Social Tenant Access to Information Requirements Policy

1.1.    This policy explains how believe housing will meet the Social Tenant Access to Information Requirements (STAIRs), introduced through the amended Transparency, Influence and Accountability Consumer Standard issued by the Regulator of Social Housing. It sets out how we will provide tenants with clear, accessible and relevant information to help them understand our services, use them effectively, influence decision-making, and hold us to account. The policy supports our wider commitments to openness, transparency, data protection, good governance and accountability. We will publish information proactively where required and respond to valid information requests unless it is reasonable and lawful to withhold or redact information.

1.2.    STAIRs supports this commitment through two routes: proactive publication of information and responses to specific information requests from tenants or their authorised representatives.

2.1.   This policy aims to:

• make relevant information easy for tenants to find, access and understand
• support tenants to scrutinise our services, performance and decision-making
• publish information proactively where required
• respond to requests fairly, consistently and within required timescales
• protect personal data and comply with data protection requirements
• protect confidential, commercially sensitive or legally restricted information
• avoid duplication with other types of requests; for example, subject access requests and complaints where relevant
• act lawfully and in line with regulatory requirements.

3.1.    This policy applies to information we hold, or that is held on our behalf by contractors, managing agents or other service providers, where that information relates to the management of social housing, landlord services, housing stock, performance, spending, governance or decision-making. It applies to requests from social housing tenants and their authorised representatives. It does not apply to leaseholders. It does not create a general public right of access to information, and it does not require us to create new records where the information is not already held.

Terminology used in this policy

3.2.    STAIRs uses the term ‘tenants’ and applies to tenants and their authorised representatives. believe housing usually uses the term ‘customers’. This policy uses ‘tenants’ when referring to the legal scope of STAIRs, and ‘customers’ when referring to our wider organisational language and approach.

Our approach

4.1.    We will take a principles-based approach centred on transparency, openness, accountability and tenant involvement in how services are delivered by:

• proactively publishing information within the STAIRs classes of information
• responding to information requests fairly, consistently and free of charge, unless there is a lawful or reasonable basis to do otherwise
• providing information in accessible formats wherever possible.

STAIRs implementation

4.2.    The scheme has two key phases: Chapter 1, the publication scheme, which applies from 1 October 2026, and Chapter 2, information requests, which applies from 1 April 2027.

Chapter 1: Publication scheme

4.3.    Our publication scheme template is included at Appendix 1. It sets out the classes of information we will routinely publish, where tenants can find that information, and how they can request alternative formats. This will help tenants understand how we operate, perform and make decisions that affect their homes and communities. Information published under the scheme will be available on our website for tenants to access.

Chapter 2: Information requests

4.4.    Our approach to responding to information requests is at Appendix 2 of this policy and explains:

• who can make a request
• how requests can be submitted
• how we will verify identity and authority to act
• how we will handle requests for clarification
• the timescales for responding.

4.5.    We will maintain a log of all information requests and timelines for responding to requests for reporting and accountability purposes.

Out of scope/withheld information

4.6.    We are not required to create new information to comply with either the publication scheme or information requests. Some information may fall outside the scope of STAIRs or may need to be withheld or redacted where there is a lawful or reasonable basis to do so. Examples are set out in Appendices 1 and 2, but these are not exhaustive. Decisions will be made in line with this policy, STAIRs, data protection requirements and any other relevant legal or regulatory duties.

Review and complaints process

4.7.    Where a tenant considers that information held by believe housing should have been published, or is dissatisfied with how an information request has been handled or responded to, an internal review may be requested.

4.8.    A review may consider whether:

• the request was handled appropriately, including whether information was provided in an accessible format
• relevant information should have been published or provided
• the required timescales were met, or whether there was a reasonable basis for any extension
• any decision to withhold or redact information was reasonable.

4.9.   Review requests should normally be made within three months of the original decision. Internal reviews will normally be completed within 30 calendar days, by a suitably senior colleague who was not involved in the original decision. Where additional time is needed in exceptional circumstances, the reason will be explained and any extension will be kept as short as possible.

4.10.    Where a tenant remains dissatisfied after the review, the matter may be escalated to the Housing Ombudsman under the STAIRs complaints route once this is confirmed.

4.11.    Only matters relating to STAIRs – publication of information under Chapter 1 or information requests under Chapter 2 – can be considered through this review process. Concerns relating to data protection will be handled through the usual data protection complaints process.

Data protection and security

4.12.    Protecting personal data and maintaining information security are key principles of this policy.

4.13.    We will not disclose personal data under STAIRs if doing so would breach data protection legislation. Where a request is more appropriately dealt with as a Subject Access Request, we will explain this and process the request in line with the relevant data protection procedure.

5.1.    The Board is responsible for making sure openness, transparency and access to information are embedded in our governance arrangements. Senior leaders must ensure their services keep appropriate records and handle information requests consistently. The Data Protection and Information Governance function will provide advice on data protection, confidentiality, redaction, reasonableness, request handling and reviews. Service areas are responsible for finding and providing relevant information within the required timescales. We will maintain a disclosure log and keep records of requests, responses, decisions, redactions, reviews and any learning identified.

6.1.    We will review this policy regularly to make sure it remains accurate, accessible and compliant.

6.2.    We will also monitor themes from requests and reviews to identify opportunities to publish more information proactively, improve records management, strengthen accountability to tenants and update supporting procedures.

7.1.    This document should also be read alongside wider organisational arrangements for governance, information management, data protection, complaints handling, colleague conduct, openness and transparency, and managing unreasonable behaviour.

This publication scheme explains how we will proactively publish relevant information about the management of social housing. We are committed to being open and transparent about how we work, the services we provide and the decisions we make.

The information covered by this publication scheme is relevant information we hold under STAIRs. Details of the information we routinely publish, and where tenants can access it, are provided through the link listed below under ‘How will relevant information under STAIRs be published?’

We will take reasonable steps to ensure published information is accurate and up to date at the time it is made available.

The publication scheme will be reviewed at least on an annual basis.

How will relevant information under STAIRs be published?

Information will be available on our website at social tenants access to information requirement scheme | believe housing and will be regularly updated.

Formats other than online

Information listed in our publication scheme will be available free of charge online wherever possible. If information is needed in another format, tenants can contact us to discuss their requirements. We may charge only where providing additional copies or non-standard formats creates a direct cost, and any charge will be limited to the actual cost of providing the information. Accessible formats (for example, large print, Braille or a translated copy) will be provided free of charge where required.

Reviews

Where a tenant considers that we have not published information that falls within the scope of the publication scheme, they can request a review by contacting STAIRs@believehousing.co.uk. Reviews will normally be completed within 30 calendar days of receipt.

Who can make requests?

Requests must:

• be made by a registered tenant with us, or by their designated representative
• be made in writing; this includes requests made by letter, email, text message, website form, social media or other instant messaging application, where the requestor can be clearly identified and a valid address for correspondence is provided
• include enough information for us to identify the tenant and their representative (where appointed) and understand the request
• confirm authority to act, where a representative is making the request.

Requests do not need to mention STAIRs. Where a tenant needs support, we will make appropriate arrangements to help them make a request.

There are no restrictions on who a tenant may choose as their representative.

How long will it take us to respond?

We will acknowledge information requests within five working days of receipt.

We will respond to valid information requests within 30 calendar days of receipt. If we need clarification or proof of identity, the 30-day period will begin upon receipt of that information.

Where exceptional circumstances require additional time to respond, we will notify the tenant as soon as possible, explain the reason for the extension, and ensure that any extension is kept to the minimum period reasonably necessary.

Providing, withholding or refusing information

Where requested information is readily available, we may provide it through our normal business processes rather than the STAIRs information request process, provided this does not affect the quality or completeness of the response.

Where a request includes the tenant’s own personal data, that part of the request will be handled as a Subject Access Request in line with our data protection arrangements.

Where requested information is held by a third party managing social housing services on our behalf, we will take reasonable steps to obtain it, taking account of our duties under STAIRs, the need for a proportionate approach and the resources required.

We may refuse to respond to an information request, withhold information or redact information where:

• it is reasonable to withhold the information from disclosure
• the identity of the applicant (or their representative) cannot be established
• the meaning of the request is not clear and you have not responded to our reasonable efforts to seek clarification
• the information requested is excluded on the basis that it is not relevant information (within the scope of information requests under STAIRs)
• the work involved with responding to the information request would exceed 18 hours of staff time
• the request is repeated (including where we receive repeated requests from multiple tenants acting in coordination or seeking the same information)
• the request is offensive or communicated in an abusive manner or is clearly intended to otherwise cause disruption to the business
• disclosure of the information may cause harm (where we have reasonably balanced the factors favouring disclosure against the likelihood of any harm arising from that disclosure).

Deciding what information we can provide 

We will normally provide relevant information unless there is a lawful or reasonable reason not to. We will make decisions fairly and consistently, in line with STAIRs, data protection rules, confidentiality, legal privilege, statutory protections and any other legal or regulatory requirements.

Before deciding whether to provide information, we will consider whether disclosure could cause harm. This may include harm to individuals, commercial interests, confidentiality, investigations, health and safety, or the effective management of services. Where information relates to, or has been provided by, another organisation or person, we may consider their views where appropriate.

We will not refuse information because of who has asked for it, why it has been requested, how it may be used, reputational concerns or the possibility of negative publicity.

If we withhold information, or redact parts of it, we will explain why unless doing so would reveal information that should reasonably be protected. We will provide information in an accessible format wherever possible.

We will keep appropriate records to support transparency, consistency and accountability. This may include records of searches carried out, information considered, decisions made, reasons for disclosure, refusal, withholding or redaction, any third-party consultation, response dates, and the outcome of any review.

Reviews and escalation

If a tenant is not satisfied with how we have handled an information request, or disagrees with a decision to withhold or redact information, they can ask us to review the decision.

Tenants should normally ask for a review within three months of our original response. We will usually complete the review within 30 calendar days. If we need longer, we will explain why and keep any extension as short as possible.

If a tenant remains unhappy after the review, we will explain how they can escalate the matter to the Housing Ombudsman, under the STAIRs complaints route.

This policy was published in August 2026.