Social Tenants Access to Information Requirements (STAIR) Policy

Introduction

Heart of Medway Homes (HoM), as a Registered Provider of social housing, is subject to the Social Tenants Access to Information Requirements (STAIR). mhs homes provides management and support services, including services delivered on behalf of HoM. This policy explains how HoM will comply with STAIR and how mhs homes will support that compliance where it holds information relevant to the management of HoM homes.

Where information relating to the management of HoM homes is held by mhs homes, contractors, managing agents or other parties acting on behalf of HoM, HoM will use all reasonable endeavours to obtain that information in order to meet its obligations under STAIR.

HoM is responsible for compliance with STAIR. mhs homes will support compliance where it holds relevant information on behalf of HoM.

Purpose

By adopting this policy, mhs will ensure we:

• Embed transparency and accountability for tenants of HoM and customers receiving housing management services from mhs homes.

• Comply with the STAIR policy statement and associated regulatory standards.

• Set clear operational expectations for teams handling publication and information requests.

• Minimise risk by applying lawful redaction and proportionate refusals, with appropriate review routes.

Scope

This policy applies to all mhs homes employees, temporary and agency workers, volunteers, apprentices, Board/Committee members and contractors who create, hold, or process information on behalf of mhs homes. It covers all formats (e.g. documents, emails, drafts, notes, call recordings, CCTV, databases and reports) created or held in the course of managing our social housing

Key definitions

• Tenant: any social housing tenant or other occupier including licensees and shared owners with under 100% equity.

• Designated representative: a person nominated by a tenant to act on their behalf (e.g. carer, solicitor).

• Relevant information: information related to the management of our social housing, including policies, plans, actions and supporting records.

Legal & regulatory basis and implementation timetable

STAIR forms part of the consumer regulatory framework overseen by the Regulator of Social Housing. The Government’s policy statement confirms a phased implementation:

(a) Publication Scheme from 1 October 2026; and

(b) Information Requests from 1 April 2027.

mhs homes will prepare and operate in line with these dates.

Roles & responsibilities

Data Protection Officer (DPO): policy owner; assures compliance; oversees refusals/redactions and complex cases.

Service teams: maintain up-to-date content for the publication scheme and provide records to fulfil requests.

mhs homes service teams and contract managers must use all reasonable endeavours to locate and provide relevant information held on behalf of HoM, including information held within mhs homes systems, by contractors, or by managing agents.

Policy Detail

Publication scheme

HoM will maintain a publication scheme in accordance with STAIR requirements.

As a matter of transparency and good practice, mhs homes may voluntarily make available equivalent information relating to its housing

management activities where appropriate. Such publication does not create independent STAIR obligations for mhs homes and remains outside the formal STAIR framework unless relating to HoM's statutory obligations.

mhs will continue to mirror the HoM publication scheme as a transparency measure and to provide a consistent customer experience across the group. However, the statutory STAIR information request requirements taking effect from 1 April 2027 apply to mhs only to the extent that it holds information relevant to the management of HoM homes on behalf of the Registered Provider. Voluntary publication by mhs homes does not create a separate STAIR obligation or Housing Ombudsman jurisdiction in relation to mhs homes activities that fall outside the management of HoM homes

HoM will make tenants aware of the scheme (e.g. website, tenant handbook) and review content regularly We will not create new records solely for publication.

Tenant review of the publication scheme

Tenants (or their designated representatives) may request a review where they believe that information which falls within the scope of the publication scheme has not been published, has not been made routinely available, or has been excessively redacted.

Requests for review will be considered in line with our STAIR review procedure and responded to within 30 calendar days of receipt, unless an extension is applied in exceptional circumstances.

We may also publish high‑level, anonymised information about STAIR requests we receive, including themes and outcomes, or make frequently requested information available via FAQs, where this would support transparency and reduce repeat requests.

Information requests (from 1 April 2027)

Where relevant information is held by mhs homes on behalf of HoM, mhs homes will assist HoM to locate, retrieve, review and provide that information.

Where information relates partly to the management of HoM homes and partly to activities outside the scope of STAIR, the relevant information will be considered for disclosure and information falling outside scope may be withheld or redacted where appropriate

Tenants (or their designated representatives) may request relevant information in writing. We will assist applicants to make clear and valid requests and will publish easy routes to submit requests (via our contact us web form, email, post).

What is covered – relevant information

• Handling of property moves; rent collection; rent rates; service charges for shared owners; occupancy rights.

• Estate management including communal areas and boundary issues; anti-social behaviour (ASB).

• Property condition, repairs and improvements; environmental and energy efficiency information.

• Staffing and training; complaints handling, procedures and performance; compensation and redress.

• Communication and customer service; health and safety; data handling and privacy; security.

• Housing stock transfers/mergers; housing stock profile.

Information not covered

• Matters determined by local councils (e.g. allocations policies, homelessness).

• Information about management of property not related to mhs homes’ social housing functions.

• Information where there is a statutory right of access under another regime (e.g. FOI to local authorities).

Mixed Information Holdings

Where records contain information relating to both HoM and non-HoM activities., each request will be assessed on its merits. Information relating to the management of HoM homes will be considered for disclosure in accordance with STAIR. Information that falls outside STAIR, contains personal data, confidential commercial information, legally privileged information or other protected material may be withheld or redacted where reasonable.

How we process requests

We will use reasonable endeavours to obtain relevant information held on our behalf by contractors/managing agents.

We are not required to create new records to comply with a request.

We will not destroy, manipulate, or alter information with intent to prevent disclosure.

If information is accessible via a statutory regime, we will direct the requester to the appropriate route.

Our service standards

• Acknowledgement: within 2 working days of receipt.

• Response time: promptly and within 30 calendar days of receipt (extensions will be applied only where circumstances are genuinely exceptional, will be proportionate and time‑limited, and will not be used for routine consideration of redaction or withholding.

Where an extension is applied, we will inform the applicant promptly, explain the reason for the extension, and provide an expected response date.).

• Accessible formats, alternative languages and reasonable adjustments will be provided free of charge, in accordance with our equality duties and the Transparency, Influence and Accountability Standard.

• Clarification: if a request is unclear, we will assist to refine it to a clear, valid request.

Redaction and refusal

We may redact documents where appropriate (e.g. to remove personal data or confidential material).

We may refuse a request where:

(a) it is reasonable to withhold;

(b) the applicant’s identity cannot be established;

(c) the meaning is unclear;

(d) the information is not classed as relevant information within the national guidance;

(e) responding would reasonably be expected to exceed 18 hours of staff time, including time spent locating, reviewing, collating and redacting information. Before refusing a request on this basis, we will consider whether the request can reasonably be refined or fulfilled in part and will explain how the time estimate was reached.;

(f) the request is repeated (including coordinated repeats);

or (g) the request is offensive or abusive.

In limited circumstances, it may be reasonable to refuse to confirm or deny whether information is held where doing so would itself cause harm, breach confidentiality, or conflict with legal obligations (for example, safeguarding, anti‑social behaviour reports, or commercially sensitive negotiations).

In such cases, we will explain that a neither confirm nor deny response has been issued and outline the basis for this decision.

In deciding what is reasonable to disclose, we will have due regard to protections in the Freedom of Information Act 2000, Data Protection Act 2018 and other relevant statutes, and will balance factors favouring disclosure against the likelihood of harm (including consulting relevant third parties where appropriate).

We will not refuse simply because of the applicant’s identity, their reasons, or how they may use the information after disclosure (provided they are a tenant or acting representative).

Complaints and review

If an applicant is dissatisfied with our response to a STAIR information request, or does not receive a response within the required timescale, they may refer the matter to the Housing Ombudsman under the Housing Ombudsman Scheme.

STAIRs matters are not complaints under our Complaints Handling Policy or Complaints Handling Code and are considered separately under the Housing Ombudsman's STAIRs complaint process.

Applicants should refer a STAIRs complaint to the Housing Ombudsman within 3 months of receiving our response, or from the date a response should have been provided if no response was received. The Housing Ombudsman has discretion to accept complaints outside this timeframe in appropriate circumstances.

The Housing Ombudsman will review whether the organisation has complied with its obligations under STAIRs and may issue findings and remedies in accordance with the Housing Ombudsman Scheme.

Interaction with other regimes

• Freedom of Information Act 2000: applies to local authorities (we will signpost where relevant).

• Data Subject Access Requests (UK GDPR): remain available for personal data; handled under our Data Rights procedure.

• Transparency, Influence & Accountability Standard: we will align STAIR implementation with consumer standards and RSH guidance.

Training

All staff are required to complete their annual Data Security and Protection training through classroom-based sessions. Bespoke training will be provided for staff who will be processing the STAIR requests and managing complaints made in relation to the scheme.

Assurance and Monitoring

This policy has been developed by the Data Protection Officer with reference to examples provided by other Housing Associations as well as other types of organisation. This guidance is in line with Housing Ombudsman guidance.

Compliance with STAIR will be monitored through quarterly reporting to LT and twice‑yearly reporting to FRAC, including learning from reviews, complaints and Housing Ombudsman determinations where relevant.

We will maintain appropriate records of STAIR publication decisions, refusals, redactions, balancing exercises and reviews to support accountability, internal assurance and Housing Ombudsman oversight.

Legal and Regulatory Overview

The policy was created in conjunction with the Housing Ombudsman guide to The Social Housing Access to Information Scheme. In line with the requirements out lined in the Social Housing (Regulation) Act 2023.

STAIR forms part of the consumer regulatory framework overseen by the Regulator of Social Housing. The Government’s policy statement confirms a phased implementation:

(a) Publication Scheme from 1 October 2026; and

(b) Information Requests from 1 April 2027.

mhs homes will prepare and operate in line with these dates.

Principles

Equality statement

mhs homes has a duty to ensure that no person receives less favourable treatment from the organisation on the grounds of age, disability, gender reassignment, marriage, civil partnership, pregnancy, religion or belief, race, sex or sexual orientation.

​​​​​​​Data protection

mhs homes will only share information that meets the requirements of the Data Protection Act 2018 and the UK GDPR. Confidentiality and impartiality will be exercised by mhs homes at all times.

Feedback

We welcome suggestions and comments from people who use or provide our services. We believe that this can provide some important lessons to help us ensure that the service is improved for everyone.

If you have something to say about this policy or the information that is provided, then please let us know. Please refer any comments to the author of this document.