Overview

The STAIRs (Social Tenant Access to Information Requirements) framework, introduced under the Social Housing (Regulation) Act 2023, aims to enhance transparency for housing association tenants. It bridges the gap with council tenants who benefit from FOI Act 2000 rights.

STAIRs will be implemented in two phases:

  • October 2026: Mandatory proactive publication of housing-related information.
  • April 2027: Statutory right for tenants to request information.
Key Differences – FOI vs STAIRs

Data Protection Considerations

STAIRs must be implemented in line with UK GDPR and the Data Protection Act 2018. For example;

Handling Requests: Handling tenant information requests under STAIRs requires careful attention to data protection principles. Requests may involve sensitive or third-party personal data, and housing associations must ensure that responses are lawful, accurate, and provided within the statutory timeframe of 20 working days.

Proactive Publication: There is a risk of inadvertently disclosing personal or confidential information, making it essential to implement robust redaction protocols and data governance controls.

Exemptions: While STAIRs is expected to mirror some exemptions under the FOI Act, housing associations must be prepared to justify refusals based on personal data, commercial confidentiality, or security concerns, with clear documentation supporting each decision.

Recommended Actions

Housing Associations should consider:

  • Updating data protection policies.
  • Training staff on STAIRs and data minimisation.
  • Maintaining audit trails for accountability.
  • Conducting a DPIA for STAIRs implementation.
  • Establishing a compliant publication scheme.
  • Aligning IT systems and records management with STAIRs requirements.
  • Providing targeted staff training.
Conclusion

STAIRs introduce a new statutory framework for transparency in housing associations. While distinct from FOI, it demands robust data protection practices. Early preparation will ensure compliance and build tenant trust.

For further advice and information please contact

Angela Ward – Director – Housing – angela.ward@tiaa.co.uk