Case Study: What We Can Learn from Thirteen’s C1 in March 2025
Background
Thirteen Housing Group is a Registered Provider of social housing, owning and managing approximately 35,000 homes in the North East and Yorkshire, England, with around 1,500 employees.
The Regulator of Social Housing (RSH) undertook an inspection of Thirteen in March 2025. The previous inspection was in January 2024, when Thirteen received a V1 and a G1 rating, for financial viability and governance. The March 2025 inspection was the first looking at the Consumer Standard too, and Thirteen received a C1 rating, while retaining its V1 and G1 too. In this Case Study, I will focus on the Consumer Standard rating, and the reasons the RSH gives for the C1.
Link to the RSH’s publication of the inspection results
Inspection Report
Inspections are carried out by reviewing information the RSH already has from regulatory , information they request from the landlord especially for the inspection, and observations made from attending Board and other meetings. They base their judgement on evidence-based assurance.
Now, I might be reading too much into it, but I welcome the order in which the findings are presented in the Thirteen judgement. On the RSH webpage the 4 standards that make up the Consumer Standards are listed alphabetically, but in the Consumer Standards Code of Conduct, they are listed: (1) Safety and quality standard, (2) Transparency, influence and accountability standard, (3) Neighbourhood and community standard, and (4) Tenancy standard. Does that indicate the importance of each standard – who can say? As I admitted above, I might be reading too much into this, but…. the order they appear in the Thirteen judgement is somewhat different, and they also say much more about one standard than the others each get.
In the judgement summary, the standards are addressed in this order: (1) Safety and quality – same as in the Code of Conduct, and this one gets the most words by far! (2) Neighbourhood and community standard – which is third in the Code of Conduct, (3) Tenancy standard – which is fourth in the Code of Conduct, and (4) Transparency, influence and accountability – which is second in the Code of Conduct.
Why am I so obsessed with this order, you ask? I can’t help but feel that it indicates a focus by the inspectors on safety and quality above all, which I am delighted to see, because the core purpose of social housing is to provide safe, warm, good quality homes. And I’ve said many times (and will likely say it many times again) that providers of social housing risk failing to fulfil their core purpose by spreading themselves too thinly. But on top of that, my experience tells me that it’s when landlords look to provide additional services that they are more likely to breach privacy and data protection.
Data Protection Considerations
To explain why I say that, let’s look at an example: When housing associations concentrate on “[tenants’] diverse needs” as stated in the Consumer Standards (Transparency, influence and accountability standard), this so often translates to a huge increase in the amount of very sensitive data that’s collected from tenants, about their health, ethnicity, religion, sexuality, gender, and more, without any clear link to achieving the housing association’s main purpose of providing bricks and mortar homes that are safe, warm homes.
As we know, more data, and more sensitive data especially, means more risk – risk of discrimination, embarrassment, or fraud, amongst other harmful outcomes.
Yes, I’m aware that landlords will say “but we’re about more than bricks and mortar”. Which I agree, but only to an extent. What about when we aren’t fulfilling the core purpose 100% of the time yet? Shouldn’t we focus on the bricks and mortar, the safe, warm, mold-free, dry homes first?
To come back to the findings in the Thirteen judgement, this is why I’m delighted to see the focus on safety and quality of stock.
Thirteen RSH Findings
Below, I’ve picked out some key phrases from the RSH (in the order they appeared!):
“Thirteen demonstrated it has appropriate processes in place that allow it to use a risk-based approach to identify and prioritise actions necessary to address health and safety issues in its homes. It has sought adequate assurance over these processes and the underpinning data”
“Thirteen keeps an accurate record of the condition of its homes at an individual property level through physical surveys of its homes and has a process for keeping this information up to date.”
“We saw evidence that it understands the risks associated with these [tall] buildings with appropriate levels of board oversight.”
“Thirteen demonstrated that it provides an effective, efficient and timely repairs service to tenants.”
“Thirteen works with relevant organisations to deter and tackle anti-social behaviour in its neighbourhoods, and we saw examples of this happening in practice.”
“Thirteen reviews its lettings and allocations policy regularly to ensure all properties are let in a fair and transparent way… Thirteen supports tenants to sustain their tenancies.”
“Thirteen has a wide range of customer engagement opportunities and we saw evidence that it is delivering a collaborative approach to the design of its landlord services… we saw evidence that feedback has led to service improvements.”
“…complaints are handled efficiently and promptly. The board and customer committee receive regular reports on complaint types and outcomes segmented by tenant data to allow for analysis to create better outcomes for tenants.”
“Thirteen considers tenants’ diverse needs in the design and delivery of services, and that it monitors its performance in continuing to deliver outcomes to tenants in this area.”
Lessons Learned
You might have noticed there are a couple of mentions that make me slightly nervous and I’d love to know a bit more – “reports on complaint types and outcomes segmented by tenant data” and “Thirteen considers tenants’ diverse needs in the design and delivery of services” especially.
But, that aside, what can we learn from the rest?
It’s clear that the C1 rating is built on a foundation of well-managed data, knowledge and information. Without having the right data/information, and without being able to access the right data/info. at the right times and for appropriate purposes, I don’t think Thirteen would have received such a glowing report, or – crucially – be having such a positive impact on their residents.
As the Housing Ombudsman has been saying for a couple of years now, KIM (knowledge & information management) is vital to providing services well. And “KIM” goes hand-in-hand with “data”, with data being recorded knowledge and/or information. Of course, data protection law only covers data (or knowledge/information) about people, but we can, and should (in my opinion), apply the data protection principles and practices to all sorts of data/info. Who can argue that data relevancy, accuracy, usefulness, security should be ignored if the data isn’t about people? (Hopefully no one!)
To conclude, it appears from the RSH C1 rating for Thirteen, that they are doing the following well:
- Record keeping: Thirteen knows about its approx. 35,000 homes, meaning they can plan and respond effectively.
- Data-driven decision-making: Their knowledge, information and data is being used to make risk-based decisions and to plan or future needs.
- Appropriate processes: Just some of the processes highlighted by the RSH include handling repairs, handling complaints, and feedback management. Nothing can work smoothly without appropriate processes in place, and the processes must be understood by, and followed by, employees.
Huge congratulations to Thirteen!
If you have any further questions or or comments, give me a shout! Clare@cpdataprotection.com