Data in demand: stakeholders may have different asks, but the foundations remain the same

From a regulatory perspective, the cornerstone for an RP’s compliance with the new proactive consumer regime is having up-to-date, comprehensive data on stock and tenants.

The reason this is required is because, in the view of the Regulator of Social Housing (RSH), it is impossible for RP boards to have assurance that they are providing tenants with safe homes and a good service if they don’t know what the current position is ‘on the ground’.

This is a particular challenge for boards of larger RPs, which can have tens of thousands of homes to keep on top of. 

RPs’ funders are also increasingly keen to see RPs’ data. While funders have always sought high-quality data about their borrowers, this has been heightened with the ongoing prevalence of sustainable finance. 

With its clear social purpose, the social housing sector is rightly viewed by funders as a natural fit – but as greenwashing regulations tighten, it is fundamental that such funding arrangements are underpinned by comparable data that is both quantitative and qualitative. 

For sustainability-linked finance, identifying and reporting on KPIs that are genuinely stretching (not ‘business as usual’) will require a full picture of the RP’s environmental, social and governance credentials and its direction of travel. Quality data must be collated from across the entire organisation. 

RPs may find it helpful to work with a third-party verifier to set and monitor appropriate baselines (and funders may require this).

Indeed, adopting and working to the Sustainability Reporting Standard for Social Housing – itself recently updated with a view to aligning more neatly with the Task Force on Climate-Related Financial Disclosures – may also assist. 

Even for finance not expressly badged as ‘sustainable’, requests from investors for sustainability data are only likely to increase as funders are themselves subject to ever-increasing scrutiny about who they lend to and on what terms.

The requirements of the Building Safety Act 2022 have also led to a greater focus on data. Following the Grenfell tragedy, during which key building safety information was unavailable to fire rescue services on the ground, the concept of the ‘golden thread’ of information was introduced to require key information relating to the building to be easily accessible in a digital format.

However, the actual detail about what information makes up the golden thread is scattered across various schedules to secondary legislation. Add to this the requirement for the golden thread to be made available to residents in part, and in full on request.

The result is a formidable requirement on RPs to collate, store and maintain a large quantity of complex technical documents in a way that is accessible and useable for a variety of stakeholders including fire and rescue services, maintenance teams, residents, regulators and potentially future purchasers.

The practicalities of hosting the data are also fraught with difficulties relating to file size, back-ups, security and ownership of the documents if the data host becomes insolvent.

Yet this requirement is clearly borne from very real and necessary need. Finding a way to manage the data and present it to meet that need will, however, present challenges.

The bottom line is that just because the data requests are coming from different stakeholders, this doesn’t mean that they are actually looking for different things – for example, data on a building’s safety may be as important to the RSH as it is to the Building Safety Regulator.

Rather than considering each request in silo, a joined-up approach that recognises each stakeholder’s drivers will also be the most effective at delivering the information they need, making everyone’s life easier.

Matt Cowen, senior associate, and Gillian Hocking, associate, Winckworth Sherwood