The main points
- We treat everyone fairly. We will not treat you worse because of who you are.
- If you need us to do something differently so that you can manage, ask us. This is called a reasonable adjustment.
- You do not have to explain your diagnosis to ask. Just tell us what would help.
- We will make a note of what you need.
- You can ask for this handbook on paper, in a bigger size, in easy read, or in another language.
Treating you fairly
We will not treat you worse because of who you are.
The law protects you. It says nobody should be treated worse because of:
- their age
- being disabled
- being transgender
- being married or in a civil partnership
- being pregnant, or having had a baby
- their race, colour or where they come from
- their religion or what they believe
- being a man or a woman
- being gay, lesbian, bisexual or straight
This applies to us. It also applies to the people who work for us, and to anyone doing work in your home.
If you think we have treated you unfairly, please tell us. Section 14 explains how to complain.
Help that suits you
Some people need things done a bit differently. That is normal, and it is fine to ask.
The law calls this a reasonable adjustment. It means we change how we do something so that you can manage it as well as anyone else.
Here are some examples. You can ask for these, or for something else.
Letters and information
- letters in a bigger size
- letters in easy read, with pictures
- letters in another language
- a phone call instead of a letter, or a letter instead of a phone call
- a text message to remind you about an appointment
Appointments and visits
- always the same day of the week, or the same time of day
- a longer appointment, so you are not rushed
- telling you the name of the person who is coming, before they come
- the same worker each time, where we can
- extra warning before a visit
- your support worker, a relative, a friend or an advocate with you
Talking to us
- someone to speak on your behalf
- more time to answer
- being asked one question at a time
- a quiet place to talk
Things in your home
- a different type of handle on a door or a tap
- furniture moved
- a grab rail, after advice from an occupational therapist
You do not have to use the words "reasonable adjustment". Just tell us what would help.
How to ask
- Tell us what you find difficult, or what would help.
- Tell us in whatever way is easiest. You can ring us, email us, write to us, or tell us in person.
- Your support worker, a relative, a friend or an advocate can ask for you.
- We will talk to you about what we can do.
- We will write down what we have agreed.
- We will give you our answer as soon as we can.
You do not have to prove anything. You do not have to show us a letter from a doctor. You do not have to tell us your diagnosis. You can if you want to, but you do not have to.
We make a note of what you need
When we agree an adjustment, we make a note of it.
If you find you are having to ask again and again, please tell us. That means we have got something wrong, and we want to put it right.
If we cannot do what you ask
Sometimes we cannot do exactly what you ask for. If that happens, we will:
- tell you why, in a way you can understand
- talk to you about what else might help
- put our answer in writing if you want us to
- tell you how to complain if you are not happy
We will not just say no and leave it there.
Changes to the building
Sometimes a person needs a change to the building itself. For example, a ramp, a walk-in shower, or a stairlift.
These are called adaptations. They work differently from the changes described above.
Here is what to do:
- Tell us, and tell your support worker.
- Ask your support worker to contact adult social care at the council.
- An occupational therapist will visit and look at what you need.
- The council decides what help you can get. There may be a grant.
- We will work with the council. We have to give our permission as your landlord. We will deal with your request promptly, and we will not refuse without a good reason.
This can take a while. Please ask as early as you can.
Information you can understand
We want our information to be easy to understand.
You can ask us for this handbook, or any letter from us:
- on paper
- in a bigger size
- in easy read, with pictures
- in another language
- as a sound recording, so you can listen to it
- as an email or a computer file, so you can change the size yourself
Just ask us or ask your support worker. You do not have to explain why.
Having someone with you
You can have someone with you when you deal with us. That might be:
- your support worker
- a relative or a friend
- an advocate
An advocate is someone whose job is to speak up for you. They are independent. They are not part of Harbour Light, and they are not part of your support provider.
Advocacy is usually free. Your social worker can usually help you find an advocate. Your support worker can help you contact them. We can also tell you about organisations that may help.
If you want someone to speak to us on your behalf, we will usually need you to tell us that first. This is to keep your information safe. Your support worker can help you do this.
Your information
We keep information about you. The law says we have to look after it properly.
You have the right to ask to see the information we keep about you. If you want to do that, ask us or ask your support worker.
We will not share your information with other people unless we have a reason to. There are sometimes when we have to share it — for example if we are worried that someone is being hurt. Section 12 explains more.
If you think we have got it wrong
If you think we have treated you unfairly, or we have not made an adjustment you needed, please tell us.
You can complain. Section 14 explains how. Complaining will not cause you any trouble, and it will not put your home at risk.
You can also go to the Housing Ombudsman. You can do that yourself. You do not need anyone's permission.
If you think you have been discriminated against, you can get free advice from the Equality Advisory and Support Service, or from Citizens Advice. Section 18 has their contact details.
More detail
This box is for tenants who want more detail, and for support staff, relatives, advocates and social workers. You do not need to read it to understand the section above.
Protected characteristics. Section 4 of the Equality Act 2010 lists the protected characteristics: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; and sexual orientation. Section 6 defines disability as a physical or mental impairment which has a substantial and long-term adverse effect on a person's ability to carry out normal day-to-day activities. Learning disability, autism and long-term mental ill health may all meet this definition.
Harbour Light's obligations as a landlord. Part 4 of the Equality Act 2010 applies to the management and disposal of premises. Section 15 provides that unfavourable treatment because of something arising in consequence of a person's disability is discrimination unless it is a proportionate means of achieving a legitimate aim, and unless the landlord did not know and could not reasonably have been expected to know of the disability.
Reasonable adjustments — scope and limits. The duty in section 20 of the Equality Act 2010 is applied to premises by Schedule 4. Three points matter in practice:
- The duty covers provisions, criteria and practices, and the provision of auxiliary aids and services. In a housing context this is the substantial part of the duty — how the landlord communicates, arranges appointments, makes decisions and enforces terms.
- The duty arises only where a request is made by or on behalf of the tenant or a person entitled to occupy (Schedule 4, paragraph 2(6)). This differs from the anticipatory duty owed by service providers. Harbour Light may nonetheless choose to act anticipatorily as a matter of good practice, and this section is drafted to invite requests rather than wait for them.
- It is never reasonable to require the removal or alteration of a physical feature of let premises (Schedule 4, paragraph 2(8)). However, "physical features" for this purpose exclude furniture, furnishings, materials, equipment and other chattels (paragraph 2(9)) — so adjustments to those are within scope. Where a term of the letting prohibits the tenant from making alterations and that puts the disabled person at a substantial disadvantage, the landlord is required to change the term so far as necessary to enable the tenant to make the alteration (paragraph 2(7)).
This is why structural adaptations are routed through the local authority rather than treated as reasonable adjustments.
Common parts. Section 36 of and the associated common parts provisions in Schedule 4 to the Equality Act 2010 would create a duty to make reasonable adjustments to physical features of the common parts of let residential premises. These provisions have not been brought into force in England and Wales. This is relevant to Harbour Light's shared houses.
Adaptations. Assistance with adaptations is generally sought through the local authority, including the Disabled Facilities Grant regime under Part 1 of the Housing Grants, Construction and Regeneration Act 1996, following an assessment by an occupational therapist. The landlord's consent is required for alterations under the tenancy agreement (clause 2.7), which provides that consent will not be refused without good reason.
Regulatory standards. The Regulator of Social Housing's Transparency, Influence and Accountability Standard, in force from 1 April 2024, includes required outcomes on fairness and respect and on the diverse needs of tenants, and on information about landlord services. Registered providers are expected to be able to demonstrate compliance.
Accessible information. The NHS Accessible Information Standard applies to health and adult social care providers. It does not legally bind Harbour Light in its capacity as a landlord. Harbour Light adopts its principles voluntarily. This should not be described to tenants or in policy documents as a legal obligation on Harbour Light.
Complaints. The Housing Ombudsman's Complaint Handling Code, which has been statutory since 1 April 2024, expects landlords to make reasonable adjustments in the complaints process itself. See Section 14.
Public sector equality duty. Whether the public sector equality duty under section 149 of the Equality Act 2010 applies to Harbour Light depends on whether, and when, it is exercising public functions. The position for private registered providers is not straightforward and is not resolved here.