuation plans, Personal Emergency Evacuation Plans [PEEPs] etc.) and statutory compliance inspections (fire doors, emergency lighting etc) are in place and taking place.

5.2.9. These inspections will be undertaken at regular intervals by Caring Circle Homes Ltd Housing Officers and records will be kept against each property. A full list of the roles and responsibilities can be found under the Key Roles and Responsibilities section.

5.2.10. Any repairs or rectification works arising from the locally completed checks will be reported by the CP to Caring Circle Homes Ltd principal repairs contractor and remediation will be delivered in line with the repairs policy.

5.2.11. Caring Circle Homes Ltd will take action alongside the CP to remove items left along escape routes and by fire exits.

5.2.12. Where appropriate, CPs will maintain a signing in/out process for all visitors to Caring Circle Homes Ltd’s premises.

5.3. Intervention

5.3.1. Caring Circle Homes Ltd will provide assistance and guidance to occupants and CPs to support adherence to this policy.

5.3.2. Caring Circle Homes Ltd will assist CPs in developing PEEPs and keeping property information packs up to date, ensuring significant hazards such as oxygen cylinders have been clearly identified.

5.3.3. In line with Caring Circle Homes Ltd Disaster Recovery Plan, in the event of a fire Caring Circle Homes Ltd will ensure information is cascaded to all relevant Caring Circle Homes Ltd personnel involved with supporting residents or remediating fire, smoke or water damage, and will also ensure that any information collected by attending officers is shared with internal stakeholders and emergency services as appropriate.

6. Key Roles and Responsibilities

Role Responsibility

Caring Circle Homes Ltd Board will have overall governance responsibility for ensuring the fire safety policy is fully implemented to ensure full compliance with the regulatory standards, legislation and codes of practice. As such, the Board will formally approve this policy and review it every two years (or sooner if there is a change in regulation, legislation or codes of practice). Head of Property and Assets The Head of Property and Assets (HoP) has strategic responsibility for the management of fire safety and ensuring compliance is achieved and maintained. The HoP will oversee the implementation of the fire safety policy with operational support from a suitably competent deputy. Repairs and Compliance Manager The Repairs and Compliance Manager will be responsible for overseeing the delivery of the agreed fire risk assessment and re-assessment programmes, and the prioritisation and implementation of any works arising from the fire risk assessments. They will also be responsible for overseeing the delivery of service, maintenance and repair programmes to all fire detection, alarms and firefighting equipment within property assets owned or managed by Caring Circle Homes Ltd. Head of Housing The Head of Housing, via their team of Housing Officers, will provide key support in gaining access into properties where access is proving difficult. They will also facilitate the legal process to gain access as necessary. Caring Circle Homes Ltd Building Surveyors will undertake fire risk assessments and produce any necessary reports. Housing Officers will complete regular property visits, auditing the local management procedures and completion of statutory compliance inspections where delegated.

Care Providers will select a suitable responsible person for each location in charge of ensuring the completion of delegated statutory inspections as requested by Caring Circle Homes Ltd. Inspections may include:

• Weekly Fire Alarm testing;

• Monthly emergency lighting flick test;

• Monthly visual check of firefighting equipment including fire blankets;

• Monthly fire door inspections;

• 6-monthly fire evacuation drills;

• Creation of a fire logbook to store all pertinent information to be made available for review upon request. CPs will also be responsible for:

• Creating a suitable and sufficient fire evacuation plan, and for making this available for review by Caring Circle Homes Ltd staff upon request;

• Creating PEEPs where needed for any resident and ensuring that the evacuation plan is updated to reflect any changes;

• Reporting any required repairs to Caring Circle Homes Ltd's appointed principal contractor in timely manner;

• Ensuring all CP staff are adequately trained to complete the statutory inspections delegated to them and that all training records are made available for inspection.

7. Performance Monitoring and Reporting

7.1. Robust key performance indicator (KPI) measures will be established and maintained to ensure Caring Circle Homes Ltd is able to report on performance in relation to fire safety.

7.2. KPIs will be produced and reported to the Executive Team and Board monthly. As a minimum, these KPIs will include:

• The percentage of properties with a valid and in-date fire risk assessment (FRA) in place, for all buildings owned or managed by Caring Circle Homes Ltd which require one. The number of properties accounting for any result less than 100% will also be disclosed, along with an explanation as to why the properties do not have a valid FRA at the time of reporting

• The number of high, medium and low level actions outstanding (in time or overdue) from FRAs

8. Managing Non-Compliance

8.1. Any issues of non-compliance with this policy that are identified at an operational level will be formally reported to the Head of Property and Assets in the first instance.

8.2. The Head of Property and Assets will agree an appropriate course of corrective action with the operational team in order to address the non-compliance issue and report details of the same to the Executive Team.

8.3. The Executive Team will ensure the Board is made aware of any unresolved non-compliance issues so they can consider the implications and take action as appropriate.

8.4. In the event of a serious non-compliance issue, the Executive Team and Board will consider whether it is necessary to disclose the issue to the Regulator of Social Housing (RSH) in the spirit of co-regulation as part of the Regulatory Framework.

9. Linked Policies

9.1. This policy is linked to the following documents and should be read in conjunction:

• Electrical Safety Policy

• Gas Safety Policy

• Health and Safety Policy

10. Policy Review

10.1. This policy will be reviewed every two years.

1. Introduction

1.1. Caring Circle Homes Ltd is responsible for maintenance and repairs to its homes and other buildings in management, many of which will contain gas installations and appliances. The Gas (Installation and Use) Regulations 1998 and the Amendment Regulations 2018 specifically deal with the installation, maintenance and use of gas appliances, fittings and flues in domestic properties and certain office premises.

1.2. The regulations also place a legal duty on landlords to ensure that all gas appliances, including fittings and flues, provided for tenants’ use are safe.

2. Purpose

2.1. The purpose of this Policy is to ensure Caring Circle Homes Ltd meets the requirements of the Gas Safety (Installation and Use) Regulations 1998. In addition to this, the policy also provides assurance to Caring Circle Homes Ltd that measures are in place to ensure compliance with these regulations and to identify, manage and/or mitigate risks associated with gas fittings, appliances and flues.

3. Scope

3.1. This policy applies to all buildings and associated structures either owned, leased, occupied or managed by Caring Circle Homes Ltd.

3.2. The policy is relevant to all types of gas appliances that Caring Circle Homes Ltd has responsibility for and applies to all Caring Circle Homes Ltd employees, tenants, contractors and other persons or other stakeholders who may work on, occupy, visit, or use its premises, or who may be affected by its activities or services.

4. Legal and Regulatory Responsibilities

4.1. Regulatory Standards

The application of this policy will ensure compliance with the regulatory framework and Safety and Quality Standard for social housing in England, which applies from 1 April 2024.

4.2. Core Legislation

The principle legislation applicable to this policy is The Gas Safety (Installation and Use) Regulations 1998 (as amended). Caring Circle Homes Ltd has a legal obligation under Part F, Regulation 36 of the legislation (Duties of Landlords) and is the ‘Landlord’ for the purposes of the legislation. Caring Circle Homes Ltd is the ‘Landlord’ by virtue of the fact that it owns and manages homes and buildings housing tenants through the tenancy and licence agreement obligations it has with its tenants.

4.3. Other Legislation

This policy also operates in the context of the following legislation:

• Health and Safety at Work Act 1974

• The Management of Health and Safety at Work Regulations 1999

• The Workplace (Health Safety & Welfare) Regulations 1992

• Gas Safety (Management) Regulations 1996 (as amended)

• The Building Regulations in England & Wales

• Dangerous Substances and Explosive Atmospheres Regulations 2002

• Pressure Equipment Regulations 1999

• Pressure Systems Safety Regulations 2000

• Pipelines Safety Regulations 1996Heat Network Regulations 2014

• Provision and Use of Work Equipment Regulations 1998

• Construction, Design and Management Regulations 2015

• Landlord and Tenant Act 1985 Gas Safety (Installations and Use) Regulations 1988 as amended by Gas Safety (Installation and Use) (Amendment) Regulations 2018

• Homes (Fitness for Human Habitation) Act 2018

4.4. The Gas Safety (Installation and Use) (Amendment) Regulations 2018 impose duties on landlords to protect tenants’ safety in their homes with respect to gas safety. The main duties as a landlord are set out in Regulation 36 requiring landlords to:

• Ensure gas fittings and flues are maintained in a safe condition. Gas appliances should be serviced in accordance with the manufacturer’s instructions. If these are not available, it is recommended that they are serviced annually unless advised otherwise by a Gas Safe registered engineer;

• Ensure the annual safety check is carried out on each gas appliance and flue within 12 months of the previous safety check;

• Have all installation, maintenance and safety checks carried out by a Gas Safe registered engineer Keep a record of each safety check for at least 2 (two) years;

• Issue a copy of the latest safety check record to existing tenants within 28 days of the check being completed, or to any new tenant when they move in;

• Display a copy of the latest safety check record in a common area of a building where the gas appliance serves a communal heating system to multiple homes.

5. Codes of Practice

5.1. The principle codes of practice applicable to this policy are as follows:

• ACoP L56: ‘Safety in the installation and use of gas systems and appliances’ (5th edition 2018)

• INDG285: ‘A guide to landlords’ duties: Gas Safety (Installation and Use) Regulations 1998’

6. Caring Circle Homes Ltd  Approach

6.1. Caring Circle Homes Ltd acknowledges and accepts its responsibilities under the Gas Safety (Installation and Use) Regulations 1998 as amended.

6.2. In order to meet these requirements, Caring Circle Homes Ltd will:

• Hold accurate records against each property it owns or manages setting out the requirements for gas and/or heating safety checks and servicing of all gas/heating fittings, appliances and flues;

• Require a gas contractor to visit all properties on an annual basis to carry out gas and/or heating safety checks, irrespective of whether the property has a gas supply or not;

• Ensure that each property requiring a gas safety check and/or service has a landlord’s gas safety record (LGSR) that has a completion date not more than 12 months following the completion date of the previous LGSR relating to the property, or from the installation date of new installations;

• Ensure that copies of all LGSRs are provided to tenants within 28 days of completion or displayed in a common area;

• Cap off gas supplies to all properties when the property becomes void and a new tenant is not due to move in immediately following the previous tenant leaving;

• Cap off gas supplies to all new build properties at handover if a new tenancy is not commencing immediately at the point of handover.

• Reinstate gas supplies to void properties and new build properties at commencement of the new tenancy and will undertake a gas safety check and issue a new LGSR.

• Ensure that gas safety checks are carried out prior to, or immediately following the commencement of any new tenancy (void properties), mutual exchange and/or transfer and that the tenant receives a copy of the LGSR prior to, or immediately upon sign up of the tenancy and/or at the time of moving in;

• Carry out gas safety checks of any of the tenants’ own gas appliances and will carry out a five-point visual safety check for gas cookers and service to gas fires where the manufacturers’ instructions are available (location, fluing, ventilation, signs of distress and stable and secure). Where appliances are found to be faulty these will be disconnected and a warning notice issued;

• Test and replace as necessary the CO alarm as part of the annual gas safety check visit;

• Carry out an annual gas safety check to all properties where the gas supply is inactive (capped) due to a previous request made by a tenant. This is to ensure that gas supplies have not been reconnected by the tenant;

• Carry out annual assessments of properties where tenants have chosen for personal reasons not to use the gas supply in the property. This is to check on the tenant’s wellbeing and also to assess that the lack of gas heating is not adversely affecting the condition of the property;

• Ensure that only suitably competent Gas Safe accredited engineers undertake gas works for the organisation;

• Remove any open flue gas appliances found in any rooms that are being used as bedrooms;

• Carry out a gas safety check following any new gas appliance installation. The safety check will include a gas soundness test of the system pipework, a visual inspection of the meter installation and a visual inspection including the safe working operation on all other gas appliances and associated flues within a property, as well as issuing a gas safety certificate to confirm the necessary checks have been completed;

• Ensure that robust processes and controls are in place to manage works to void and occupied properties that may affect existing gas installations;

• Have a robust process in place to gain access to properties where tenant vulnerability issues are known or identified whilst ensuring the organisation can gain timely access to any property in order to be compliant with this policy and safeguard the wellbeing of the tenant;

• Establish and maintain a plan of all continuous improvement activity undertaken with regards to gas safety.

6.3. Ordinarily, Caring Circle Homes Ltd will not carry out the annual gas safety checks on properties leased from private landlord properties, except where there are explicit clauses within the leases requiring Caring Circle Homes Ltd to carry out gas safety checks.

6.4. Instead, Caring Circle Homes Ltd will seek a copy of the LGSR from the private landlord as evidence of completion; however, where the LGSR is not supplied and Caring Circle Ltd has reason to believe the existing certificate has expired, or a new installation or alteration has been made that would require a new certificate to be obtained, Caring Circle Ltd will instruct a gas contractor to visit the property to complete a gas safety check.

6.5. Caring Circle Homes Ltd will seek to recover this cost from the landlord.

7. Inspection Testing Programmes

7.1. Domestic properties

Caring Circle Homes Ltd will carry out a programme of annual gas safety checks and services to all domestic properties, covering all heating types. This check will include all gas fittings, appliances and flues in the property and will be completed 12 months from the date of the previous LGSR. This safety check is driven from the anniversary date of the most recent LGSR which may have been carried out at the start of a new tenancy or following installation of new gas appliances.

7.2. Other properties (offices/communal areas)

Caring Circle Homes Ltd will carry out a programme of annual gas safety checks and services to all ‘non-domestic’ and ‘other’ properties (where it has the legal obligation to do so). These checks will include all gas fittings, appliances and flues in the property and will be completed no longer than 12 months from the date of the previous LGSR or as detailed within manufacturer’s instructions. These safety checks and maintenance services will be carried out by a suitably competent engineer in accordance with the manufacturer’s instructions. These installations may include catering equipment, boilers serving communal heating systems, combined heat and power systems, pressure vessels and water heating boilers.

8. Compliance Follow Up Work

8.1. Caring Circle Homes Ltd will ensure that there is a robust process in place to collate and store all warning notices and associated records of completed remedial works.

8.2. A safety check will be carried out on completion of any repair and/or refurbishment works to occupied or void properties where works may have affected any gas fittings, appliances or flues.

8.3. Caring Circle Homes Ltd will ensure there is a robust process in place to investigate and manage all RIDDOR notices issued with regard to gas safety.

9. Securing Access to Tenants’ Properties

9.1. Customers have an obligation as per their tenancy agreement to ensure their home is kept to an acceptable standard and allow access to inspect and/or carry out any works, including gas compliance works.

9.2. In cases where access has not been granted to complete the annual gas safety and/or heating inspection, a controlled entry may be made to ensure the safety of all our customers and neighbouring properties. A member of the Executive Team will approve any such action.

9.3. As a last resort, Caring Circle Homes Ltd will use all legal remedies available to it should any tenant refuse access to carry out essential gas safety checks, maintenance and safety related repair works.

10. Key Roles and Responsibilities

10.1. Caring Circle Homes Ltd Board will have overall governance responsibility for ensuring the gas safety policy is fully implemented to ensure full compliance with the regulatory standards, legislation and codes of practice. As such the Board will formally approve this policy and review it every two years (or sooner if there is a change in regulation, legislation or codes of practice).

10.2. The Executive Team and Board will receive reports in respect of gas safety management performance and ensure compliance is being achieved. They will also be notified of any noncompliance issue identified.

10.3. Caring Circle Homes Ltd Board is responsible for ensuring it is fully assured of compliance measures, monitoring performance and that the policy is implemented and adequately resourced.

10.4. The Chief Executive Officer is responsible for implementing, resourcing this policy and monitoring performance.

10.5. The Head of Property and Assets has strategic responsibility for the management of gas safety and ensuring compliance is achieved and maintained monitored and reported upon. The Head of Property and Assets will oversee the implementation of the gas safety policy, with the operational support of the Compliance Manager.

10.6. The Head of Property and Assets will be responsible for overseeing the delivery of the gas servicing and safety check programmes; completion of any works arising from gas safety checks or reported by tenants and the maintenance of sufficient records in respect of works completed to gas appliances, fittings and flues.

10.7. The Maintenance and Compliance Manager will act as deputy and support to the Head of Property and Assets.

10.8. The Head of Housing will provide key support in gaining access into properties where access is proving difficult and use standard methods to do so. They will also facilitate the legal process to gain access as necessary.

10.9. will ensure that only suitably competent Gas Safe accredited contractors are Caring Circle Homes Ltd and appointed to undertake works to gas fittings, appliances and flues.

10.10. Where sub-contractors are engaged by Caring Circle Homes Ltd repairs contractor, responsibility for ensuring the sub-contractor is appropriately qualified and accredited for the work that they are carrying out resides with the repairs contractor. Caring Circle Homes Ltd may request periodic audits to ensure that the repairs contractor holds this information.

11. Performance Reporting

11.1. Robust key performance indicator (KPI) measures will be established and maintained to ensure Caring Circle Homes Ltd is able to report on performance in relation to gas safety, and these will be reported to the Executive and Caring Circle Homes Ltd Board monthly.

11.2. As a minimum, these KPI measures will include the percentage of all unexpired gas safety certificates held by Caring Circle Homes Ltd as a proportion of the total number of domestic properties with gas appliances, with a target of 100% completion at all reporting dates.

11.3. Any RIDDOR incidents linked to gas supplies or appliances will also be reported to the Executive and Caring Circle Homes Ltd Board at the first opportunity, with appropriate narrative.

12. Non-Compliance

12.1. Any non-compliance issue identified at an operational level will be formally reported to the Head of Property and Assets in the first instance.

12.2. The Head of Property and Assets will agree an appropriate course of corrective action and report details of the same to the Executive Team.

12.3. The Executive Team will ensure the Board is made aware of any non-compliance issue so it can consider the implications and act as appropriate.

12.4. In cases of a serious non-compliance issue the Executive Team and Board will consider whether it is necessary to disclose the issue to the Regulator of Social Housing in line with Caring Circle Homes Ltd Escalations Protocol.

13. Record Keeping

13.1. Caring Circle Homes Ltd will:

• Establish and maintain a core asset register of all properties that have an active or inactive gas supply. This register will also hold data against each property asset of gas heating inspection and servicing requirements, where applicable, for all domestic and non-domestic property assets;

• Ensure the Gas Safe registered engineer records the details of all appliances and other equipment which is served by the gas supply in every domestic and non-domestic property;

• Establish and maintain accurate records of all completed safety records, warning notices and associated remedial works and keep these for a period of not less than two years.

• Hold and maintain accurate records on the qualifications of all engineers undertaking gas works for the organisation, or require that its repairs contractor holds this information and can provide it to Caring Circle Homes Ltd upon request;

• Ensure robust processes and controls are in place to provide and maintain appropriate levels of security for all gas safety related data.

14. Linked documents

14.1. This policy is linked to the following documents and should be read in conjunction:

• Health and Safety Policy

15. Policy Review

15.1. This policy will be reviewed every two years.

1. Introduction

1.1. Caring Circle Homes Ltd recognises the requirement to comply with the Health and Safety at Work etc. Act 1974, Management of Health and Safety at Work Regulations 1999 and all other associated legislation, Approved Codes of Practice and guidance.

1.2. Caring Circle Homes Ltd Health and Safety Policy details how we will achieve and demonstrate our commitment to occupational health and safety, and establishing and maintaining suitable and sufficient safety arrangements.

2. Purpose

2.1. The aim of this Policy is to ensure the safety of employees, staff working at our properties, tenants, members of the public and contractors.

3. Linked policies

3.1. The following policies are concerned with specific areas of health and safety in our tenants’ homes, and should be read in conjunction:

• Asbestos Management Policy

• Damp and Other Hazards Policy

• Electrical Safety Policy

• Fire Safety Policy

• Gas Safety Policy

• Lift Safety Policy

• Repairs and Maintenance Policy

• Water Safety Policy

4. Health and safety policy statement

4.1. Caring Circle Homes Ltd recognises that as a priority, employees should be safe in their job roles and residents should be safe in their homes. Caring Circle Homes Ltd undertakes to do everything reasonably practicable to protect the health and safety of employees, residents, property, staff and visitors through the implementation and maintenance of safe systems of work.

5. Responsibilities

5.1. So far as is reasonably practicable, Caring Circle Homes Ltd will:

• Ensure all our properties are maintained in a safe condition and any risks to our tenants, employees, partners and other visitors have been fully considered and addressed. In doing this, Caring Circle Homes Ltd acknowledges that some of our tenants have very specific health and safety considerations

• Ensure all places of work are maintained in a safe condition, without risks to health

• Encourage tenants to report incidents

• Ensure incidents are investigated thoroughly and promptly to identify immediate, route and underlying causes and, where possible, to ensure measures are implemented to reduce or eliminate recurrence

• Ensure employees are trained in general health and safety awareness and receive specific training instruction, information and supervision relating to hazards and safe practices

• Ensure risk assessments are undertaken for hazardous work activities and that they are reviewed regularly, including asbestos surveys, fire risk assessments, gas and electrical works, and in respect of all work carried out by Caring Circle Homes Ltd contractors that visit its properties

• Ensure that safe systems of work are implemented for hazardous activities

• Ensure that contractors (and sub-contractors) and suppliers are committed to achieving and adhering to the standards of health and safety detailed in this Policy and their own method statements and risk assessments

• Ensure that health and safety is considered at all Board meetings

• Encourage Care Provider staff working at Caring Circle Homes Ltd properties and other interested parties to take responsibility for health and safety management

• Carry out monthly visits to all of our properties, during which any health and safety issues will be highlighted to the property staff for remediation

5.2. All employees have a duty to co-operate in the operation of this Policy by:

• Taking reasonable care of their own safety and that of their colleagues, tenants, employees, members of the public and contractors by complying with this Policy and all policies and procedures that are relevant to their role

• Not interfering with, misusing, or wilfully damaging anything provided by Caring Circle Homes Ltd in the interests of health and safety

• Training property staff to report incidents that have led, or may lead, to injury/damage to people, property, plant or equipment

• Attending training courses appropriate to their role and responsibilities as and when necessary

5.3. To ensure this Policy is effective, Caring Circle Homes Ltd will:

• Review it at regular intervals and when significant changes are made to health and safety legislation, guidance, related policies and procedures or within Caring Circle Homes Ltd

• Immediately make any amendments known to employees

• Produce this Policy and related procedures in alternative formats as and when necessary

6. Lone workers

6.1. Many of Caring Circle Homes Ltd employees will meet the definition of a lone worker during the course of their employment.

6.2. Caring Circle Homes Ltd Lone Working Policy details additional health and safety considerations and responsibilities for Caring Circle Homes Ltd and employees who are lone workers.

7. Policy review

7.1. This policy will be reviewed every year.

1. Introduction

1.1. This policy details Caring Circle Homes Ltd repairs and maintenance service, covering both the standards and delivery that can be expected by our customers and service providers.

1.2. Effective maintenance is a critically important and high-demand service for service providers and their customers. It is vital that a cost-effective service is delivered which meets the diverse needs of our customers and service providers.

2. Purpose

2.1. The purpose of this policy is to:

• Ensure that all properties are maintained to a high standard

• Ensure that our customers and service providers live and work in homes which are safe and comfortable

• Ensure that high standards of customer care are achieved

• Ensure customers know what to expect from our service

• Provide users with a service which is appropriately tailored to their needs

• Adhere to relevant statutory compliance obligations

• Provide an efficient responsive repairs service

• Provide a value for money service whilst meeting regulatory requirements

• Ensure active asset management is implemented to maximise efficiencies

3. Scope

3.1. This policy applies to the delivery of all Repairs and Maintenance obligations and the requirement to meet the Decent Homes Standard in respect of all buildings and associated structures either owned, leased, occupied or managed by Caring Circle Homes Ltd.

3.2. This policy applies to all employees, supplies and contractors who undertake repairs and maintenance work on Caring Circle Homes Ltd properties.

4. Legal and regulatory responsibilities

4.1. The policy complies with all relevant statutory provisions and will be updated to consider any future relevant legislation.

4.2. The policy complies with the Regulatory requirements set by the Regulator of Social Housing (RSH) and more specifically the Safety and Quality Standard.

5. Reporting of repairs

5.1. Customers and service providers can report a non-emergency repair

• By phone, on 0115 9298308

5.3. Where requests for repairs are notified to Caring Circle Homes Ltd colleagues, including Housing Officers when on-site visits.

5.4. Customers and service providers should report an emergency repair by phone on 01159298308. An out-of-hours service is available via this number for all emergency repair calls received outside of normal office hours.

5.5. An emergency repair is defined as any repair that is required to sustain the immediate health, safety or security of the customer at risk, or that materially affects the structure of the property or those around it. A list of repairs that are usually considered as emergency repairs is shown at 6.2.

6. Repair priorities

6.1. All repairs will be prioritised based on an assessment of the following criteria:

• Health and Safety risk to persons or property of the fault being reported

• The vulnerability of the customer's reporting the fault

• Access to the property and/or location of the fault

6.2. The following items are ordinarily considered to be emergency repairs:

• Loss of entire supply of electricity, and/or water and/or gas

• Loss of entire heating provision

• Loss of hot water facilities where customer’s health condition or vulnerability requires regular bathing and where there is no electric shower

• All serious plumbing leaks where the property structure is in danger of damage

• Report of a gas escape

• Serious structural failures

• Issued concerning the security of the property

• Broken glazing to windows

• Blocked toilet where it is the only toilet in the property

• Main drain to property is blocked

• Repairs to communal door entry systems where controlled access is required

• Out of service lifts including stair lifts

• Customer locked out of home

• Mains smoke alarm and/or carbon monoxide (CO) alarm faulty

6.3. This list is not exhaustive and other items may be considered to be emergency repairs, depending on the needs of the individual customer(s) impacted.

6.4. In addition, some of Caring Circle Homes Ltd's leases and tenancy agreements may list other items as being emergency repairs.

7. Repair response times

7.1. All repairs are prioritised as per the table below, with the timescale for remediation shown alongside each category:

• Priority Timescales (days)

• OOH (Out of Hours) Same day (make safe)

• P1 1 (within 24 hours)

• P2 7

• P3 28

• Planned Works 90

7.2. Caring Circle Homes Ltd and its repairs contractor use a fluid decision making process to apply priorities to repairs, combining the nature of the issue with the tenant risk to determine the urgency of works. For example, a broken external door in a property facing a busy road which houses a tenant under a Deprivation of Liberty Order will require a faster response than a broken external door in a block of flats occupied by adults with capacity.

7.3. The requirement to complete emergency repairs within 24 hours is in line with Caring Circle Homes Ltd obligations under Awaab’s Law.

8. Repair appointments

8.1. Caring Circle Homes Ltd repairs contractor will determine the priority code of a repair at the point that the repair is reported to them.

8.2. Emergency repairs will be attended to the same day to make safe as per the table at 7.1.

8.3. Wherever possible, all remediation works required by an emergency repair (i.e. works to restore full service, not just making safe) will be completed on attendance. However, in circumstances where this is not possible, a follow-up appointment will be raised and the customer will be informed of the timescale for completed as per the table at 7.1.

9. Rechargeable repairs

9.1. Current and former customers will be recharged where repairs (including emergency repairs) are required because of negligence, deliberate or accidental damage. Caring Circle Homes Ltd will take into account mitigating factors and individual circumstances before a final decision is reached on whether or not to recharge a customer.

9.2. Where a recharge is made, an administration charge of 5% + VAT of the total repair cost will be made, with the charge capped at £20 + VAT.

10. Customer repair responsibilities – reporting

10.1. Customers are responsible for reporting any defects in their home as soon as they become apparent, so that a repair can be scheduled before any damage becomes more serious.

10.2. However, there are some types of repair that Caring Circle Homes Ltd would never undertake, and that would therefore be the responsibility of the customer or service provider.

10.3. Examples of such repairs are as follows:

• Repairs to unauthorised alterations carried out by a customer or service provider

• Changing easily accessible light bulbs

• Gritting

• Cleaning or gardening outside of the agreed specification

11. Customer repair responsibilities – access to property

11.1. Customers have an obligation as per their tenancy agreement to ensure their home is kept to an acceptable standard and allow access to inspect and/or carry out any works. Caring Circle Homes Ltd, through their contractors, will confirm with the customer the appointment for the repair work. The customer and service provider must provide access at the requested time and date.

11.2. Caring Circle Homes Ltd will not tolerate any instances of a member of staff or a contractor being threatened or intimidated when visiting or working in a customer’s home. If this happens, the work will be stopped and the staff member/contactor will leave the property. The incident will be reported to the appropriate teams and tenancy enforcement action will be taken where necessary.

11.3. Alternative arrangements to complete the repair will be made where possible; however, this will take into account an assessment of whether the threat or intimidation is likely to reoccur on the subsequent visit.

11.4. Health and safety compliance activity is a top priority and so Caring Circle Homes Ltd operates a robust access procedure for undertaking statutory compliance checks such as water hygiene, gas and electrical servicing activities. Legal enforcement action will be taken if necessary to complete these activities.

12. Requests for alterations

12.1. Caring Circle Homes Ltd will take a reasonable approach when considering a request for alterations. If the request is likely to cause a financial impact to Caring Circle Homes Ltd then this request will generally be refused, unless the customer is able to fund the works themselves or can obtain third-party funding.

12.2. If the alteration requested would not be compliant with health and safety law / regulations, then the request will always be refused.

12.3. Further information can be found in Caring Circle Homes Ltd Adaptations and Equipment Policy.

13. Customer feedback

13.1. Caring Circle Homes Ltd will provide a range of opportunities for customers to provide feedback on the Repairs and Maintenance service and will look to use this information to improve this service wherever possible.

14. Caring Circle Homes Ltd inspection of internal communal areas

14.1. As part of Caring Circle Homes Ltd programme of monthly visits to properties, inspections of internal communal areas will take place, to identify any property-related repairs that may be required.

14.2. Where these have not already been reported, the Caring Circle Homes Ltd colleague who identifies the issue will be responsible for reporting the repair.

15. Health and Safety compliance

15.1. In addition to completing day-to-day and emergency repairs, Caring Circle Homes Ltd is also responsible for ensuring its properties remain safe and compliant with various health and safety standards, including gas, electrical, fire, asbestos, lifts and water safety.

15.2. All appointments for compliance testing works, as well as any follow-up appointments for remediation will be arranged between Caring Circle Homes Ltd and the customer/service provider, with a mutually convenient time agreed.

15.3. Caring Circle Homes Ltd has published various policies covering health and safety compliance works which contain more details of the responsibilities of Caring Circle Homes Ltd and its customers.

16. Decent Homes Standard compliance

16.1. Caring Circle Homes Ltd must also ensure all its properties meet the Decent Homes Standard in order for them to be considered lettable.

16.2. The Decent Homes Standard requires all of the following conditions to be met for each property:

1. It meets the current statutory minimum standard for housing

2. It is in a reasonable state of repair

3. It has reasonably modern facilities and services

4. It provides a reasonable degree of thermal comfort

16.3. To meet condition 1., a property must be free of category 1 hazards unless practical steps to remediate them cannot be taken without disproportionate expense or disruption. Where a hazard cannot be dealt with effectively, Caring Circle Homes Ltd will ensure that all occupiers are fully aware of the position.

16.4. A property will meet condition 2. unless one or more key building components are old and, because of their condition need replacing or major repair, or where two or more other building components are old and, because of their condition need replacing or major repair.

16.5. A building component cannot fail condition 2. based on age alone, it must also require replacing or repair.

16.6. A property is not considered to meet condition 3. if it lacks three or more of the following facilities:

• A reasonably modern kitchen (20 years old or less)

• A kitchen with adequate space and layout

• A reasonably modern bathroom (30 years old or less)

• An appropriately located bathroom and WC

• Adequate insulation against external noise

• An adequate size and layout of common areas for blocks of flats

16.7. Condition 4. requires all properties to have both efficient heating and effective insulation. The exact requirements will vary by property according to condition, age and the source of heating/insulation in place.

16.8. Caring Circle Homes Ltd completed a stock condition survey of all of its properties during 2020 to determine whether they met the Decent Homes Standards. Where deficiencies were identified, a programme of investment was agreed between Caring Circle Homes Ltd and its landlords to ensure all properties were brought up to this standard.

16.9. In order to maintain compliance with the Decent Homes Standard, Caring Circle Homes Ltd operates a rolling programme of completing stock condition surveys across 20% of its portfolio every year, meaning that all properties are surveyed at least once every five years. This survey programme ensures that all data is refreshed and tested on a regular basis in line with the Decent Homes Standard as well as current good practice and sector guidance.

16.10. All properties will be visited during this period by a surveyor competent in the collection of building metrics and building surveying. Age and condition data will be collected on all building components that have a defined lifespan.

16.11. The scope of the survey encompasses all internal and external areas of each building, and the resolution of any immediate Health and Safety concerns (HSRR Category 1) that are identified will be managed through the repairs contractor as emergency repairs.

16.12. As part of the process of assessing potential new properties, Caring Circle Homes Ltd conducts pre-handover inspections to ensure that they meet the Decent Homes Standard. Where issues are identified, Caring Circle Homes Ltd will refuse to accept handover until they are resolved satisfactorily.

17. Void properties

17.1. Where a property becomes vacant, Caring Circle Homes Ltd will determine what works are required to bring the property back into a lettable condition as per Caring Circle Homes Ltd Void Policy.

18. Linked documents

18.1. This policy is linked to the following documents and should be read in conjunction:

• Adaptations and Equipment Policy

• Asbestos Management Policy

• Damp and Other Hazards Management Policy

• Electrical Safety Policy

• Fire Safety Policy

• Gas Safety Policy

• Health and Safety Policy

• Lift Safety Policy

• Voids Policy

• Water Safety Policy

19. Policy review

19.1. This policy will be reviewed every two years

1. Introduction

1.1. Water systems within blocks of flats and to individual dwellings need to be risk assessed, kept safe for use, and if required, be regularly maintained.

1.2. This policy explains how Caring Circle Homes Ltd's commitments to water safety will be met. It is supported by a Water Management Procedure providing more detailed guidance.

2. Purpose

2.1. As a Landlord and Employer, Caring Circle Homes Ltd are responsible for meeting all their statutory obligations. In addition, as a landlord and provider of Social Housing, we must meet the Regulatory Standards contained within the Regulator for Social Housing’s Regulatory Framework for Social Housing.

2.2. A key objective of this Policy is to describe how Caring Circle Homes Ltd will meet the required statutory, contractual and regulatory requirements in relation to water safety.

2.3. In addition, Caring Circle Homes Ltd must undertake a monitoring role to ensure that they are able to demonstrate a validated landlord compliance position, and in doing so, can provide assurance to other 3rd Parties that statutory and regulatory standards are being achieved.

2.4. Further objectives of this policy are detailed below:

• Provide clear lines of responsibilities for the management of water safety.

• Form part of Caring Circle Homes Ltd's wider organisational commitment to health and safety as set out in its Health and Safety Policy.

• To ensure that all persons involved with the installation, inspection and servicing of water systems and appliances are properly trained and accredited.

• Provide a commitment to customers and key partners (Care Providers) who are affected by water safety to communicate and raise awareness regarding the key issues.

• Put in place quality assurance and performance management arrangements to ensure that we are delivering excellent services to our customers.

• To provide a timetable for the review of the Water Safety Policy and the associated Management Plan.

• Provide a service that recognises the diversity of our customers as well as being inclusive and respectful.

• To ensure Caring Circle Homes Ltd provide a safe environment for customers, colleagues and third parties to live and/or work.

3. Scope

3.1. This policy relates to offices, specialist supported housing, and other rented properties either owned or managed by Caring Circle Homes Ltd, unless other parties are explicitly specified as having statutory responsibility in a lease or management agreement.

3.2. In addition to managing the potential risk arising from legionella, this Policy and the supporting Management Plan will cover risks from scalding.

4. Legal and regulatory responsibilities

4.1. The application of this policy ensures compliance with the regulatory framework for social housing in England, which requires all housing providers to ‘meet all applicable statutory requirements that provide for the health and safety of the occupants in their homes’.

4.2. Caring Circle Homes Ltd Supported Housing will comply with all current and relevant legislation and specifically as detailed in the following:

• The Health and Safety at Work Act 1974: This act places a duty on landlords to ensure, so far as is reasonably practicable, the health, safety, and welfare at work of all their employees, tenants and other users or visitors to our buildings.

• The HSE’s Approved Code of Practice L8: This code of practice provides advice on the control of Legionella bacteria in water systems.

• Control of Substances Hazardous to Health Regulations 2002 (COSHH)

• HSG274 - Legionnaires’ disease Part 2: The control of legionella bacteria in hot and cold water systems.

• Health Services Information Sheet No 6 - Managing the risks from hot water and surfaces in health and social care

4.3. Caring Circle Homes Ltd takes the view that delivery of the commitments within this policy will ensure that the requirements of other legislation, such as the Health and Safety at Work etc. Act 1974 and Landlord Tenant Act 1985 and The management of Health and Safety at Works Regulations 1999 will also be met.

5. Our Approach

5.1. Suitable and sufficient individual Legionella Risk Assessments will be undertaken for all water systems at corporate offices, existing locations, acquired premises and new build properties, by a competent person in accordance with the requirements set out in ACoP L8 and in line with HSG274.

5.1.1 All Caring Circle Homes Ltd properties will be categorised according to their potential risk to Legionella. This section details the approach Caring circle homes ltd will take in the conduct of Water Risk Assessments for each in order to minimise risk, so far as is reasonably practicable.

5.1.2 Caring Circle Homes Ltd categorise the water systems within its properties into the following distinct groups:

• Shared Water Systems

• Dwelling water systems - Shared Premises. No stored water

• Dwelling water systems - Shared Premises. Stored water

5.2. Scalding:

5.2.1 Temperatures for hot water are expected to exceed 50°c at outlets in order to control the risk of legionella. Where vulnerable groups are present bathing or showering at temperatures above 44°C creates an increased risk of serious injury or fatality. Vulnerable groups are those such as:

• Children

• Older People

• People with reduced mental capacity, mobility or temperature sensitivity

• People who cannot react appropriately or quickly enough to prevent injury.

5.3. Where a specific risk is thought to exist, Care Providers are asked to complete a scalding and burning risk assessment in line with Health Services Information Sheet No 6 - Managing the risks from hot water and surfaces in health and social care. Caring Circle Homes Ltd will then support to deliver any further works required.

6. Record Keeping & Monitoring

6.1. Details of completed legionella risk assessments will be held digitally using our compliance management system.

6.2. Details of any recommendations and/or regimes arising from the risk assessment which Caring Circle Homes Ltd are responsible to undertake will be stored in the compliance management system.

6.3. All legionella risk assessments will be reviewed on a 2 yearly basis to ensure they are still relevant where:

• There are changes to the water system or its use

• Following changes to the use of the building in which the system is installed

• In light of new information about risks or control measures

• A case of Legionnaires Disease associated with the system

• A key change in personnel

7. Other documents

7.1. This policy is linked to the following documents and they should be read in conjunction:

• Water Safety Procedure

• Standard Form – Legionella Risk Assessment Review

• Guidance – Guide to completing legionella risk assessment review

8. Policy review

8.1. This policy will be reviewed every 2 years.