23rd May 2018
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HOUSING LAW NEWS & POLICY ISSUES
 

Grenfell Tower fire inquiry opens
On 21 May 2018 the Grenfell Tower fire inquiry opened. The Chairman, Sir Martin Moore-Bick, described the inferno as “the single greatest tragedy to befall [London] since the second world war”. Proceedings began with a 72 second silence to honour the victims of the fire. Family of those who died in the fire made statements to the inquiry, paying tribute to their loved ones. Such testimonies are expected to continue into next week. For a report in The Guardian, click here For the inquiry website, click here

Removal of unsafe cladding in social housing
On 16 May 2018 the government announced that it will fully fund the removal and replacement of unsafe cladding by councils and housing associations, estimated at £400 million. Local authorities and housing associations, which are non-profit making, will be given access to the money to help with reasonable costs of removing and replacing unsafe cladding from buildings which they own. For the announcement, click here

Cladding: direction to local authorities
On 17 May 2018 the Housing Secretary James Brokenshire issued a direction under section 3(3) of the Housing Act 2004, instructing all local housing authorities to pay particular regard to cladding related issues when reviewing housing in their areas. For the details, click here

‘Radical reform’ of building regulatory system needed: Hackett Review
On 17 May 2018 Dame Judith Hackitt, Chair of the Independent Review of Building Regulations and Fire Safety, stated that a new regulatory framework for higher-risk residential buildings is required to improve building safety and ensure that residents are safe. She said that the current system is not fit for purpose. Dame Judith was appointed by the government to lead the review in light of the system failures revealed by testing carried out in the wake of the Grenfell Tower tragedy. For her published findings, click here For a press release published on her behalf, click here For the Housing Secretary’s statement to Parliament, click here For the response of the Commons Housing, Communities and Local Government Committee, click here For comments by the Local Government Association, click here

Combustible material consultation
In the Housing Secretary’s statement to Parliament in respect of the Hackett Review (see above), he announced that the Government will launch a consultation into banning the use of combustible materials in cladding and insulation systems on high-rise residential buildings. For his statement, click here For the Local Government Association’s response, click here

Update on fire doors investigation
On 16 May 2018 the Housing Secretary James Brokenshire updated Parliament on the fire door investigation and confirmed that experts advise the risk to public safety remains low. Earlier this year the Metropolitan Police informed government a fire door installed at Grenfell Tower designed to resist fire for up to 30 minutes – as required by building regulations guidance – failed after approximately 15 minutes when tested by the police. Government sought advice from its independent expert panel to see what action was required. The expert panel has advised that owners of buildings with Manse Masterdor fire doors should review their building’s fire risk assessment and consider how quickly these doors should be replaced. The expert panel has published guidance to assist building owners. For more details, click here For the guidance itself, click here

Leasehold high-rise flats: who pays for fire safety work?
On 18 May 2018 the House of Commons Library published a paper considering the debate about who is responsible for paying for fire safety works on blocks of flats in the wake of the Grenfell Tower fire. For the paper, click here

Housing (Scotland) Act 2014 (Commencement No 8, Savings, Transitional and Supplemental Provisions) Order 2018
This order brings into force various provisions of the Housing (Scotland) Act 2014 (the Act). Section 99 comes into force on 30 July 2018. Sections 3, 4 (insofar as not already in force), 5, 6 (insofar as not already in force), 7 (insofar as not already in force), 8 to 11, 14 (insofar as not already in force) and 15 come into force on 1t May 2019. Sections 12 and 13 come into force on 1 November 2019. For the most part, the order makes saving and transitional provisions. Article 9 ensures that social landlords will inform their tenants of the changes that will be made to their tenancy agreements due to the commencement of Part 2 of the Act. For the commencement order, click here For the 2014 Act, click here

Scottish Secure Tenancies (Proceedings for Possession) (Form of Notice) Amendment Regulations 2018
These regulations, which come into force on 1 May 2019, amend the Scottish Secure Tenancies (Proceedings for Possession) (Form of Notice) Regulations 2012 (the 2012 regulations) to reflect the terms of section 16(2)(aa) of the Housing (Scotland) Act 2001 (which was inserted by section 14(2)(a) of the Housing (Scotland) Act 2014) which means that the court no longer has to consider whether it is reasonable to make an order for eviction in cases where the landlord has a ground for recovery of possession set out in paragraph 2 of Schedule 1 to the 2001 Act and the notice in the form of the 2012 regulations is served within 12 months of the tenant’s conviction or dismissal or abandonment of any appeal. For the 2018 regulations, click here For the 2012 regulations, click here For the 2001 Act, click here

Short Scottish Secure Tenancies (Proceedings for Possession) Regulations 2018
These regulations, which come into force on 1 May 2019, prescribe the form of notice to be used by a landlord when notifying a tenant under a short Scottish secure tenancy, within the meaning of Part 2 of the Housing (Scotland) Act 2001, that the landlord requires possession of the house occupied by that tenant and may commence possession proceedings in respect of that house. For the regulations, click here For the 2001 Act, click here

Short Scottish Secure Tenancies (Notice) Regulations 2018
These regulations, which come into force on 1 May 2019, prescribe the notice that is to be used by a prospective landlord when notifying a prospective tenant that the tenancy offered is a short Scottish secure tenancy. Regulation 2 and the Schedule set out the notice that is to be sent out. The notice specifies the grounds for granting a short Scottish secure tenancy and the term of the tenancy. Regulation 4 makes a saving provision in respect of any notice that was issued prior to 1 May 2019 in the form prescribed by the Short Scottish Secure Tenancies (Notices) Regulations 2002, which Regulations are revoked as at that date by regulation 3. For the regulations, click here

Regulation of letting and managing agents – England
There is currently no overarching statutory regulation of private sector letting or managing agents in England but the Government has said that regulation will be introduced. On 16 May 2018 the House of Commons Library published a briefing paper describing the current regulatory regime in England and includes comparisons with policy in the devolved nations. For the briefing paper, click here

England ‘short of four million homes’
On 18 May 2018 the National Housing Federation and Crisis published the finding from research, conducted by Heriot-Watt University (to be published in full this summer), which shows that England’s total housing need backlog has reached four million homes. To satisfy this need, the research states that the country needs to build 340,000 homes per year until 2031. Of these new homes 145,000 must be affordable homes (compared to previous estimates of the annual affordable housing need of around 78,000). The new research breaks down exactly what type of affordable homes are needed: 90,000 should be for social rent; 30,000 should be for intermediate affordable rent; and 25,000 should be for shared ownership. For a summary of the research findings, click here

Homeless gamblers
On 17 May 2018 Homeless Link reported that the University of Lincoln and the National Centre for Social Research (NatCen) have been working with homelessness practitioners and individuals to conduct research to develop a set of tools to better identify and support people suffering from gambling problems. The first tool developed is an information sheet, designed to support and inform homeless practitioners. It contains brief bullet points asking and answering the following questions: What is gambling? Why ask about gambling? What is the appeal of gambling? What should you look for? What are the barriers to talking about gambling? For more information about the project, click here

‘Homeless people fined and imprisoned in England and Wales
On 20 May 2018 The Guardian reported that a Freedom of Information request had revealed that “at least 51 people have been convicted of breaching a public space protection order (PSPO) for begging or loitering and failing to pay the fine since 2014, receiving criminal behaviour orders in some cases and fines up to £1,100. Hundreds of fixed-penalty notices have been issued.” The newspaper found that, despite recent updated Home Office guidance which instructs councils not to target people for being homeless and sleeping rough, over 50 local authorities have PSPOs in place. For the article, click here

Government challenged on legal aid to prevent homelessness
On 21-22 May 2018 the High Court heard a challenge from Law Centres Network (LCN) to changes that the Ministry of Justice wants to introduce to legal aid. There are currently 113 Housing Possession Court Duty schemes (HPCDS) across England and Wales. MoJ last year decided to consolidate them into only 47 schemes, each covering much larger geographical areas. Currently, MoJ sets the fees for the service, and organisations wanting to deliver it bid for contracts at these fixed fees. Last year, MoJ also decided to introduce a price competition among bidders, potentially driving fees even lower. LCN is asking the Court to quash MoJ’s decision to proceed with the tender in a form that drastically consolidates the scheme areas and introduces price competition. It argues that MoJ chose to dismantle HPCDS in its former form based on questionable and untested assumptions, and without any serious analysis of how this might affect the people for whom the service is intended. LCN says that Law Centres are not alone in objecting to the changes and that MoJ decided to press ahead despite overwhelming opposition from duty desk providers which responded to its consultation on the matter. For more information, click here

HOUSING LAWS IN THE PIPELINE
 

Local Housing Authority Debt Bill
This Bill, which had its first reading in the House of Lords on 4 July 2017, seeks to replace the current regime of limits on local housing authorities’ debt with limits determined by the existing prudential regime for local authority borrowing for non-housing-related purposes. The second reading is yet to be scheduled. For the Bill as introduced, click here To follow progress of the Bill, click here

Homes (Fitness for Human Habitation and Liability for Housing Standards) Bill
This is a Private Member’s Bill introduced in the House of Commons by Karen Buck. The Bill aims to amend the Landlord and Tenant Act 1985 to require that residential rented accommodation is provided and maintained in a state of fitness for human habitation; to amend the Building Act 1984 to make provision about the liability for works on residential accommodation that do not comply with Building Regulations; and for connected purposes. The Bill received its second reading on 19 January 2018. It will begin its Committee stage on a date to be announced. On 14 January 2018 the government confirmed that it would support the Bill. For the Bill as introduced, click here For a House of Commons Library research briefing, click here To follow progress of the Bill, click here

Homeless People (Current Accounts) Bill
This is a Private Member’s Bill introduced in the House of Commons by Peter Bone. The Bill is intended to require banks to provide current accounts for homeless people seeking work; and for connected purposes. The Bill is being prepared for publication. The Bill received its first reading on 5 September 2017. The second reading is due to take place on 1 February 2019. To follow progress of the Bill, click here

Housing (Amendment) Scotland Bill
This Scottish government Bill aims to amend the law on the regulation of social landlords and to reduce the influence of local authorities over registered social landlords. It was introduced on 4 September 2017 and completed Stage 2 on 18 May 2018. The Stage 3 debate is scheduled for 31 May 2018. For the Bill as amended at Stage 2, click here For a research briefing on the Bill, click here To follow progress of the Bill, click here

Sublet Property (Offences) Bill
This is a Private Member’s Bill introduced in the House of Commons by Christopher Chope. It is intended to make the breach of certain rules relating to sub-letting rented accommodation a criminal offence; to make provision for criminal sanctions in respect of unauthorised sub-letting; and for connected purposes. The Bill is being prepared for publication. The Bill received its first reading on 5 September 2017. The second reading has been postponed and is now due to take place on 6 July 2018. To follow progress of the Bill, click here

Mobile Homes and Park Homes Bill
This is a Private Member’s Bill introduced in the House of Commons, also by Christopher Chope. It is intended to require the use of published criteria to determine whether mobile homes and park homes are liable for council tax or non-domestic rates; to make provision in relation to the residential status of such homes; to amend the Mobile Home Acts; and for connected purposes. The Bill is being prepared for publication. The Bill received its first reading on 5 September 2017. The second reading has been postponed and is due to take place on 6 July 2018. To follow progress of the Bill, click here

Affordable Home Ownership Bill
This Bill was introduced to Parliament on Tuesday 24 October 2017, also by Christopher Chope, under the Ten Minute Rule and is a Private Member’s Bill. It was said by him to make provision for affordable home ownership; to require the inclusion of rent to buy homes in the definition of affordable housing; to make provision for a minimum proportion of new affordable housing to be available on affordable rent to buy terms; to provide relief from stamp duty when an affordable rent to buy home is purchased; and for connected purposes. The Bill itself has not yet been published. Its second reading has been postponed to 15 June 2018. To follow progress of the Bill, click here

Creditworthiness Assessment Bill
This Private Member’s Bill was introduced by Lord Buck and had its second reading in the House of Lords on 24 November 2017. The Bill would require certain matters (including rental payment history) to be taken into account when assessing a borrower’s creditworthiness. For the Bill as introduced, click here The Bill had its committee stage on 11 May 2018. It will have its report stage (when there will be further line by line examination of the Bill) on a date to be announced. For progress of the Bill, click here

Regulation of Registered Social Landlords (Wales) Bill
The purpose of this Bill is to amend or remove those powers which are deemed by the Office for National Statistics (ONS) to demonstrate central and local government control over Registered Social Landlords (RSLs). These changes will enable the ONS to consider reclassifying RSLs as private sector organisations for the purpose of national accounts and other ONS economic statistics. The Bill was agreed by the Assembly in accordance on 8 May 2018. It is now in the four-week period of intimation (9 May – 6 June 2018).  During this period, the Counsel General or the Attorney General may refer the question whether the Bill, or any provision of the Bill, would be within the Assembly’s legislative competence to the Supreme Court for decision (section 112 of the Government of Wales Act). Similarly, the Secretary of State for Wales may make an order prohibiting the Clerk of the Assembly from submitting the Bill for Royal Assent. For progress on the Bill, click here and scroll down.

Private Landlords (Registration) Bill
This Bill was introduced to Parliament on 17 January 2018 under the Ten Minute Rule. The Bill seeks to require all private landlords in England to be registered. The second reading of the Bill has been postponed to 26 October 2018. For the Bill, as introduced, click here To read the debate on introduction of the Bill, click here To follow progress of the Bill, click here

Leasehold Reform Bill
This Bill, introduced to Parliament on 7 November 2017 under the Ten Minute Rule and sponsored by Justin Madders, makes provision about the regulation of the purchase of freehold by leaseholders; to introduce a system for establishing the maximum charge for such freehold; to make provision about the award of legal costs in leasehold property tribunal cases; and to establish a compensation scheme for cases where misleading particulars have led to certain leasehold agreements. It is scheduled to receive a second reading on 26 October 2018. The Bill is being prepared for publication. To follow progress of the Bill, click here

Homelessness (End of Life Care) Bill
This Bill, sponsored by Sir Edward Davey, was introduced to Parliament on 7 February 2018 under the Ten Minute Rule. It makes provision about end of life care and support for homeless people with terminal illnesses, including through the provision of housing for such people. The Bill’s second reading has been further postponed to 6 July 2018. The Bill itself is being prepared for publication. To follow progress of the Bill, click here

Rating (Property in Common Occupation) and Council Tax (Empty Dwellings) Bill
This government Bill was given its first reading in the House of Commons on 28 March 2018. It makes provision, where two or more hereditaments occupied or owned by the same person meet certain conditions as to contiguity, for those hereditaments to be treated for the purposes of non-domestic rating as one hereditament; and to increase the percentage by which a billing authority in England may increase the council tax payable in respect of a long-term empty dwelling. The Bill has completed its passage through the House of Commons. It had its first reading in the House of Lords on 16 May 2018. It is due to have its second reading on a date to be announced. For the Bill as introduced in the House of Lords, click here For the government’s announcement of the Bill, click here To follow progress of the Bill, click here

Tenant Fees Bill
This government Bill makes provision for prohibiting landlords and letting agents from requiring certain payments to be made or certain other steps to be taken; makes provision about the payment of holding deposits; to make provision about enforcement and about the lead enforcement authority; and amends the provisions of the Consumer Rights Act 2015 about information to be provided by letting agents and the provisions of the Housing and Planning Act 2016 about client money protection schemes. It received its first reading on 2 May 2018 and its second reading on 21 May 2018. For the second reading debate, click here The Bill has been committed to a Public Bill Committee whose proceedings will conclude by 12 June 2018. For the Bill as introduced, click here For the impact assessment, click here To follow progress of the Bill, click here

NEW HOUSING CASES
 

Worthington and Parkin v Metropolitan Housing Trust Ltd [2018] EWCA Civ 1125

Mr Worthington and Ms Parkin (“the Claimants”) were assured tenants of Metropolitan Housing Trust (“Metropolitan”). They lived at separate properties but were both concerned about antisocial behaviour in the area. Ms Parkin installed CCTV cameras with Metropolitan’s consent, before moving to a different property and installing the cameras there (having assumed that Metropolitan’s permission for the cameras would extend to the new property too).

There were some complaints to Metropolitan about the Claimants, alleging, amongst other things, that they were taking photographs of other residents and invading their privacy.

An employee of Metropolitan wrote to Ms Parkin asking her to take down her CCTV cameras. There ensued correspondence between Metropolitan and the Claimants regarding the Claimants’ activities. Ultimately, Metropolitan instructed solicitors to write to the Claimants asking them both to remove their CCTV cameras (despite the fact that Mr Worthington did not have any cameras at his home).

Metropolitan relied on a petition signed by 80 residents calling for the cameras to be removed, although it appeared in actual fact that few of the signatories were actually residents and that the petition had likely been produced at a football practice.

Metropolitan’s solicitors advised Metropolitan that a claim for an injunction against both Claimants would have at least a reasonable prospect of success.

A case conference was scheduled for Metropolitan to decide what action to take. Before that conference, a member of Metropolitan’s compliance committee expressed concerns about the case, suggesting that further investigation was needed before any threats of legal action were made. Contrary to his advice, Metropolitan decided at the case conference to proceed with legal action. It wrote to both Claimants warning them that possession proceedings would be issued shortly. Both letters contained serious factual errors when alleging what the Claimants had done wrong.

Later correspondence threatened court proceedings for an injunction.

The first instance decision
The Claimants issued proceedings in the county court, alleging that Metropolitan’s conduct amounted to harassment. The judge found for the Claimants, finding that Ms Parkin had been reasonable to assume that permission given to her to have CCTV cameras at her former Metropolitan property would extend to a new Metropolitan property that she moved to. The judge found that Metropolitan’s employee had been careless or incompetent in his handling of the case, which had led to inaccurate solicitors’ letters being sent to the Claimants. The judge found that Metropolitan’s employee had been inadequately supervised and had failed to stop and consider the Claimants’ responses to what was being alleged. The judge found that Metropolitan’s conduct had gone beyond being merely unreasonable or disproportionate and had in fact been oppressive. The judge held that a reasonable person would have considered that the conduct amounted to harassment and Metropolitan were therefore found to have committed harassment against the Claimants contrary to sections 1 and 3 of the Protection from Harassment Act 1997 (“the 1997 Act”). The trial judge awarded the Claimants between £4,000 and £5,000 each.

The appeal
Metropolitan appealed to the Court of Appeal but were unsuccessful in their appeal. The Court of Appeal noted that the 1997 Act requires a course of conduct (i.e. on two or more occasions) which amounts to harassment. The Court of Appeal held that although the trial judge had not specifically identified each item of unacceptable correspondence by Metropolitan as being part of the course of conduct relied on, he had set out earlier in his judgment the letters sent by Metropolitan and it was therefore perfectly clear that he had considered those letters to form the course of conduct.

The Court of Appeal reiterated that for the purposes of the 1997 Act, it is the overall course of conduct which must amount to harassment, not each individual act forming part of that course of conduct.

The Court of Appeal held that the trial judge had specifically turned his mind to whether Metropolitan’s conduct had been of sufficient gravity to amount to harassment: he had asked himself whether it was oppressive rather than merely unreasonable.

The trial judge had specifically found that a reasonable person would have known Metropolitan’s conduct to amount to harassment as required under section 1 of the 1997 Act.

The Court of Appeal stressed that Metropolitan should have known that letters threatening possession proceedings would have caused particular anxiety to social housing tenants. The Court of Appeal held that Metropolitan was well aware that Ms Parkin’s CCTV cameras had been installed for a proper purpose and that evidence from police in support of Metropolitan’s approach could be given little weight in the light of the tone and content of an email from one of the officers.

The Court of Appeal noted that no heed appeared to have been taken of the concern expressed by a member of Metropolitan’s compliance committee of insufficient investigation prior to legal proceedings being threatened.

In all the circumstances, the Court of Appeal held that Metropolitan’s actions had been such that a reasonable person would think that they caused alarm and distress. The Court of Appeal reproached Metropolitan for issuing threats to the Claimants without first having a proper foundation for doing so. The Court of Appeal held that the trial judge had been entitled to find that Metropolitan’s conduct amounted to harassment and it therefore dismissed Metropolitan’s appeal.

Summary by Alexander Campbell, barrister, Field Court ChambersFor the full judgment click here.

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HOUSING LAW CONSULTATIONS
 

Reviewing the landlord registration fee structure and application process – Scotland
The Scottish government is consulting on proposals intended to strengthen the system of landlord registration in a proportionate way that will help to ensure that homes rented to private rented sector tenants are of good quality and are managed professionally. Responses to the consultation will help to shape changes to the application process that will require landlords to demonstrate that they meet their legal responsibilities. They will also inform amendments to the way that fees are charged so that local authorities have enough resources to make informed decisions about who can be approved to operate as a landlord. The consultation closes on 7 June 2018. For more details, click here

Powers for dealing with unauthorised development and encampments
The MHCLG and Ministry of Justice have launched a consultation seeking views on the effectiveness of powers for dealing with unauthorised development and encampments. The consultation asks a series of questions relating to powers for dealing with unauthorised development and encampments, including: local authority and police powers; court processes; trespass; planning enforcement; the provision of authorised sites; and the impacts on the travelling community. The consultation closes on 15 June 2018. For the consultation document, click here

Consultation on the Energy Efficiency Standard for Social Housing post-2020 (EESSH2) – Scotland
The Scottish Government says that consultation on the Energy Efficiency Standard for Social Housing post-2020 (EESSH2) will be a critical part of Energy Efficient Scotland, and realising its vision that by 2040 homes and buildings will be ‘warmer, greener and more efficient’. When EESSH was launched in 2014, a review was proposed for 2017 to assess progress towards the 2020 target and consider future milestones beyond 2020. Phase 1 of the Review assessed progress and concluded with publication of revised EESSH Guidance for Social Landlords in December 2017. Phase 2 of the Review considered milestones and activity post 2020, with the EESSH Review Group recommending the proposals set out in this public consultation. The Scottish Government wants to hear views on these proposals for new milestones for the Energy Efficiency Standard for Social Housing. Responses will help inform how the government continues to improve energy efficiency in social housing in Scotland. The consultation closes on 27 July 2018. For the consultation document, click here

HOUSING LAW ARTICLES & PUBLICATIONS
 

Developing support strategies for homeless gamblers Steve Sharman Homeless Link 17 May 2018. To read this article, click here

Court of Appeal on illegal eviction – quantum and heads of claim Giles Peaker Nearly Legal 18 May 2018. To read this article, click here

Government is leading by spending on cladding and banning combustibles John Bibby Shelter Blog 18 May 2018. To read this article, click here

'We still have hearts': homeless on the streets of Kettering Sarah Marsh and Patrick Greenfield Guardian 20 May 2018. To read this article, click here

The Guardian view on the Grenfell Tower inquiry: necessary but not sufficient Editorial Guardian 20 May 2018. To read this article, click here

Heavy handed, inaccurate threats of legal action – Metropolitan HT harass their tenants Giles Peaker Nearly Legal 20 May 2018. To read this article, click here

Mind the gap: why do we still have distance between housing rhetoric and reality? Steve Akehurst Shelter Blog 21 May 2018. To read this article, click here

Predicting the future is a tricky business, but we must Boris Worrall CIH Blog 21 May 2018. To read this article, click here

Is £400m enough? Andrew Lancaster Anthony Collins Blog 21 May 2018. To read this article, click here

Refusing to apply the sanction? Some thoughts on non-cooperation (and some letters) Mark Prichard Mark Prichard blog 21 May 2018. To read the article, click here

Mortgage possession claims: the changed legal landscape Daniel Clarke, Derek McConnell and Simon Mullings Legal Action May 2018. To read this article, click here

Housing: Recent Developments Jan Luba QC & Nic Madge Legal Action May 2018 (subscription required). To read this article, click here

HOUSING LAW DIARY
 

31 May 2018                            
Stage 3 debate of Housing (Amendment) Scotland Bill (see Housing Laws in the Pipeline)

6 June 2018                             
Completion of the four-week period of intimation for the Regulation of Registered Social Landlords (Wales) Bill (see Housing Laws in the Pipeline)

7 June 2018                             
Consultation closes on reviewing the landlord registration fee structure and application process (Scotland) (see Housing Law Consultations)

12 June 2018                            
Conclusion of the Committee stage of the Tenant Fees Bill (see Housing Laws in the Pipeline)

15 June 2018                           
Re-scheduled second reading of the Affordable Home Ownership Bill (see Housing Laws in the Pipeline)

15 June 2018                           
Consultation closes on powers for dealing with unauthorised development and encampments (see Housing Law Consultations)

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Housing/Debt Supervisor
GN Law Housing team
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Allocations Officer
Teignbridge District Council
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Empty Property Officer
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Operations Manager
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Information and Advice Money Adviser
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Assessment Co-ordinator (Housing Options & Homelessness)
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Anti-Social Behaviour (ASB) Case Officer
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Independent Domestic Violence Advisor
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Homelessness Prevention Officer
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Housing Mediation Officer
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Private Lettings Officer
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