Social Tenant Access to Information (STAIRs)

Social Tenant Access to Information (STAIRs) Policy

Organisation: jLiving – Jewish Community Housing Association
Policy owner: Chief Executive / Data Protection Lead
Approval: Board
Policy status: Draft
Effective date: 1 October 2026
Information request provisions effective: 1 April 2027
Review frequency: Annually, or earlier following any change in legislation, regulation or regulatory guidance

  1. Purpose

jLiving is committed to being open, accountable and transparent with its tenants.

This policy explains how we will comply with the Social Tenant Access to Information Requirements (STAIRs) and how tenants can obtain information about the management of their homes and the housing services that jLiving provides.

STAIRs has two principal elements:

  1. the proactive publication of information about the management of our social housing; and
  2. the right of tenants, or their designated representatives, to request relevant information from us.

The publication requirements apply from 1 October 2026. The individual information request requirements apply from 1 April 2027. (GOV.UK)

Our approach will be based on a presumption in favour of openness. We will disclose information unless there is a proper and reasonable reason why it should not be disclosed.

  1. Regulatory framework

This policy has been prepared having regard to:

  • the Housing and Regeneration Act 2008, as amended;
  • the Social Housing (Regulation) Act 2023;
  • the Secretary of State’s Direction on the Social Tenant Access to Information Standard 2025;
  • the Government’s Social Tenant Access to Information Requirements Policy Statement, dated 30 September 2025;
  • the Regulator of Social Housing’s Transparency, Influence and Accountability Standard;
  • the Consumer Standards Code of Practice;
  • the Housing Ombudsman Scheme;
  • the UK General Data Protection Regulation;
  • the Data Protection Act 2018; and
  • other legislation governing confidentiality, disclosure and access to information.

The revised Transparency, Influence and Accountability Standard requires private registered providers to comply with the government’s STAIRs expectations concerning information about accommodation, facilities and services provided in connection with the management of social housing. (GOV.UK)

  1. Who this policy applies to

This policy applies to jLiving social housing tenants.

For STAIRs purposes, the definition of a tenant includes:

  • tenants;
  • licensees;
  • shared owners who own less than 100% of the equity in their home; and
  • other people who have a landlord-and-tenant relationship with jLiving.

A tenant may nominate another person to act as their designated representative.

The tenant must identify the representative to jLiving before we disclose information to that person. (gov.uk)

  1. Our principles

When applying this policy jLiving will:

  • promote openness and transparency;
  • make information easy for tenants to find and understand;
  • publish information proactively wherever reasonably possible;
  • assist tenants who wish to request information;
  • avoid unnecessary secrecy or redaction;
  • consider partial disclosure where a complete document cannot reasonably be disclosed;
  • protect personal, confidential and legally protected information;
  • explain decisions to withhold information;
  • provide information in accessible formats where reasonably practicable;
  • keep appropriate records of decisions; and
  • use information requests and complaints to improve our information management and services.

Information will not be withheld merely because its disclosure could be embarrassing, critical of jLiving or create reputational risk. The STAIRs requirements expressly provide that reputational risk is not, by itself, a reasonable basis for refusing disclosure. (gov.uk)

PART A — PUBLICATION SCHEME

  1. Publication scheme

From 1 October 2026, jLiving will proactively publish, or otherwise make routinely available, information that it holds falling within the STAIRs publication classes.

We will:

  • identify information we hold which falls within the publication scheme;
  • make that information reasonably accessible to tenants;
  • explain to tenants where the information can be found;
  • keep published information under regular review; and
  • update information where appropriate.

STAIRs does not require jLiving to create documents or records which do not already exist solely for the purpose of the publication scheme. (GOV.UK)

  1. Information we will publish

Subject to appropriate redaction or withholding, our publication scheme will include information falling within the following categories.

6.1 Governance and decision-making

This may include:

  • the names and roles of senior staff;
  • jLiving’s organisational structure;
  • governance arrangements;
  • information about decision-making processes;
  • relevant policies;
  • information about tenant consultation;
  • methods used to obtain tenants’ views;
  • tenant meeting agendas and minutes; and
  • information explaining how tenants can influence services and decisions.

6.2 Spending

This may include information concerning:

  • organisational expenditure;
  • grants;
  • expenditure relating to the management of social housing;
  • service charge expenditure where relevant; and
  • the use of service charge income.

Information may be presented in an appropriate and proportionate format and may be redacted where disclosure of individual transactions or other information would not be reasonable.

6.3 Housing stock management

This may include information about:

  • planned maintenance programmes;
  • major works;
  • stock condition;
  • improvement programmes;
  • progress towards energy efficiency and net-zero objectives; and
  • housing stock transfers, acquisitions or mergers where relevant.

6.4 Performance

This may include:

  • regulatory inspection outcomes;
  • regulatory ratings;
  • Tenant Satisfaction Measures;
  • performance reports;
  • complaints performance and statistics;
  • STAIRs information request statistics;
  • health and safety performance information;
  • compliance performance;
  • repairs and maintenance performance; and
  • information about evictions.

6.5 Housing services

This may include descriptions of:

  • housing management services;
  • repairs services;
  • estate and communal services;
  • sheltered housing services;
  • complaints arrangements;
  • support and advice available to tenants; and
  • guidance explaining how tenants can access our services.

6.6 Lists and registers

Where appropriate, we will publish information contained in registers required by law and other relevant lists and registers connected with the management of our social housing.

Information which contains personal, confidential, commercially sensitive or security-related information may be withheld or redacted.

6.7 Social housing management

This will include relevant policies and strategies concerning the management of jLiving’s social housing.

The seven publication classes above reflect the government’s STAIRs publication scheme. (GOV.UK)

  1. Accessibility of published information

Information will normally be made available through jLiving’s website and may also be made available through other appropriate means.

We recognise that not all tenants use digital services.

Where reasonably practicable, tenants may request information in an alternative format, including:

  • paper copies;
  • large print;
  • accessible electronic formats; or
  • another reasonable format appropriate to their needs.

We will take account of tenants’ communication needs and any reasonable adjustments required.

PART B — INDIVIDUAL INFORMATION REQUESTS

  1. Commencement

The individual information request provisions in this Part apply from 1 April 2027.

A tenant does not have to use the word “STAIRs” when making a request.

Where correspondence is reasonably identifiable as a request for information falling within STAIRs, we will deal with it accordingly. (gov.uk)

  1. How to make a request

A STAIRs request must:

  • be made in writing;
  • identify the applicant; and
  • provide sufficient information to enable us to understand what information is being requested.

Requests may be submitted by email, letter or another written channel made available by jLiving.

A request may be made by:

  • a tenant; or
  • a designated representative acting on behalf of a tenant.

If a request is unclear, we will make reasonable efforts to help the applicant clarify what information they require rather than simply refusing the request.

  1. What information can be requested

STAIRs applies to relevant information concerning the management of jLiving’s social housing which:

  • is held by jLiving; or
  • is held by another person or organisation responsible for managing jLiving’s social housing on our behalf.

Relevant information may include information concerning:

  • property moves;
  • rents and rent collection;
  • rent levels;
  • relevant service charges;
  • occupancy rights;
  • estate management;
  • communal areas;
  • boundary issues;
  • property condition;
  • repairs;
  • planned and major works;
  • improvements;
  • anti-social behaviour;
  • staffing and training;
  • complaints handling and complaints performance;
  • compensation and redress;
  • communication and customer service;
  • health and safety;
  • data handling and privacy;
  • security;
  • stock transfers and mergers;
  • housing stock information; and
  • environmental and energy efficiency matters.
  1. Information held by contractors and other organisations

Where relevant information is held by a contractor, managing agent or another person or body responsible for managing jLiving’s social housing on our behalf, we will use all reasonable endeavours to obtain that information.

We will keep an appropriate record of the steps taken to obtain information from third parties.

The fact that information is held by one of our contractors will not, by itself, be treated as a reason for refusing a request.

  1. Information covered by another statutory access regime

STAIRs does not replace existing legal rights of access to information.

Where the requested information is accessible under another statutory regime, it will not normally be dealt with as a STAIRs request.

For example, a request by an individual for copies of their own personal data may need to be dealt with as a Subject Access Request under UK GDPR and the Data Protection Act 2018.

Where another statutory route is more appropriate, we will make reasonable efforts to tell the applicant which route applies and how they can use it.

  1. Information created after a request

STAIRs applies to information that already exists and is held at the time of the request.

jLiving is not required to:

  • create a new report;
  • create a new analysis;
  • answer hypothetical questions;
  • prepare information that is not already recorded; or
  • create a new record solely in order to respond to a STAIRs request.

We will, however, provide reasonable advice or assistance where this may help a tenant identify information that we do hold.

  1. Timescale for responding

We will acknowledge STAIRs requests promptly.

We will respond:

as promptly as possible and no later than 30 calendar days after receipt of the request.

The 30-day period begins when jLiving receives the request, not when we acknowledge it.

Additional time may be taken only in exceptional circumstances, including where additional time is reasonably required:

  • to determine whether information should properly be withheld; or
  • to obtain relevant information from another body responsible for managing jLiving’s housing on our behalf.

Where additional time is required, we will inform the applicant:

  • that the response will be delayed;
  • why additional time is required; and
  • when we reasonably expect to respond.
  1. Grounds on which a request may be refused

jLiving may refuse a request where:

  1. it is reasonable to withhold the information;
  2. we cannot establish the applicant’s identity;
  3. the request remains unclear despite reasonable efforts to assist the applicant;
  4. the information is not relevant information for STAIRs purposes;
  5. responding would require more than 18 hours of staff time;
  6. the request is repeated, including repeated requests made by multiple applicants acting in coordination; or
  7. the request is offensive or has been communicated in an abusive manner.

These grounds will not be applied automatically. Decisions will be made reasonably, proportionately and consistently with the objective of promoting transparency.

Requests exceeding 18 hours

Where we estimate that complying with a request would exceed 18 hours of staff time, we will normally consider whether the applicant can narrow or refine the request so that some or all of the information can be provided.

Where a request is refused on this basis, we will explain our decision.

  1. Our policy on withholding information

The starting point for jLiving will be disclosure.

Information will only be withheld where there is a proper reason for doing so and it is reasonable and proportionate in the circumstances.

When deciding whether information should be withheld, we will have due regard to:

  • the protections afforded to information under the Freedom of Information Act 2000;
  • the Data Protection Act 2018 and UK GDPR;
  • duties of confidentiality;
  • legal professional privilege;
  • other applicable legislation; and
  • the potential harm that disclosure could cause.

The fact that an exemption or protection may exist will not necessarily mean that an entire document must be withheld.

  1. Examples of information which may require protection

Depending upon the circumstances, information that may require withholding or redaction can include:

  • personal information about another tenant or individual;
  • special category personal data;
  • information identifying complainants, witnesses or vulnerable people;
  • information protected by legal professional privilege;
  • confidential information received from a third party;
  • information where disclosure would create a genuine risk to the safety or security of residents, staff or property;
  • information concerning security systems or security arrangements where disclosure would create a risk;
  • information where disclosure could prejudice the prevention or investigation of crime;
  • information whose disclosure would breach a statutory duty;
  • commercially sensitive information where there is a genuine and material risk of harm from disclosure; and
  • information whose disclosure would breach enforceable confidentiality obligations.

These categories do not create automatic exemptions from disclosure.

  1. How we decide whether withholding is reasonable

When considering whether information should be withheld, jLiving will balance:

Factors favouring disclosure

These may include:

  • promoting transparency;
  • enabling tenants to understand decisions affecting their homes;
  • enabling scrutiny of jLiving’s performance;
  • demonstrating accountability for expenditure;
  • increasing understanding of health and safety matters;
  • helping tenants understand service standards;
  • improving public and tenant confidence;
  • identifying lessons from complaints or service failures; and
  • the general objectives of STAIRs.

Factors favouring withholding

These may include:

  • protection of another person’s privacy;
  • risk of serious prejudice to legal proceedings;
  • protection of legally privileged communications;
  • genuine health, safety or security risks;
  • genuine and significant commercial harm;
  • protection of confidential third-party information; or
  • a conflict with another statutory obligation.

The decision will depend upon the circumstances of the particular case.

Where information concerns or was provided by a third party, we will consider the third party’s views about any potential harm resulting from disclosure where appropriate.

However, the final decision remains jLiving’s responsibility.

  1. Partial disclosure and redaction

Where only part of a document reasonably needs to be protected, we will normally disclose the remainder.

Redaction will therefore be preferred to withholding an entire document where this enables meaningful information to be disclosed safely and lawfully.

Where practicable, we will explain:

  • that information has been redacted;
  • the general reason for the redaction; and
  • the tenant’s right to request a review.

We will not use redaction simply because information may be inconvenient, embarrassing or critical of jLiving.

  1. Destruction or alteration of requested information

Once an information request has been received, no employee, contractor or person acting on behalf of jLiving may destroy, manipulate or alter information with the intention of preventing its disclosure.

This does not prevent the lawful application of jLiving’s normal document-retention arrangements where no request has been made, or the legitimate redaction of information before disclosure.

STAIRs expressly prohibits destroying, manipulating or altering requested information with the intention of preventing disclosure.

  1. Format of information

We will make reasonable efforts to provide disclosed information in a format that is accessible to the applicant.

Where appropriate, we will discuss alternative formats or reasonable adjustments with the tenant.

We may also direct tenants to information already publicly available where this satisfactorily answers the request.

PART C — REVIEWS AND COMPLAINTS

  1. Right to an internal STAIRs review

A tenant or their designated representative may request a review where they believe:

  • information that should have been published has not been published;
  • their information request has not been handled properly;
  • information has been wrongly withheld or redacted;
  • a request has been wrongly refused;
  • jLiving has failed to respond within the required timescale; or
  • reasonable efforts have not been made to obtain information from a contractor or other relevant third party.

The review will consider whether the original decision complied with this policy and the STAIRs requirements.

  1. Timescale for reviews

A STAIRs review should normally be completed within 30 calendar days of receipt.

Where additional time is required because of the particular circumstances of the case, we will tell the tenant:

  • why additional time is necessary; and
  • when the review is expected to be completed.

The person conducting the review should, wherever reasonably practicable, not be the person solely responsible for the original decision being reviewed.

  1. Housing Ombudsman

If the tenant remains dissatisfied following jLiving’s STAIRs review, they may refer the matter directly to the Housing Ombudsman Service in accordance with the Housing Ombudsman Scheme.

Our review response will tell the tenant about their right to approach the Housing Ombudsman.

The Housing Ombudsman is responsible for resolving individual STAIRs disputes, while the Regulator of Social Housing is responsible for regulating compliance with the regulatory standards.

  1. Relationship with jLiving’s Complaints Policy

A complaint specifically concerning the publication, withholding or provision of information under STAIRs will be considered under the STAIRs review arrangements required by this policy.

Where the complaint also concerns the underlying housing service — for example repairs, estate management, staff conduct or complaint handling — those elements may also need to be considered under jLiving’s Complaints Policy.

We will explain to the tenant which process applies and will avoid requiring a tenant to pursue unnecessarily duplicated processes.

PART D — GOVERNANCE AND MONITORING

  1. Responsibilities

The Board has overall responsibility for ensuring that jLiving complies with the regulatory requirements relating to transparency and access to information.

The Chief Executive has executive responsibility for implementation of this policy.

Relevant managers are responsible for:

  • identifying information which should be proactively published;
  • keeping published information up to date;
  • responding to information requests;
  • ensuring contractors assist jLiving with information requests where necessary;
  • applying withholding and redaction decisions consistently;
  • maintaining appropriate records; and
  • ensuring staff understand their responsibilities.

All staff are expected to cooperate promptly with a STAIRs request.

  1. Record keeping

jLiving will maintain appropriate records of:

  • STAIRs requests received;
  • the date each request was received;
  • acknowledgements;
  • information disclosed;
  • redactions;
  • information withheld;
  • reasons for refusal;
  • estimated staff time where the 18-hour limit is relevant;
  • requests for clarification;
  • contact with contractors and third parties;
  • response dates;
  • extensions;
  • internal reviews; and
  • outcomes.

Good records will enable us to demonstrate that decisions have been made consistently, reasonably and transparently.

  1. Monitoring

We will monitor the operation of this policy, including:

  • the number of information requests received;
  • the subjects of requests;
  • response times;
  • the number of requests refused;
  • the reasons for refusals;
  • use of the 18-hour limit;
  • the number of internal reviews;
  • Housing Ombudsman findings;
  • accessibility issues;
  • information frequently requested by tenants; and
  • opportunities to add frequently requested information to our publication scheme.

Where appropriate, performance information about STAIRs will itself be proactively published.

  1. Staff training

Relevant staff will receive appropriate guidance and training before the individual information-request provisions take effect on 1 April 2027.

Training will cover:

  • recognising a STAIRs request;
  • distinguishing STAIRs from Subject Access Requests and other statutory information rights;
  • the 30-calendar-day timescale;
  • the 18-hour staff-time limit;
  • third-party information;
  • withholding and redaction;
  • data protection;
  • accessibility;
  • record keeping; and
  • reviews and complaints.
  1. Review of this policy

This policy will be reviewed at least annually.

It will also be reviewed following:

  • changes to the STAIRs Policy Statement;
  • changes to the Regulator of Social Housing’s standards or Code of Practice;
  • relevant Housing Ombudsman guidance or decisions;
  • significant legislative changes; or
  • evidence from requests or complaints indicating that changes are required.

Tenant summary

From 1 October 2026: jLiving will proactively publish specified information about how we manage our social housing.

From 1 April 2027: you can make a written STAIRs request for information about the management of jLiving’s social housing.

You do not have to say that your request is a “STAIRs request”.

We will acknowledge your request promptly and normally provide a response within 30 calendar days.

Some information may need to be withheld or redacted to protect other people, comply with the law, protect security or confidentiality, or for another proper reason. We will not withhold information simply because it may be embarrassing or critical of jLiving.

If you disagree with our decision, you can ask us to carry out a STAIRs review. This will normally be completed within 30 calendar days.

If you remain dissatisfied after our review, you can take the matter to the Housing Ombudsman Service.

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