Data challenges of the Building Safety Bill
Data challenges of the Building Safety Bill
In the course of my job I get to speak to a lot of Compliance Managers in the social housing sector. On the whole they are a dedicated and determined group of individuals who consume vast quantities of data generated by the ongoing operations of the average social housing enterprise. If the corporate mission of a social housing organisation could be mischievously summarised as to “collect the rent and keep everyone safe” they are clearly focussed on the latter.
As the implications of the Building Safety Bill hove into view they are now preparing for a significant step change in the corporate mission as it becomes painfully evident that all the components of building safety require the same fastidious approach as previously afforded to gas safety.
The data challenges of evidencing gas safety compliance are well known and the Regulator of Social Housing routinely “outs” well known organisations for a failure to provide even cursory evidence of a gas safety inspection, the Landlord Gas Safety Certificate, for each property the organisation owns each year.
The draft Building Safety Bill makes it clear, initially for high risk buildings, that these data challenges of evidencing that “someone, went somewhere, and did something” in a timely fashion are required for the other components of building safety. This week is Fire Door Safety week and fire doors are highlighted as requiring up to quarterly inspections for both communal and private spaces in high risk buildings. Evidencing this is a challenge way beyond gas safety.
Whilst currently framed against only high-risk buildings, the draft Building Safety Bill is a framework bill which means it will be probably augmented over time to cover other buildings. Organisations will have to consider whether, in the meanwhile, it is ethically right to have different levels of safety for tenants in different types of buildings.
Going back to the data challenges, Compliance Managers are glumly contemplating whether current systems, relying as most do on a number of spreadsheets running in the background, will ever help them sleep comfortably at nights or take that post-Covid long holiday in the sun.
Software suppliers are inevitably keen to assist by either offering modules to existing systems or in the case of my own company specific packaged cloud solutions to support this challenge. Whilst the former look enticing they will usually require a period of consultancy for the organisation to define what is actually required. This is understandably difficult as the nature of unfolding legislative requirements make this akin to hitting a moving target. Waiting for clarity is also ruled out as the sector is encouraged to get on and do something.
Packaged cloud solutions are an attractive alternative, offering the opportunity to join up the data for all areas of compliance current and future. Some of these are based on centralising data gathered from disparate sources in the field and logic checking. Whilst this is a step forward it is still based on a quality control methodology, identifying looks right and what looks wrong.
A quality assurance approach of getting it right first time would generate benefits for tenants (who already probably receive more visits than they would probably want from their landlord without repeat visits to put something right). The Social Housing provider or their contractors would benefit from not having the cost and challenge of regaining access to the property. Compliance Managers will also worry that different contractors will do things in different ways and arguably tenants will receive different standards of safety inspection.
Combining a field application with defined current best practice and a focus of ensuring only accurate data is input together with a reporting tool specifically designed around compliance seems like the correct long term choice to quality assure management of this activity. These tools will be upgraded (usually for free) as standards change and promote sharing best practice across the sector. With COVID hastening all sorts of changes in working practices, Compliance Managers I talk to about such a system feel that now seems the right time. Certainly, it is better than creating another generation of spreadsheets and VLOOKUPs to combine static data from disparate sources.
However, for Compliance Managers promoting such new systems internally is a task that can be fraught with barriers. Protecting the organisation from unexpected “compliance failure” is not a magic trump card and arguing that introducing such systems would make working life better is seldom sufficient. Boards who protect their organisation from additional IT systems simply expose their organisation to further spreadsheets as Compliance Managers will try and make sense of what the organisation is actually doing. This is odd given that a compliance downgrade is usually accompanied by executive Directors moving on and finance directors paying additional interest on corporate debt but return on investment on such systems is perhaps the subject of another blog.
So in summary how do I think organisations should respond to the data challenges of the Building Safety bill.
- Firstly, you should understand the difficulties of translating draft legal requirements into policy and thence into systems that evidence compliance with policy. The role of IT departments should be to collaborate with their Compliance Managers in delivering solutions.
- Second you should understand this is an area of evolving requirements. Hard coding a fixed solution or creating your own bespoke solution at a point in time is only going to incur ongoing projects to keep pace as the requirements change. Subscription to packaged solutions is likely to be more cost-effective in the long term even if you avoid the ignominy of a downgrade to your governance ratings.
- By thinking about this as only a data reporting issue you are perpetuating the problems of poor quality data being entered and by tweaking existing systems you are likely missing the opportunity to make a step change toward a quality assurance type culture.