Best practices for landlords to document tenant vulnerability details

Under Awaab’s Law (2025) and related social housing standards, landlords are now legally and ethically required to document tenant vulnerability details to assess risk severity and tailor responses to health or safety hazards. The aim is to safeguard residents whose age, disability, mental health, or medical conditions may increase harm from hazards like damp, mould, or cold exposure. The following outlines best practices based on UK Government guidance, regulatory standards, and local council vulnerability policies.

Lawful Collection and Consent

Obtain informed consent under the UK GDPR and Data Protection Act 2018 before collecting any physical or mental health information.
Tenants must be fully informed about:
- What data is collected and why.
- Who can access it (e.g., housing officers, maintenance teams).
- How it will influence inspection priority, communication, and repairs.
Landlords should seek specific, explicit, and recorded consent for sensitive health data and allow tenants to withdraw it at any time.

Identifying and Recording Vulnerabilities

Best practice requires landlords to actively identify potential vulnerabilities affecting risk from housing hazards:

During initial triage of a reported hazard, staff should identify if any household member has a disability, long‑term health condition, or language or mobility limitation that could increase risk.
Record relevant details in the tenant file or digital housing management system using structured, auditable fields such as:
- Health‑related vulnerabilities (respiratory disease, mobility impairment, mental illness).
- Age‑related vulnerabilities (elderly or young children).
- Communication or language needs.
- Preferred contact methods and reasonable adjustments.

Examples of good documentation practice (from local authority examples such as St Albans and Kirklees):

Note the date, source, and consent for each recorded vulnerability.
Verify accuracy annually during tenancy reviews or home visits.
Restrict viewing permissions to relevant, trained staff.

Integrating Vulnerability Data in Risk Assessment

Under Awaab’s Law, whether a hazard is “significant” or “emergency” depends on the landlord’s knowledge of the tenant’s health circumstances.

This means vulnerability records directly shape the priority level and timeframes for investigations and repairs.
Landlords must ensure these records are linked to housing condition records so inspectors and contractors immediately see vulnerability flags before visits.

Communication and Accessibility Adjustments

Provide correspondence (inspection updates, safety notices) in accessible formats — e.g., large print, Braille, translation, or easy‑read versions for neurodivergent tenants.
Note and adhere to preferred communication channels (email, phone, interpreter).
Record each communication type in the tenant’s file.
Where capacity issues exist (under Mental Capacity Act 2005), document next‑of‑kin or advocate contact details for repair decisions and safety notifications.

Multi‑Agency Collaboration

Where vulnerabilities suggest safeguarding concerns (frailty, self‑neglect, domestic abuse), landlords must record referrals to adult‑social‑care or support agencies following the Care Act 2014 and Safeguarding Vulnerable Groups Act 2006.
Keep cross‑agency communication logs noting who was contacted, when, and why.
Always follow data‑sharing protocols ensuring minimal, lawful disclosure of sensitive details.

Record Audit and Review

Review vulnerability markers at least annually or sooner after major health, household, or property changes.
Conduct quarterly case file audits to confirm accurate recording and enforcement of reasonable adjustments.
Store all related records securely for six years under Awaab’s Law record‑retention rules.

In practice, these steps create a consistent, GDPR‑compliant process allowing social landlords to balance legal precision, privacy, and proactive safeguarding. Documenting tenant vulnerability accurately and respectfully is now a statutory component of both housing safety management and the broader Regulator of Social Housing Consumer Standards framework.

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https://www.housing-ombudsman.org.uk/centre-for-learning/key-topics/awaabs-law/