STAIRs policy

Status: Draft

Subject to SNG Customer Influence Panel (CIP) feedback and approval

Last reviewed: October 2026

1. Scope

2. Purpose and objectives

3. Policy statement

4. Definitions

5. Policy

6. Compliance and review process

7. Responsibilities

8. Equality, diversity and inclusion

9. Related documents

10. Legislation and regulation

11. Review

Appendix A

1 - Scope

This policy applies to Sovereign Network Group (SNG), including all colleagues, contractors and third parties providing social housing management services on SNG's behalf as the Private Registered Provider (PRP).

It sets out the rights of customers to access information under the Social Tenant Access to Information Requirements scheme (STAIRs). It covers information relating to SNG's social housing management functions, including information held by organisations providing services on our behalf.

This policy applies to:

• Current tenants
• Licensees
• Shared owners who own less than 100% of their home
• Representatives acting on behalf of a customer

This policy doesn’t apply to:

• Leaseholders
• Shared owners who own 100% of their home
• Former customers

2 - Purpose and objectives

The purpose of this policy is to explain how we’ll meet the requirements of STAIRs.

This includes how we’ll:

• Publish information about our social housing services under the publication scheme
• Help customers access information
• Respond to information requests within the required timescales
• Explain when we can’t share information and why
• Handle complaints about STAIRs requests

It also explains how customers can contact the Housing Ombudsman if they’re unhappy with how we’ve handled a request. 

3 - Policy statement

SNG will take an open and customer-focused approach to sharing information about our social housing services.

From 1 October 2026, we’ll publish information about our social housing services available on our STAIRs webpage. If a customer thinks information is missing, they can ask us to review it

From 1 April 2027, customers and their designated representatives can make a written request for relevant information that isn’t already available as published information through STAIRs.

SNG will:

• Respond to requests within 30 calendar days
• If we need more time to respond, we’ll explain why and let customers know when they can expect a response
• Let customers know if we need more information or proof of identity before we can process a request
• Provide information in an accessible format where possible
• Usually provide the information free of charge
• Explain if we’re unable to share information or if a charge applies for additional copies

4 - Definitions

Customer - A current tenant, licensee, shared owner who owns less than 100% of their home, or any other person who is eligible to make a request under this policy.

Designated representative - A person authorised by a customer to act on their behalf for a STAIRs request or review.

Policy statement - The government policy that sets out the requirements of STAIRs.

Publication scheme - The categories of information we’re required to publish under STAIRs.

Published information - Information we’ve published on our website as part of the publication scheme.

Reasonableness test - The checks we carry out to decide whether information can be shared. This includes considering data protection laws and balancing the benefits of sharing information against any potential harm that sharing the information could cause. 

Relevant information - Information held by SNG about the management of our social housing services that can be requested under STAIRs.

STAIRs - Social Tenant Access to Information Requirements scheme.

Valid request - A request for information that meets the requirements set out in this policy. 

5 - Policy

We’ll publish information about our social housing services on our STAIRs webpage where it’s relevant and required under the publication scheme. This includes information about:

• Governance and decision making
• Spending
• Housing stock management
• Performance
• Housing services
• Lists and registers
• Social housing management

We’ll regularly review this information and make reasonable efforts to keep it clear, accessible and up to date.

We’re not required to create new information to publish or respond to a STAIRs request. However, we may bring together, extract or present information we already hold in a format that’s easier to access and understand.

SNG is committed to being open and transparent about its services and will normally share information requested through STAIRs. We'll apply a reasonableness test when considering requests and any decision to withhold information. For example, we may not provide information if we don't hold it, the request falls outside the scope of the Policy Statement, the request is unclear or repetitive, the information is available through another legal process, or it would take more than 18 hours of staff time to process the request. When considering the time needed to respond, we'll use the most practical and efficient way of finding and providing information from our systems and records. We may also refuse requests that are offensive or abusive.

We may withhold or remove information where it’s reasonable to do so, where sharing it would breach data protection laws, reveal personal, confidential or legally privileged information, affect commercial interests, create a risk to health, safety or security, affect an investigation or legal proceedings, or conflict with another legal obligation.

When deciding whether to share information, SNG won’t take into account who has made the request, why they’ve made it, how they intend to use the information, or any reputational impact on SNG.

In some cases, information may already be available through another legal process and doesn’t need to be provided under STAIRs. For example, information about SNG’s corporate activities that must be filed with Companies House.

Requests for personal information should be made through a Subject Access Request (SAR) in line with our Privacy Notice. A SAR is used to access personal information and is different from a request made under STAIRs. 

6 - Compliance and review process

SNG will keep records and processes in place to help us meet the requirements of STAIRs. This includes keeping records of information requests, response times, decisions to withhold or remove information, internal reviews and their outcomes.

We’ll acknowledge requests promptly, ask for clarification if we need more information, and verify the identity of customers or their designated representatives where appropriate. We’ll respond to requests within 30 calendar days unless there are exceptional circumstances that require more time.

Customers can ask us to review information published on our STAIRs webpage if they believe information that should be included is missing.

Customers can also ask us for a review if they’re unhappy with how we’ve handled their request or with the response they’ve received

A request will usually be valid if:

• It includes enough detail for us to identify the information being requested
• We’ve been able to confirm the identity of the person making the request and their authority to act on behalf of a customer, where applicable

Requests for a review should usually be made within three months of our original response or decision. We’ll aim to complete the review within 30 calendar days.

The review will be carried out by a different colleague from the person who provided the original response and, where appropriate, by a more senior colleague.

If a customer remains unhappy after the review, they can refer the matter to the Housing Ombudsman through the STAIRs complaints process.

Complaints about STAIRs will be handled separately from SNG’s general complaints process. 

7 - Responsibilities

Executive policy owner - Approves this policy and is responsible for making sure it’s implemented and reviewed.

Data Protection Officer - Provides advice on data protection, personal information, redacting information and when information can be shared.

STAIRs lead - Manages the day-to-day STAIRs process, maintains the STAIRs webpage and disclosure log, coordinates requests and helps ensure responses are provided within the required timescales.

Business area leads - Identify, provide and review information held by their teams for publication and responding to requests.

All colleagues - Recognise potential STAIRs requests, support customers appropriately, follow the relevant procedures and pass requests to the STAIRs lead promptly.

8 - Equality, diversity and inclusion

We will apply this policy consistently and fairly and will not discriminate against anyone based on any protected characteristics, including those set out in the Equality Act 2010.

At SNG, our commitment is to make sure that no individual or group experiences unfair, discriminatory, or prejudicial treatment in recruitment, pay or promotions, housing, or any other service we provide, such as lettings, tenancy advice, repairs or rent collection.

SNG strives to be an open, inclusive, and diverse organisation where everyone has the right to be treated with dignity, fairness and respect. As an organisation we value the diversity and talents of all individuals and the richness that brings to our culture.

We understand the varying needs of our residents and communities and promote equality of opportunity in employment and service provision.

We deliver appropriate, accessible, and flexible services, being tolerant, understanding and not judging others or their lifestyle choices. We stand up to and challenge prejudice, discrimination, and harassment in all its forms. 

9 - Related documents

Related documents include:

• Data Protection Policy
• Data Privacy Notices
• Subject Access Request Procedure

10 - Legislation and regulation

This policy is informed by:

• Social Tenant Access to Information Requirements (STAIRs)
• Policy Statement of Ministry for Housing, Communities and Local Government dated 30 September 2025
• Transparency, Influence and Accountability (TI&A) Consumer Standards
• Tenant Satisfaction Measures (TSMs)
• Social Housing (Regulation) Act 2023
• UK GDPR/ Data Protection Act 2018
• The Housing Ombudsman Scheme

The legislation listed in this policy is not intended to cover all legislation applicable to this policy. To comply with clause 1.1 of the Regulator of Social Housing’s Governance and Financial Viability Standard, which requires adherence to all relevant law, SNG will take reasonable measures to ensure compliance with all applicable legislation by reviewing policies and procedures and amending them as appropriate. Any queries relating to the applicable legislation should be directed to the policy owner.

11 - Review

This policy will be reviewed every 6 months for the first two years after it’s introduced, and at least once a year after that.

We may review it sooner if there are changes in law, regulation, Housing Ombudsman guidance or the way we deliver our services.

The policy owner is responsible for ensuring the policy remains accurate, effective and up to date.

Appendix A

Publication Scheme and Request Handling Summary

 SNG will publish information about our social housing services on our STAIRs webpage where it’s relevant, available and within the scope of STAIRs.

Customers and designated representatives can make a request for information that isn’t already available on the STAIRs webpage from 1 April 2027. Requests should be submitted using our dedicated online form once it’s available. If this isn’t possible, requests can be emailed to a dedicated email address - STAIRS_PS@sng.org.uk

SNG will support customers who need help making a request, including where a reasonable adjustment is needed. Responses will explain the request, the information disclosed, any information withheld or redacted, the reasons for withholding or redaction, and the right to request an internal review.

The publication scheme will include information about:

• Governance and decision making
• Spending
• Housing stock management
• Performance
• Housing services
• Lists and registers
• Social housing management 

We’ll keep this information under review and update it regularly.

A table listing the types of information that are included in the Publication Scheme is set out below (as required by the Policy Statement):

Some information may be out of scope of STAIRs. This includes information relating to local authority services, non-social housing activities, shared ownership homes where the customer owns 100% of their property, commercial premises, draft documents, wider commercial activities, or matters that don’t relate to SNG’s role as a social housing landlord. 

If a customer thinks information is missing from our STAIRs webpage, they can ask us to review it by emailing STAIRS_PS@sng.org.uk.  

We’ll aim to complete the review within 30 calendar days of receiving the request. In some circumstances, we may need additional time to complete the review.

If a customer is unhappy with the outcome of the review, they can refer the matter directly to the Housing Ombudsman.

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