Our tenants come from a range of national, ethnic and religious backgrounds, with varied disabilities and health conditions, as well as unique life experiences and circumstances. We are proud of that diversity and what it brings to our community.

However, like many social landlords, Wealden’s housing services were historically designed predominantly as a standard, “one-size-fits all” service. Whilst we have done a great deal to change that in recent years, we know we are not always able to meet the full range of our tenants’ diverse needs, particularly for those that have diverse needs and might not be able to ask for help.

This can give rise to a range of issues, but at its most serious, failing to adapt to meet tenants’ needs could result in their safety being put at risk. This strategy is all about making sure that we can identify when our tenants need us to adapt our services or provide them with additional support.

This strategy does not just consider our most vulnerable tenants, although they are an important part of the picture – we aim to ensure that all tenants have a safe home and a good landlord service from the Council, no matter what their age, background, disabilities, health conditions or life experiences. To do this, we need to further evolve the way we deliver our housing services to adapt to our tenants’ diverse range of individual needs.

This strategy supports the Council Strategy and Housing Strategy, including the commitment to providing high quality council homes and landlord services.

It also works alongside our Housing and Support Strategy –  Tenants and Leaseholders Housing & Support Strategy – Wealden District Council , the Corporate Reasonable Adjustment Policy for Customers (Wealden District Council’s Reasonable Adjustment Policy for Customers – Wealden District Council), the draft Equality, Diversity and Inclusion Policy, our commitment to Five Star Customer Service and a broad range of Housing policies, including our, Tenant Involvement Strategy, Aids & Adaptations Policy, Condensation & Mould Policy, Domestic Abuse Policy and Visiting and Inspections Policy.

The purpose of this strategy is to outline the steps we will take to:

• Understand the diverse needs of our tenants
• Ensure that there is equitable access to our landlord services for tenants and their household members
• Deliver fair and equitable outcomes for tenants
• Ensure our communication and information for tenants is appropriate to the diverse needs of our tenants

The following objectives set out the key ways in which we will achieve our aims. These objectives align with four themes that have been identified through the research, informed by the Transparency, Influence and Accountability Consumer Standards, and the feedback from the early engagement with residents, our housing board and other stakeholders. These form the structure of the strategy:

Treating tenants with fairness and respect – We will support our staff to consistently interact respectfully with tenants and ensure that there is a positive culture around diverse needs.

Identifying and reporting diverse needs – we will proactively recognise when reasonable adjustments are needed and provide these in line with our Reasonable Adjustments Policy.

Record-keeping and use of data– we will keep accurate records of tenants’ needs, that are accessible only to the people who need to see them. We will be transparent with our tenants about how their data is used and use the information we hold about them to understand if we are delivering services fairly and equitably.

Tailoring our services We will use the information we hold to adapt the way we deliver our services, including repairs and maintenance, complaints, tenancy management and resident engagement.We will ensure that tenants are offered reasonable adjustments when it will help them to access our services, their property or remove a barrier for them. We will record their individual needs to ensure they do not need to make multiple requests when interacting with different teams within our housing service.

Fair and Equitable Outcomes –  we will use data and reporting to assess whether services are delivering fair and equitable outcomes for all tenants. Taking action where this is not the case to understand why and put in place plans to rectify this. 

Transparency, Influence and Accountability Standard (Diverse needs)
 Our approach to diverse needs is designed to demonstrate delivery improvements against the Regulator of Social Housing’s Transparency, Influence and Accountability Standard.

1.2 Diverse needs  

1.2.1 In relation to the housing and landlord services they provide, registered providers must take action to deliver fair and equitable outcomes for tenants and, where relevant, prospective tenants.

 Specific expectations 

2.1 Diverse needs 

2.1.1 Registered providers must use relevant information and data to: 

a)understand the diverse needs of tenants, including those arising from protected characteristics, language barriers, and additional support needs; and 

1. b) assess whether their housing and landlord services deliver fair and equitable outcomes for tenants. 

2.1.2 Registered providers must ensure that communication with and information for tenants is clear, accessible, relevant, timely and appropriate to the diverse needs of tenants. 

 2.1.3 Registered providers must ensure that landlord services are accessible, and that the accessibility is publicised to tenants. This includes supporting tenants and prospective tenants to use online landlord services if required. 

 2.1.4 Registered providers must allow tenants and prospective tenants to be supported by a representative or advocate in interactions about landlord services. 

 We will improve our approach to delivering fair and equitable outcomes for tenants by:

• Improving the collection and use of relevant information and data to understand tenants’ diverse needs (including protected characteristics, language barriers and additional support needs) and to assess whether our services are delivering fair and equitable outcomes
• Ensuring communications are clear, accessible, relevant, timely and appropriate to tenants’ diverse needs, including making information available in alternative formats on request.
• Ensuring services are accessible, that we publicise how to access them, and that we provide support for tenants who need help to use online services.
• Making sure tenants and prospective tenants can be supported by a representative or advocate in interactions about landlord services.

Expected delivery improvements from this strategy include:

• earlier identification of unmet or emerging needs;
• more consistent application of reasonable adjustments across teams and contractors; fewer avoidable failures in communication and access;
• improved resident confidence to raise issues and use services; and
• clearer evidence (through data, feedback and scrutiny) that outcomes are fair and equitable for tenants with diverse needs.

Under the Public Sector Equality Duty (section 149 of the Equality Act 2010), we are required to have due regard to:

• eliminating discrimination, harassment and victimisation related to protected characteristics
• advancing equality of opportunity between people who share a protected characteristic and those who do not
• fostering good relations between people who share a protected characteristic and those who do not

The Public Sector Equality Duty relates to all protected characteristics under the Equality Act 2010, these are:

• age
• disability
• gender reassignment
• marriage and civil partnership
• pregnancy and maternity
• race
• religion or belief
• sex
• sexual orientation

Under the Equality Act 2010, we have an additional duty to make “reasonable adjustments” when requested to ensure that people with disabilities are not put at a substantial disadvantage in how they are able to access and use their property and how they access our services.

Our approach to making reasonable adjustments in relation to services is anticipatory rather than reactive. We consider in advance what the impact of our services and policies are on people and take reasonable steps to avoid causing disadvantage for people with disabilities.

However, while we take all reasonable steps to remove or reduce barriers that may disadvantage people with disabilities, we acknowledge the need to provide other reasonable support on a case-by-case basis to ensure tenants can access our services and their property.

The Council has a Reasonable Adjustments Policy which sets out our approach.

We aim to not only comply with our legal requirements, but to drive equitable access to our landlord services for tenants and their household members, improving safety and wellbeing among all tenants.

In practice this means making changes to the property or to how we deliver our services to ensure that the tenant is safe and benefits from their tenancy as they would if they did not have a disability.

This strategy goes further than the Equality Act to consider how we can make reasonable adjustments for other characteristics which can create barriers to accessing services.

Awaab’s Law, which came into effect in part in October 2025, requires social landlords to consider the interaction between a range of disrepair issues (although initially focussed on damp and mould) and the characteristics of the household, assessing whether the household has any additional risk factors and expediting assessment where those are found to be present. 

Under the Regulator of Social Housing’s Consumer Standards, we must treat tenants and prospective tenants with respect and deliver fair and equitable outcomes for residents with diverse needs.

We recognise that tenants or members of their household may have diverse needs or face barriers which can make it harder for them to do things like:

• Get in touch with us as their landlord
• Access services – e.g. repairs, mutual exchanges
• Take part in resident involvement activities
• Understand the communications we are sharing

There are many reasons why someone might face challenges with any of the above. Because this could be caused by one or more conditions or characteristics, we call these “diverse needs”.

This strategy sets out how we will gather information about our residents’ diverse needs, understand their needs, and adjust our services to make sure that they are not unfairly disadvantaged.

We have a basic understanding of our tenant profile, with characteristics including age, gender and ethnicity held for lead and joint tenants. 

Data on residents’ vulnerabilities and support needs is held for 16% of tenants, with any adjustments they may need to enable them to access services.

Table 1: Comparison of Age Distribution Between Wealden’s Tenants and Leaseholders and the profile of Wealden District residents

The age profile of our residents show a disproportionately older aged population compared to the district as a whole, with 69.7% of our residents over the age of 65 compared to 26.6% of the district’s residents.

The age profile of our residents means that we instinctively tailor services to meet the needs of older residents.

 Table 2: Comparison of Gender Distribution between Wealden’s Tenants and Leaseholders and the profile of Wealden District residents

Table 3: Comparison of Ethnic Group Distribution between Wealden’s Tenants and Leaseholders and the profile of Wealden District residents

As a district, there is a high proportion of residents identifying as white British at 91.8% with lower numbers of other ethnic groups.  At a basic level, the profile of our residents appears to align with the district profile, however, we lack recorded ethnicity data on 46.4% of tenants. This data gap will be addressed through the action plan.

The improvements we are making through this strategy and action plan will enable a better understanding of the diverse needs of our residents, and improve our ability to deliver services in ways to suit their needs.

Reasonable adjustments are changes we make to how we do things, to remove barriers and support someone who has a particular need. This includes:

• Changes we make to how we deliver our services to ensure they meet the needs of that individual
• Physical changes to a property or block to ensure that individual can use and access their home

Each case will be assessed and agreed on a case-by-case basis, in collaboration with the tenant.

We work with the individual tenant to understand their needs and agree with them the reasonable adjustments that can be put in place to support them.

The following table sets out how some common diverse needs that can lead to additional support, as well as some practical examples of reasonable adjustments that our housing teams are already putting in place:

Table 4: Example reasonable adjustment scenarios

We recognise the importance of better understanding and responding to the diverse needs of our tenants, and a range of positive actions are already underway.

Our 2023/24 self-assessment against the Regulator’s Consumer Standards, found gaps against the Diverse Needs expectations of the Transparency, Accountability and Influence Standard and this was identified as a Priority Action – one of five key priorities identified by the self-assessment. Our Housing and Tenants Together Board has oversight of these key priorities, with quarterly updates provided to the Board.

It was apparent at the time that the Council’s housing management system held limited up-to-date data about the diverse needs of our tenants and our legacy systems lack the capability to act on the data held. This gap has impacted our capacity to effectively identify and support tenants with diverse needs, and for ensuring that communications and our service offer are accessible and appropriate to the diverse needs of tenants. 

One of the ways we have been working to address this, is through investment in a new housing management system. Following formal procurement processes in 2023, the new system ‘Housing One’ is currently in phased implementation. Housing One replaces four very long-term legacy systems and involves significant data migration and setup to ensure that it works effectively for our teams and our tenants. The system will enable consistent recording, reporting and use of data on tenants’ diverse needs and protected characteristics. This work is being shaped with tenants through our Consumer Panel to ensure data is collected sensitively, kept up to date, and used appropriately.

In time, the system will provide the service with a single database for all tenant information and streamline the process of recording individual tenant needs and agreed adjustments. As the name suggests, this will be one system, ensuring that the customer experience is the same regardless of their point of contact. So in practice, if we know the tenant has diverse needs, this will be known to all our teams, including (when necessary) our contractors (in accordance with General Data Protection Regulations).

Alongside this, we already make extensive use of transactional and perception surveys, including new tenant, repairs and anti-social behaviour surveys. Feedback from these surveys is actively used to monitor service delivery and we plan to further integrate this activity through Housing One to improve efficiency and insight.

We are also strengthening tenant involvement and inclusion. Tenants have contributed to national research led by TPAS on barriers to engagement for harder-to-reach groups, helping inform our approach to trust, communication and understanding diverse needs.

Our Tenants’ & Leaseholders’ Housing & Support Strategy, refreshed in 2024 following tenant engagement, provides a structured and proactive framework for identifying and supporting tenants who may need additional help.

Practical initiatives such as Tenancy Visits have proved particularly effective in identifying support needs and unreported repairs, with 346 visits completed in 2025. We also use digital tools such as TPTracker to share time‑sensitive information, and our website has been reviewed with tenants to improve accessibility and usability.

Recent analysis by Inner Circle Consulting for the Council has identified the following in relation to current practice at Wealden –

“The most significant gap in the [Consumer] standards relates to capturing suitable diversity data and acting upon it

You meet diverse needs well when they are known through individual cases. The opportunity now is to identify unmet or emerging needs earlier and at scale, and evidence how this insight shapes decisions and outcomes across the service. This is already progressing, including consultation with the Consumer Panel on which measures to track, and inclusive by default practice such as accessibility improvements and plain language communications.

• Move from case-by-case knowledge to an aggregated, strategic-level “zoomed out” picture
• Evidence the impact on prioritisation, service design and outcomes”

This analysis reflects feedback from our tenants (through complaints, tenant satisfaction surveys, our consumer panel and individual tenant conversation), from our Housing Board and from our own staff.

Helpfully, the Inner Circle report identifies a recommended path forward to assist –

“Strengthen resilience by making the service model clear, repeatable and less person-dependent. The focus is strengthening the connection between formal controls and relational practice so the service can scale what works, withstand churn and respond to future pressures, including local government reform.”

Inner Circle’s review concluded that Council is currently doing a good job of responding to the needs of individual tenants because our staff know our tenants and any support needs they have. However, this information is not held as centrally as it should be to ensure a robust system.

Finally, we recognise a need to use data to its full extent to ensure that we are delivering fair and equitable outcomes  in the most efficient & repeatable way and identifying people/groups that we can support better without them needing to request specific support.

Taken together, these actions provide a strong foundation on which to develop a more consistent, data-led approach to delivering fair and equitable outcomes for residents with diverse needs.

This section sets out the key actions that we plan to take, what problem we are working to overcome, the relevant timeframe, who is responsible and criteria for success.

It is important to acknowledge that this action plan remains an iterative document. Part of the challenge posed by having insufficient data is that we will not know at this stage the full set of interventions necessary to better support our tenants.

The first iteration of the action plan will therefore necessarily focus on closing effectively the data gaps, whilst setting the foundations for further targeted action.

This strategy and action plan will remain dynamic and be updated as we collect and analyse the data, but also as our tenants change over time.

We will review progress against the action plan, including updating the actions themselves as we develop our understanding of our tenants. The strategy itself will then be reviewed every three years, taking account of any new best practice, or sooner if there are any major legislative or other changes that dictate a different approach.

Action Plan