independent complaints reviewer (icr) for land … · complaints reviewer (icr) office – in spite...

RICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICCRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICCRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICCRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICCRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRIRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICCRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRICRI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Independent Complaints Reviewer(ICR) for Land RegistryAnnual Report 2014/15

Large printPlease contact the ICR office if you require a copyof this report in large print.

Other versionsPlease contact the ICR office if you require a copyof this report in Braille or audio, or in otherlanguages.

Further informationFull details of the service that the ICR provides canbe found in our booklet, Seeking a fair resolution,which can be downloaded from the ICR’s website atwww.icrev.org.uk

Independent Complaints Reviewer for Land RegistryAnnual Report 2014/15

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Contents

1 Introduction2 The ICR service3 Facts and figures4 Casebook

1 Introduction

Elizabeth A Derrington

I am proud to report that 2014/15 was a veryproductive and successful year for the IndependentComplaints Reviewer (ICR) office – in spite ofsignificant challenges. We carried out more full-scaleinvestigations than last year and also helped manycustomers to get problems resolved without theneed for a full review, for example by contactingLand Registry to enquire about the progress of anapplication. In addition we completed cases muchmore quickly and reduced costs.

We received some very positive feedback fromindividual customers – even in cases where we wereunable to provide the result they wanted. And whileit is disappointing that several customers weredissatisfied with the results of our investigations, andreferred their complaints to the ParliamentaryOmbudsman (PHSO) as the final authority on public

sector complaints, in each of these cases, after anin-depth review, PHSO agreed with our findings andrecommendations and confirmed that the ICR officehad done a good job. This was a very powerfulendorsement of the skill and effectiveness of the ICRteam. And, last but not least, we achieved all of thiseven though we moved out of our office in DoverHouse in May 2014 and spent the rest of the yearwithout a permanent base.

Of course the ICR deals only with a tiny proportionof Land Registry customers. I know that the greatmajority are very satisfied with the service LandRegistry delivers. But difficult and unusual cases arevery useful for testing systems and pointing to waysof making them work better for customers.

My recommendations during the year highlightedopportunities for Land Registry to make itsprocedures more robust and to improve its serviceto customers. Land Registry’s own working group,the ICR Review, Evaluation and Study Team(ICREST), has taken on these recommendations –deciding the best way to implement them and thenfollowing progress to make sure that the necessarysteps are completed.

During 2014/15 ICREST has been active inimproving Land Registry’s communication withcustomers in relation to boundaries, adversepossession, amendments to title plans, identityrequirements and searches of Land Registry’s indexmap. I continue to meet regularly withrepresentatives of ICREST to look at progress onrecommendations and ensure a sharedunderstanding of issues.


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Land registration law is complex and this can makeit difficult for customers to appreciate the reasons forits decisions. Two developments in 2014/15 shouldmake things easier.

First Land Registry’s website moved to GOV.UK inAugust 2014 and as part of the process much of thecontent was rewritten to make it simpler tounderstand. This is a really good idea and much ofthe information on GOV.UK is excellent. Butexplaining complex points in plain language is trickyand can cause confusion through over-simplification.

The Public Guides on specific topics published onLand Registry’s website, which were valuable fortheir clear explanations of complex points in non-technical terms, are no longer available throughGOV.UK. I have been supporting Land Registry in itswork with the Government Digital Service to improvethe content on GOV.UK, spotting and correctingstatements that may be confusing or misleading andincluding fuller information on key topics.

Second, a specialist Citizen Centre at Land RegistryWales Office was set up to deal with applicationsmade directly by members of the public rather thanby conveyancing professionals. This means thatcustomers who wish to handle matters themselvesare able to deal with staff who are focused on theneeds of citizens rather than of professional usersand who have developed skill in explaining technicallegal processes in plain language. I am planning tovisit the Citizen Centre early in 2015/16 to learnmore about how things are done there and toprovide feedback from my perspective as aspecialist in complaint resolution.

Turning to the wider landscape of complainthandling and alternative dispute resolution, theCabinet Office, in response to recommendations bythe Public Administration Select Committee, hasbeen looking over the last year at ways to make iteasier, across the public sector, for customers tocomplain. Land Registry is working with the CabinetOffice and the Department for Work and Pensions topilot new approaches and ideas. I very muchwelcome Land Registry’s involvement in thisimportant project. Its experience over many years ofdeveloping its own complaints process into a highlyeffective tool for learning the lessons of complaintswill enable it to make a strong contribution.

Another Public Administration Select Committeereport led to the publication in March 2015 of aconsultation on the establishment of a single PublicSector Ombudsman as the final reviewer for publicsector complaints. This proposal recognises that theincreasing complexity of arrangements for publicservice delivery needs to be balanced by simplifiedaccess for members of the public to proper redress.If the plans are implemented they will mean thatcomplainants who are dissatisfied with an ICRreview can refer the case to the Ombudsmanthemselves without having to go through an MP. Iresponded to the consultation expressing strongsupport for the proposals and also highlighting therole of intermediate complaint reviewers such as theICR in supporting and facilitating the role of theOmbudsman.

In addition regulations effective from 1 July (as aresult of a European Directive on Alternative DisputeResolution) will require all ‘traders’ to providecustomers with access to independent complaint


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review. This will fill an important gap in thecomplaints landscape and will mean that allcustomers, whether in the public or private sector,will be able to obtain independent help with theircomplaints.

So overall it is a time of reform and opportunity in theworld of complaint-handling. All the changes I havementioned have the potential to increase awarenessand understanding of the right to complain amongmembers of the public, and to ensure consistentlyhigh standards of objectivity and professionalismwhichever complaint handler they turn to for help.

Outside the direct scope of my role with LandRegistry I have continued to work in other areas ofcomplaint-handling policy and practice. I serve as anelected member of the Executive Committee of theOmbudsman Association for the UK and Ireland,working to promote shared values and standardsacross the sector. I also provide complaint reviewservices for the Solicitors Regulation Authority andthe Scottish Public Services Ombudsman.

In conclusion I should like to express my sincerethanks to the members of the ICR team for theirdetermination to maintain excellent service to ourcustomers during the disruption caused by our officemove, their inventiveness in finding solutions to allproblems and their unfailing cheerfulness even whenseverely tested by circumstances. I am pleased toreport that as the end of the year approached wewere able to look forward to settling into longer-termaccommodation at 1 Victoria Street, home of LandRegistry’s sponsoring department (Business,Innovation and Skills) and also of the ShareholderExecutive.

Elizabeth DerringtonIndependent Complaints Reviewer for LandRegistryJune 2015


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2 The ICR service forLand RegistryCustomers

Our missionTo seek a fair resolution of complaints.

Our purposeTo provide a free, effective and impartial complaintsreview and resolution service that settles complaintsin a proportionate manner and makes a positivedifference for future Land Registry customers.

People can expect from the ICR team:— courtesy— honesty— respect— objectivity— plain language.

The principles of good complaint handlingThe Ombudsman Association’s principles of goodcomplaint handling underpin the process I carry outwhen reviewing a complaint. They are:— clarity of purpose: each review includes a clear

statement of its purpose, intent and scope— accessibility: the service is free, open and

available to all who need it— flexibility: procedures are responsive to the

needs of individuals— openness and transparency: we provide public

information that demystifies our service— proportionality: the process and resolution are

appropriate to the complaint

— efficiency: the service strives to meet challengingstandards of good administration

— quality outcomes: complaint resolution leads topositive change.

When I carry out a review, I also take into accountthe ‘FREDA’ principles of human rights fairness,respect, equality, dignity and autonomy.

Our officeIt is vital to my independence that I am not part ofLand Registry or a civil servant. The service Iprovide is under the terms of a contract and servicelevel agreement with Land Registry, and I ampersonally responsible for all conclusions andrecommendations that come from complaintreviews. I am supported by a small team of staffseconded from Land Registry but directly line-managed by me. These staff bring to the office thebenefit of their knowledge of Land Registry practiceand procedure and the legislation under which LandRegistry operates.

Our remitAnyone who has made a complaint to LandRegistry and is dissatisfied with the outcome canask me to review the matter. However, I cannotreview or overturn Land Registry’s legal decisions,or investigate issues that are subject to proceedingsbefore the Property Chamber1 or any other court. Inaddition, I will not generally be able to accept areferral made more than six months after the date ofthe final complaint response from Land Registry.


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1 From 1 July 2013, the Land Registration Division of the PropertyChamber, First-tier Tribunal, took over the functions of the Adjudicatorto HM Land Registry. It is part of HM Courts and Tribunals Serviceand, like the Adjudicator, is entirely independent of Land Registry.

Initial enquiriesBefore a complaint is accepted for review, apreliminary investigation is carried out to determinewhether or not the complaint is one that falls withinmy remit. This may involve discussion with thecomplainant to find out more about his or hercontinuing areas of dissatisfaction, and to gain anunderstanding of the outcome the complainant ishoping to achieve. It may also be necessary tomake enquiries of Land Registry in order to clarifythat its internal complaints procedure has been fullycompleted. If the complaint is not one that I canconsider, we will offer advice to the complainant onoptions for pursuing the matter.

Full reviewWhere there is a full review, a summary of the issuesis sent out to the complainant for agreement. This isto make sure there is a clear, shared understandingat the outset of the areas to be addressed. A copyof the summary is also sent to Land Registry. All theavailable information is then analysed in detail and Iconsider whether the concerns that have beenraised are justified.

The outcome of the review is a report sent at thesame time to the complainant and to Land Registry,giving my conclusions and any recommendations.The aim of a report is to set out, in as clear andstraightforward a manner as possible, my opinionon the way in which matters have been handled byLand Registry, and to provide redress in appropriatecases. Both the complainant and Land Registryhave the opportunity to comment on a draft beforethe report is finalised.

RedressI have three main forms of redress at my disposaland these are:— that Land Registry should take specific action to

help put things right for the customer – forexample by apologising or providing extrainformation or explanation

— that Land Registry should make a consolatorypayment (maximum £7,500) in recognition ofdistress and inconvenience experienced as aresult of shortcomings in the service provided byLand Registry

— that Land Registry should consider practicalchanges to improve customer service andreduce the risk of similar problems in future.

In deciding when to consider making a consolatorypayment, I have regard to the ICR office’s FinancialRedress Policy. The sums paid are relatively smallsums to reflect the distress and inconvenience anindividual may have suffered. They are fixedaccording to the seriousness of any service failuresidentified, as well as the particular circumstances ofthe individual complainant.

The table below gives an overview of the work ofmy office in 2014/15, comparing it with the figuresfor 2013/14.


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3 Facts and figures

As can be seen from the above table, a number ofcomplaints are not accepted for investigation. Thereasons for this include:— the complainant has not received a final

response from Land Registry. In thesecircumstances, we will refer the complaint backto Land Registry to provide one

— the outcome sought by the complainant is notone that the ICR can provide and may beachievable only by taking action in the courts

— the complainant has referred the complaint forreview after the normal six-month time limit hasexpired, or

— we have been able to secure an acceptableoutcome for the complainant without the needfor carrying out a full review (resolved throughintervention).

We also receive many complaints that are not aboutLand Registry. In those circumstances my staff usetheir knowledge of the wider complaints resolutionsector to guide the complainant to the mostappropriate organisation that may be able to assist.

The following table compares the number ofspecific complaint issues and their outcomes withthose of previous years.

RecommendationsMy recommendations to Land Registry aredesigned to provide redress to individual customersand also to help Land Registry improve its systemsand procedures to reduce the risk of similarcomplaints recurring in future. During 2014/15 Imade 28 recommendations to Land Registry andthe categories in which they fall are set out in thetable below.


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Year Investigatedcomplaintsreported on

Total issues

Issuesupheld orpartiallyupheld

Issues notupheld

2014/15 28 722 23 (32%) 45 (63%)2013/14 22 55 18 (33%) 37 (67%)2012/13 29 57 14 (25%) 43 (75%)2011/12 30 97 24 (25%) 73 (75%)2010/11 30 110 35 (32%) 75 (68%)

2014/15 2013/14

Complaints received 139 127

Complaints resolved throughintervention

11 13

Complaints acceptedfor investigation

42 29

Investigated complaintsreported on

28 22

Investigated complaintsreported on: fully upheld

5 1

Investigated complaints reported on:partly upheld

10 12

Investigated complaints reported on:not upheld

13 9

2 No decision was made on four complaint issues – either becausethere was insufficient information to make any finding or, on oneoccasion, because the ICR did not consider the matter within herremit but carried out a review in order to enable a referral to theParliamentary Ombudsman.

Land Registry has continued to respond positivelyand has given serious consideration to all myrecommendations – even where, in the case ofrecommendations for systemic improvement, it hasultimately decided that the action proposed wouldbe impracticable. ICREST continues to facilitate andmonitor the implementation of systemicrecommendations. I have been impressed by itsability to draw lessons from all aspects of myreports, even regarding issues which had notformed part of the actual complaint.

Feedback from customersFeedback for us – as for Land Registry – isextremely important in improving the quality of theservice we provide. With all completed reports weprovide feedback questionnaires. During the lastyear the completion of the questionnaires has beenvery low, so we are now looking at better ways torecord the level of satisfaction with our service.Nonetheless we take seriously all of the commentsthat we have received.

Levels of customer satisfaction tend to reflect theextent to which I have been able to assist inachieving the customer’s desired outcome. Onecustomer in 2014/15 said: “I am really grateful forthe fact that my complaint has been upheld, but thefact that the compensation is only £1,000 isdistressing.” This highlights the importance of ourstressing throughout the investigation process that Ihave no power to award compensation for anyfinancial loss a complainant may have suffered –that is a matter for the courts. As I mentioned in theintroduction, we have also received positivefeedback from the Parliamentary Ombudsman whohas investigated reports referred to it by customerswho, unfortunately, remained dissatisfied with theoutcome.

On the other hand, where I have found servicefailures by Land Registry and have maderecommendations for redress, we receive morepositive feedback. One complainant referred to thestress he had experienced in seeking to resolveproblems that had arisen following Land Registry’sfailure to follow its normal process and said: “It isreassuring to know that offices such as yours arethere to help and protect the public in suchinstances.”

As I have said we also try to help by interveningmore informally. During a year which has seen asignificant rise in the number of applicationsreceived by Land Registry, more people than usualhave contacted us with concerns about delays inprocessing matters. Sometimes they haveexplained their frustration at not being able to speakto someone who can tell them what is happening


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Recommendation type 2014/15 2013/14 2012/13 2011/12

Apology 36% 35% 45% 34%

Consolatory payment 32% 23% 37% 23%Review procedures/guidance

14% 11% 7% 11%

Remind staff of existingprocedures/guidance

7% 16% 7% 7%

Review/improve publicinformation

7% 11% 4% 14%

Other 11% 4% 0% 11%

with an application which, in turn, has been holdingup a conveyancing transaction. We have assistedboth individual members of the public and legalfirms who have found it difficult to find theappropriate people at Land Registry to speak to.One complainant told us: “With one email you'vegot further in one day, than we have in threemonths."

Our speed of serviceWhile we seek to provide a swift response to allenquiries, formal investigations can be extremelytime-consuming. We look at all the paper andelectronic files relating to a complaint; they are oftenconsiderable and extend over many years. We alsoneed to allow time at each stage of the process toallow for the complainant and for Land Registry toprovide comments. Our target is to complete aformal investigation within 26 weeks from the datethat I have agreed the complaint is within my remit.In 2012/13 we had reduced the average time takento complete an investigation to 22 weeks; this wasreduced to 20 weeks in 2013/14 and in the lastyear the average time has fallen still further to 19weeks.

Financial informationAs already mentioned my office is manageriallyindependent from Land Registry.The following table compares expenditure over thelast four years and demonstrates our continuingefforts to manage our budget as effectively aspossible and provide good value for money.


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3 Includes accommodation costs.4 This includes a refund of rent paid for our former office.

ICRRunningCost

Staff Costs Administration3 Total

2014/15 £190,547 -£2794 £190,2712013/14 £181,857 £42,556 £224,4132012/13 £178,358 £47,355 £225,7132011/12 £174,858 £50,801 £225,6592010/11 £167,407 £53,704 £221,111

4 CasebookThe complaints referred to the ICR in 2014/15covered a wide range of subjects. Some completelynew issues cropped up – for example about thehandling of Land Registry’s price paid data. Othercases raised important points about how to handlecustomer complaints, the respective responsibilitiesof Land Registry and its customers, and the factthat once a property is registered it is generally notpossible for Land Registry simply to reverse theprocess.

Where I find that Land Registry has provided poorservice, my job is to recommend action by LandRegistry – to put matters right, as far as possible,for the complainant and to point to steps that LandRegistry should take to prevent similar problemscropping up in future. Where, on the other hand, Iam satisfied that Land Registry has helped as far asit can, my role is to explain in plain language thereasons why, as an external assessor, I haveconcluded that Land Registry has actedappropriately. If I do not uphold a complaint I try,where possible, to point to options that may still beopen to the complainant to resolve the situation.

This section gives some examples of cases I havereviewed this year, highlighting some of thecommon themes and some of therecommendations I have made to Land Registry.

Price paid dataLand Registry’s publication of free price paid datahas made a huge impact. People are now able, in afew seconds, to obtain information from LandRegistry’s website and from commercial websites

on the last price paid for a property and also acurrent valuation based on the prices paid for thatproperty and others in the neighbourhood. As withany project, success also brings challenges. Thepublic quite rightly expect that the data publishedwill be complete and accurate and that, if there is amistake, it will be corrected without delay. It is fair tosay that the numbers of complaints referred to mehave been tiny compared with the numbers ofsatisfied customers, but they have provided usefulindications of areas for improvement.

Mr A complained that the price paid data publishedfor his flat was mistaken and in fact related toanother flat in the same house. On investigating Ifound that Land Registry had taken the matterseriously and had tried to correct the error. I found,however, that there had been delays in correctingthe price shown on Land Registry’s own site, andthat the same problem appeared to affect similarproperties in the same area. With regard to thedelays, I recommended that Land Registry shouldapologise and offer a consolatory payment torecognise the inconvenience caused to Mr A. Toprovide reassurance to Mr A that other customerswould not experience similar problems, I askedLand Registry to explain to Mr A the action itintended to take to ensure that similar mistakeswere corrected and not repeated.

It is important that customers should feel confidentthat Land Registry’s approach to publishing pricepaid data is fair and consistent. Mr B and Ms Cqueried the fact that the price paid for a propertythey owned had not been published. Land Registryinformed them that the purchase had beenclassified as a commercial transaction and had


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therefore been excluded from publication. Thecomplainants argued that the property had beenbought on the open market and that the price paidhad not been affected by the fact that it was acommercial deal. Land Registry responded that itscurrent policy was not to publish prices paid inapparently commercial transactions but that thiswas shortly to change, so similar problems shouldnot arise in future. I was satisfied that Land Registryhad provided a reasonable explanation of itsactions, and that its decision to change its policyshowed that it was willing to respond to customerfeedback. I did not therefore uphold the complaint.The complainants asked Land Registry, in thecircumstances, to arrange for the price paid for theproperty in question to be published. However I wasnot persuaded that making an exception in this waywould have been appropriate as it would have beenunfair to others whose price paid data had beenexcluded for the same reason and had had nochance to request special treatment.

Mr D, in contrast, had bought a propertycommercially at a discounted price, andcomplained at the fact that the price had beenpublished, saying that this had led to the propertybeing undervalued on property websites. LandRegistry’s response was that there had beennothing to identify the purchase as a commercialtransaction, and so there had been no reason toexclude the price paid from publication. AlthoughMr D felt that the result had been unfair, I found thatLand Registry had responded promptly to hisconcerns and that the reasons it had given forpublishing the data reflected the procedures inplace at the time and the information available fromthe documents Land Registry had received. As I

have already noted, Land Registry’s policy is due tochange and publishing prices paid in commercialtransactions will be the norm. Whether or not datais published will no longer depend on judgementsabout whether purchases are commercial, and thesame rules will apply to all, leaving little room forcomplaints of unfairness.

Complaints about misconduct by members of LandRegistry staffIt is rare, in my experience, for customer complaintsto raise serious issues of misconduct by LandRegistry staff. It is all the more important thereforethat when such a situation does arise, LandRegistry should deal confidently both with thecustomer complaint and the disciplinaryproceedings.

Mr E complained about the actions of an individualmember of Land Registry staff and it rapidlybecame clear to Land Registry, when it started toinvestigate, that the member of staff had disobeyedLand Registry’s Code of Conduct. Land Registrytook disciplinary action against the member of staffand although it provided Mr E with someinformation about the disciplinary process it did notrespond directly to his concerns as a customer. Hewas very dissatisfied and asked me to carry out areview. I found that Land Registry had failed todistinguish clearly between the complaint made byMr E as a customer and the internal disciplinaryinvestigation, and as a result that it had failed toinvestigate the specific issues raised in thecomplaint or to report back promptly, explainingwhat had gone wrong and what it proposed to doto put things right. I recommended that LandRegistry should apologise to Mr E for the


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misconduct and its impact on him, and also forfailing to respond effectively to his complaint. I alsoproposed a consolatory payment to Mr E by way ofrecognition that he would have experienced muchless distress and inconvenience if his complaint hadbeen dealt with properly in accordance with LandRegistry’s complaints procedure. I recommended inaddition that Land Registry should review its internalguidance on handling situations of this sort toensure that staff are aware of the need to make aclear distinction between Land Registry’s internalstaff disciplinary process and its customercomplaints procedure.

Responsibility for mistakes in applicationsCustomers often assume that Land Registry isresponsible for checking the accuracy of all theinformation provided by applicants or theirconveyancers in an application. In fact LandRegistry is generally entitled to rely on applicantsand conveyancers to complete the application formcorrectly and to supply accurate information. Thismakes a lot of sense from a practical point of viewas it would seriously slow down registrationprocesses if Land Registry had to verify all thedetails on the application form before completing aregistration.

On the other hand there are cases where LandRegistry can help spot obvious errors so that theapplicant can put them right. One of the complaintsI investigated demonstrated how much time andtrouble can be wasted if opportunities of this sortare missed.

Mr F complained that Land Registry had causedhim huge problems and considerable expense

because it had failed to notify him of a fraudulenttransfer of his property. What had happened wasthat when Mr F had originally applied for registrationof the transfer of the property, his address had beenmis-typed on the application form by theconveyancers. This incorrect address was enteredin the register as Mr F’s address. Later when anapplication was made, apparently on Mr F’s behalf,to register the property to a third party, LandRegistry wrote to Mr F to inform him of theapplication and give him the chance to object butsent the letter to the incorrect address and it did notreach Mr F. The third party was then registered asthe new owner. When he found out what hadhappened Mr F had to apply for his name to bereinstated as registered owner. The new ownerobjected and Mr F was only reinstated as ownerafter a full hearing in the Property Tribunal.

Although I concluded that Land Registry had beenentitled to rely on the information provided on theoriginal application form, I also noted that theincorrect address shown on the form was verysimilar to the address of the registered property. Ifelt that a quick call by Land Registry to theconveyancers before completing the registrationcould potentially have saved a good deal of time,inconvenience and distress for Mr F. Although I didnot uphold the complaint I urged Land Registry tokeep its policy and practice in this area underreview, taking into account that unquestioningreliance on the accuracy of information onapplication forms can allow obvious errors to gouncorrected and so store up problems for thefuture.


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The importance of strict impartialityWhere there is a dispute about property it is vital forLand Registry to remain impartial and to avoid doinganything that appears to favour one side rather thanthe other. This is not always easy and it is vital forLand Registry staff always to be alert to the risk ofappearing biased.

Mr and Mrs G complained that Land Registry hadbeen in contact for over two years with neighbourswith whom they were in dispute but had notinformed them of what was going on. They alsocomplained that Land Registry had carried out twosurveys without letting them know. I found thatalthough Land Registry had not been legallyrequired to contact Mr and Mrs G, it had beenaware that there was a dispute and therefore shouldhave recognised the need to take great care to befair to both sides. I fully understood why Mr and MrsG had felt, when they found out about thecorrespondence and surveys, that Land Registryhad been biased in favour of their neighbours. WhileI accepted that staff had been trying to be helpful,and had hoped that the problems could be sortedout without affecting Mr and Mrs G’s property, theyhad failed to follow Land Registry’s guidance onimpartiality. In responding to Mr and Mrs G’scomplaint Land Registry had already recognisedthat it had handled matters badly and had offered aconsolatory payment in recognition of the distresscaused. Taking into account the fact that I hadfound no evidence of deliberate bias, and also thefact that there was an ongoing boundary dispute, Iconcluded that Land Registry had recognised itsfailures and taken proper steps to make amendsand did not propose any additional redress. Thecase, however, is a clear example of how risky it is

for Land Registry to try to be helpful when there is adispute in progress.

In spite of this it is sometimes possible for LandRegistry, without compromising its impartiality, tooffer an authoritative assessment of the legalsituation and so help to resolve a dispute byagreement. Mr and Mrs H complained that LandRegistry had continued to process an applicationfor the removal of an area of land from theirregistered title without taking into account theevidence they had provided to show that the landwas theirs. When I investigated the whole sequenceof events I found that Land Registry had acted quiteappropriately in processing the application. Its dutywas to be fair both to the applicants and to Mr andMrs H. Even though it was aware that theapplication was hotly disputed, it had no power todecide the dispute. Nonetheless Land Registry didwarn the applicants, in the light of the legalarguments on both sides, of the uncertainty of theoutcome. This led directly to a decision by theapplicants to withdraw their application, with theresult that the dispute was resolved without theneed for a judgment by a court or tribunal. I wassatisfied that Land Registry, far from failing in itsduty to its customers, had acted in the bestinterests both of Mr and Mrs H and the applicantsby offering its impartial but informed comments onthe situation

The difficulty of undoing what has been doneIn Mrs I’s case Land Registry had granted adversepossession of a piece of unregistered land in the1990s without realising that it was part of the landbelonging to a nearby house. Mrs I was thedaughter of the original owners and when she later


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applied for registration of the whole property, LandRegistry excluded the piece of land from her titlebecause it was already registered. Mrs I was veryupset that Land Registry, even with knowledge ofthe full facts, refused either to reverse the grant ofadverse possession or to pay Mrs I compensationfor the loss of the land.

Land Registry’s position was that it had handledmatters appropriately. It said that there had beennothing to suggest, when the application foradverse possession was made, that Mrs I’s parentshad an interest in the land, which was somedistance from their house and garden. While I hadconsiderable sympathy for Mrs I’s position I had torecognise that Land Registry, when dealing with theapplication for adverse possession of unregisteredland, had no duty to make specific enquiries aboutownership, or to serve notice on anyone. Moreover,events had moved on over the years and it was notpossible for Land Registry simply to reverse theregistration and start again. I concluded that LandRegistry could not take the matter further without aspecific application. Accordingly I told Mrs I that ifshe wanted to pursue the matter she would need toapply herself for the title based on adversepossession to be closed. I had to point out,however, that if the registered owner objected, LandRegistry would have no option but to refer thedispute to the Property Tribunal for a judicialhearing. While customers may expect that LandRegistry will simply turn the clock back to restoreland to an original owner, more often than not, asthis case illustrates, this is not in fact possible.

When it is best to bring correspondence to an endIt is not unusual to come across cases where

correspondence between a customer and LandRegistry about the same issues has been going onfor years without any progress or prospect of asolution. The very fact that Land Registry continuesto reply to letters and emails can give customersfalse hope of progress or a change of mind by LandRegistry and may prevent them from looking intoother ways of sorting out the problem. The timetaken and the stress and strain caused by suchcorrespondence – mainly for the customer, but alsofor Land Registry staff – can be very great.

Mr J had been in correspondence with LandRegistry regarding the accuracy of his title plan forover 30 years. Several years ago a court had madea decision on his boundaries and the register hadbeen changed to reflect the court order. Mr J,however, continued to believe that his title plan waswrong and to press Land Registry to look at thesituation again. Land Registry said that it could nothelp further and that the only option, if Mr J wishedthe boundaries to be looked at again, was to returnto court. Mr J eventually requested a review by theICR of the way Land Registry had responded to hisrequests. I recognised that Mr J continued to feelvery strongly that his title plan was wrong. I wassatisfied, however, that Land Registry had handledthe situation fairly and reasonably, that it could donothing further, and that it had acted in the bestinterests of Mr J in bringing correspondence to anend. I urged Mr J to recognise that continuingcorrespondence was not going to produce theresults he wanted but would simply cause moredistress.

Ms K came to Land Registry as a result of a disputewithin her family about the administration of an


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estate. She felt that the estate was not beinghandled properly and hoped that Land Registrywould support her claim that a transfer of a propertyhad been wrongly registered. Land Registry repliedthat it had processed the transfer correctly and hadno role in investigating the way in which the estatewas being administered. I was satisfied that thiswas a fair and appropriate response. I wasconcerned, however, to find that before thecomplaint was referred to me, Ms K and LandRegistry had been in correspondence for nearly fouryears without any progress and without any offer ofan independent review. I felt that Land Registry hadmissed several opportunities to provide a full andfinal response and then to bring thecorrespondence to an end, giving Ms K the optionof an independent review. If this had been done itwould have saved Ms K the inconvenience anddistress of pursuing her correspondence with LandRegistry for so long, avoided raising expectationsthat Land Registry might change its mind andenabled her to consider other options much earlier. Irecommended that Land Registry shouldacknowledge that it had not handled the situationwell and should offer a formal apology.

The need for caution in offering assurances aboutthe futureLand Registry is a key part of our national legal andeconomic framework and is, quite rightly, highlyrespected by the public. Customers naturally setgreat store by statements made and assurancesoffered by Land Registry. It is therefore especiallyimportant for Land Registry staff to be cautious inmaking statements or offering assurances aboutwhat will happen in the future, since the future is ofcourse notoriously unpredictable.

Mr L complained that Land Registry had given hima written assurance in 1995 that a specific area ofland would not be registered to the local council asthe council’s title was defective. Mr Lunderstandably regarded this as a guarantee thatsuch a registration would not happen. In fact manyyears later the council made an application forregistration of the land and was successful. I foundthat the member of staff who had given theassurance in 1995 had made a mistake and hadhad no power to make such a promise. Irecommended that Land Registry should apologisefor the mistake made in 1995 and for the distressMr L had experienced later when he found that theland had in fact been registered to the council. I alsorecommended that Land Registry should considerwhether there was any need for it to provide trainingor guidance for staff to prevent similar mistakesbeing made in future.

Land Registry requirements for identity evidenceAlthough most people hire conveyancers to dealwith their property transactions, some prefer tohandle matters themselves. As mentioned in myintroduction, Land Registry has set up a specialistteam of staff at its Wales Office to handleapplications made directly by members of thepublic. This should help Land Registry to develop abetter understanding of the needs and expectationsof its non-professional customers so that it canrespond more appropriately to their questions andconcerns. An issue specific to ‘citizen customers’that has been raised a number of times in casesreferred to me is Land Registry’s practice on identitychecks.

Members of the public who make applications


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themselves must have their identity checked beforeLand Registry will accept their applications. This ispart of Land Registry’s strategy to combat propertyfraud. A number of customers have complained,however, that Land Registry currently insists onhaving the checks done by a conveyancer – ratherthan offering a list of people qualified to do so. Mr Mwrote several times to Land Registry asking for the‘chapter and verse in legislation’ that entitled it torequire checks specifically by a conveyancer. Hisreason for asking was to help him decide whetherhe could get the requirement changed without achange in the law. I found that although LandRegistry had referred Mr M to its publishedguidance on identity requirements, it had notanswered his specific question. I also set out asclearly as I could the complex legal situationregarding identity check requirements andrecommended that Land Registry should apologiseto Mr M for failing to deal with his enquiries properly.In addition I urged Land Registry to complete aplanned review of its published information onidentity checks and recommended that in themeantime it should think about providing guidancefor staff on how to respond clearly and consistentlyto customer enquiries on this complex subject.


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Independent Complaints ReviewerGround Floor, Dover House, 66 Whitehall, London SW1A 2AUTel 020 7930 0749 Fax 020 7321 [email protected]

independent complaints reviewer (icr) for land … · complaints reviewer (icr) office – in spite...

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